Copay Technologies, LLC
PRIVACY POLICY
Last updated: May 1, 2025

INTRODUCTION:
Copay Technologies, LLC (“Copay” “we,” “our” or “us”) has prepared this notice (the “Privacy Policy”) to explain the privacy practices of Copay. You (“you” or “your”) should read this Privacy Policy carefully to understand how Copay collects and uses personal information and data. This Privacy Policy applies to your use of all Copay websites, software applications (including hosted software), and mobile apps that we provide or that are provided on our behalf that link to this Privacy Policy (collectively, “Digital Media”).
Please note the following sections that include important disclosures related to our website and services:

Cookies and Other Tracking Technologies: To learn more about how our Digital Media uses cookies and related technologies (including from third parties), see Cookies and Other Tracking Technologies
Your Choices Disclosures: To learn more about your choices concerning your information, see YOUR CHOICES RELATING TO YOUR PERSONAL INFORMATION

Changes to this Privacy Policy. We review this Privacy Policy regularly and may update it from time to time. Any and all changes will be reflected on this page, and where appropriate will be provided in person or by another electronic method. The date of the last update is stated at the top of this Privacy Policy. You should regularly check this page for any changes to this Privacy Policy.

PERSONAL INFORMATION THAT WE COLLECT:
Our Services on our Digital Media enable you to type in a particular medical issue and receive a list of medical care facilities (“Facilities”) in your geographic area that may provide the type of health care that you may be seeking, including a display of the aggregate healthcare costs at such providing Facilities based on insurance and health plan for that type of care. We also provide user ratings and reviews for Facilities and encourage users to provide us with their own ratings and comments on their experiences for the Facilities they use.
In connection with our business and services provided to customers, we collect and process the following categories of personal information of individuals:

Basic identifying information, such as your name and email address.
Location information, such as your zip code.
Other individual identifiers, including insurance information and medical costs.
Device identifiers, including your IP address and similar device identifiers, and other information relating to your device, such as your operating system, browser, network, and device type (desktop, tablet, or mobile phone).
Subscription information, including information regarding your use of our software, mobile app(s), or other services.
Internet use information, such as browsing or search history and other information regarding your interactions with our website(s), emails, and advertisements.
Regulatory information to satisfy regulatory obligations such as tax and other reporting obligations.
Account Credentials, including your username, password, password hints, and information used for authentication and account access.
Profile Information, such as your locations, treatment history, historical medical queries interests, preferences, and treatment history.
Communications Content, such as any messages you send to us such as feedback and questions to customer support, information you publicly post on our websites or other websites (such as product reviews or blog comments), e-mail messages, and recordings of telephone calls with customer service or other Copay representatives, and interactions with us on our social media channels.

HOW WE COLLECT YOUR PERSONAL INFORMATION:
General. We collect personal information when you create an account with us; visit our website; subscribe to, license or use our software, services or products; participate in a feature of our application and web services that requests or requires your personal information; and when you otherwise transact business with or communicate with Copay.
Directly from You. We collect information directly from you when you create an account with us, search a Facility or medical service, subscribe to or license our software or Digital Media, update your profile, or engage in communications directly with us, including without limitation chat windows, email, instant messaging, written, and in-person communications.
Information Collected Automatically. When you visit our website(s) or use our Digital Media, information about your electronic device is automatically collected, including a Universally Unique Identifier (“UUID”), browser type, domain name, access times, geographic location, referring website address and other technical information. For more information, see Cookies and Other Tracking Technologies below.
Information Collected from Third Parties. We use a variety of third-party companies in connection with providing our website, products and services, including analytics providers and social media providers, and may collect information about you from such third parties for providing our products and services, and other business and commercial purposes. We may also collect additional personal data about you from our third-party services providers (e.g., the Apple® App Store® or the Google PlayTM store) who provide us with e-commerce and/or technical related services/support associated with the functionality and purposes of the Digital Media. Where the Digital Media is available as a mobile application, the application is downloaded from Apple’s App Store or Google Play and may be subject to their privacy policy and terms and conditions.
Cookies and Other Tracking Technologies: We use analytics providers, including Google Analytics, and other tracking technologies and cookies to collect information. Tracking technologies are used to collect information from your web browser through our servers or filtering systems when you visit any of our websites.

Cookies store small text files onto a user’s computer hard drive with the user’s browser, containing the session ID and other data. Cookies enable a web site to track a user’s activities on the website for the following purposes: (1) enable essential features; (2) provide analytics to improve website performance and effectiveness; (3) store user preferences; and (4) facilitate relevant targeted advertising on advertising platforms or networks. Users are free to change their web browsers to prevent the acceptance of cookies. Cookies may also be set within emails in order to track how often our emails are opened.

Necessary Cookies. These cookies are necessary for you to browse the websites and use their features, such as accessing secure areas of the websites. Without these cookies, certain aspects of the websites may not be available to you.

Preferences Cookies. These cookies collect information about how you have used the websites in the past and allow the websites to remember the choices you have made. These cookies allow us to improve how the websites work for you and tailor the websites to your preferences.

Statistics Cookies. These cookies collect information about how you use the websites, such as which pages you most often visit on the websites, the time you spend on the websites, which links you click on, and any issues encountered. These cookies help us understand how visitors interact with the websites. All information collected is aggregated and do not identify you.

Marketing Cookies. These cookies track your online activity to help deliver advertisements that are relevant to you and your interests and measure the effectiveness of the advertising campaigns. They also limit how many times you see a certain advertisement. We may share the information collected through these cookies with others, such as advertisers.

Information collected from these technologies may include but is not limited to your browser type, your operating system, your language preference, any referring web page you were visiting before you came to our site, the date and time of each visitor request, and information you search for on our sites. We can also track the path of page visits on a website and monitor aggregate usage and web traffic routing on our sites. We collect this information to better understand how you use and interact with our sites in order to improve your experience. We also collect this information to better understand what services and marketing promotions may be more relevant to you. We may also share this information with our employees, service providers, business partners and affiliates.
You can change your web browser settings to stop accepting cookies or to prompt you before accepting a cookie from the sites you visit. If you do not accept cookies, however, you may not be able to use some sections or functions of our sites.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org.

HOW WE USE YOUR PERSONAL INFORMATION:
We may use and process personal information for any purpose that is permitted under applicable data protection laws in accordance with this Privacy Policy. “Processing” of personal information includes collecting, recording, organizing, structuring, storing, altering or modifying, retrieving, transmitting, disclosing or otherwise making available to third parties, deleting, and otherwise using or dealing with your personal information. We may process your personal information with or without automatic means.
These purposes include:

Our business purposes, including addressing customer service issues; processing marketing leads; planning and conducting marketing activities; responding to inquiries; conducting web analytics and business operations and administration; and addressing tax and other regulatory requirements.

Purposes related to our software products, including SaaS or cloud-based software. These purposes include licensing and operation of the software, education and information services, communication, customer service, system monitoring and data security. We use personal information to enable use of software features and related services, including through use of third-party service providers. We also use personal information to communicate with our users (e.g., via push notifications in our software applications) to inform them of software updates and enhancements, educational information, available software features and modules, and other information that may helpful or informative for our users.

Marketing and Advertising. Copay sends users marketing communications to inform them of new products, services, promotions, or other special events or offers that might be of interest to them (“Special Offers”). When you register for one of our products or services, you consent to receiving communications about Special Offers. In connection with Special Offers, we may ask for contact information or other personal information. If you would like to stop receiving information about Special Offers from Copay, please see YOUR CHOICES RELATING TO YOUR PERSONAL INFORMATION

For the Protection of Copay and Others. If Copay, in good faith, determines that you have used the service to menace, threaten, harass, intimidate or otherwise deceptively pose as another person, or in any other way in violation of law. Simply, if you attempt to use the website or purchase or use a product for any unlawful means, you have no expectation of privacy and we may use and disclose any and all information for the protection of Copay and others.

Pursuant to Law, Rule or Regulation. If required or permitted to do so by law or if, in good faith, Copay believes that such action is necessary to: (1) comply with laws and regulations or with legal processes; (2) protect and defend Copay’s rights and property or prevent fraud; (3) protect Copay against abuse, misuse or unauthorized use of Copay’s products or services; (4) protect the personal safety or property of our personnel, users of our website or the public; and/or (5) comply with tax reporting requirements, then Copay may use and disclose any and all information as needed. The servers that serve our website automatically identify a computer by its IP address.

De-identified data. We may de-identify, anonymize and/or aggregate personal information of users of Digital Media and other products and services, as well as Digital Media usage and performance data that is not identifiable as to any person (collectively, “De-Identified Data”). De-identified Data may be retained and used by Copay to improve its products and services and for other proper purposes, subject to applicable laws.

HOW WE SHARE OR DISCLOSE YOUR PERSONAL INFORMATION:
Sale of personal information. We do not sell or rent personal information to third parties. However, certain of our online tracking technologies may be considered a “sale” or a “share” of your information to third parties under the California Consumer Privacy Act (CCPA) or other applicable privacy laws. Visitors to our website can opt out of being tracked by these technologies by following the instructions below under YOUR CHOICES RELATING TO YOUR PERSONAL INFORMATION or by contacting us as set forth in the COPAY CONTACT INFORMATION section below.
Disclosures of personal information. Depending on the circumstances, we may share your information in the following circumstances:

With Your Consent. We may disclose, share, or make available your information with your consent, which may be obtained in writing, online, through “click-through” agreements, when you accept our terms for our websites, orally (including over the telephone), or by other means such as communications through our various social media channels.

Service Providers Providing Services on Our Behalf. We may disclose or share your information with certain non-affiliated third parties to facilitate your access and use of our application and web services, and to provide us with certain business functions, including but not limited to sharing your information with data analytics providers

In a Business Transfer or with Our Affiliates. We may disclose, share, or make available your information as part of a business transaction, such as a merger or acquisition, joint venture, corporate reorganization, financing, or sale of Copay assets, or in the unlikely event of insolvency, bankruptcy, or receivership, in which such information could be transferred to third parties as a business asset in the transaction. We may also share personal data with our affiliated companies for our organization’s internal business purposes, as described in this policy.

For Legal Process and Protection. We may access and disclose your personal data to regulatory bodies if we have a good-faith belief that doing so is required under regulation or in order to defend and protect our legal rights. This may include submitting personal data required by tax authorities. Additionally, we may disclose your personal data and other information as required by law, including in response to lawful requests by public authorities, including law enforcement and judicial authorities.

De-identified Data. We reserve the right to disclose De-Identified Data (such as anonymous or aggregated usage data) in order to market and describe our services to prospective partners, licensees, advertisers, and other third parties.

TRANSFER AND STORAGE OF PERSONAL INFORMATION:
We may transfer, process and store personal information collected from our application and web services in centralized data centers and with service providers in the United States, cloud storage solutions, or on our premises.
Our software and mobile apps are cloud-based. This means they are stored in and run from the cloud, specifically an Amazon Virtual Private Cloud (“VPC”). Amazon VPC guarantees the security and privacy of its VPC. The Amazon servers we utilize are hosted in the USA. For more details, visit https://aws.amazon.com/vpc/.

HOW WE PROTECT PERSONAL INFORMATION:
We take commercially reasonable steps to protect your personal information in accordance with all applicable laws and regulations, as appropriate to the sensitivity of your information. Copay uses technical and organizational measures to protect the personal data that we store, transmit, or otherwise process, against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed. Although we are committed to employing reasonable technology in order to protect the security of our website, even with the best technology, no website is 100% secure. In transacting business with us through our website, you assume the risk inherent in transacting business online.

RETENTION OF PERSONAL INFORMATION:
We keep your information for as long as necessary in accordance with the purposes for which it was collected, our business needs, and our legal and regulatory obligations. It is Copay’s policy to delete users’ personal information upon termination of an account or your contract with Copay. If we dispose of your information, we will do so in a way that is commercially reasonable taking into account the sensitivity of the information.
Copay reserves the right to retain usage data relating to our products and services, as well as data that has been anonymized and/or aggregated, to the extent permitted by applicable laws. With respect to any personal information collected by us for marketing or for our own internal purposes, we will retain that data for a reasonable time in order to fulfill those purposes.

YOUR CHOICES RELATING TO YOUR PERSONAL INFORMATION:
General. If you wish to opt out of any of the uses of personal information that are specified in this Privacy Policy, except in the case of legal proceedings or where your data is required for tax and transactional purposes, please contact us as described in the COPAY CONTACT INFORMATION section below. We will comply with requests to the extent required by law. Even if not required by law, we have a policy of honoring and respecting the requests of all data subjects when it is reasonable and practical to do so and does not place an undue administrative burden on our Copay. Please note that your subsequent disclosure of personal information to us may override prior opt-out requests. Copay does not discriminate against those who opt out. However, opting out may prevent us from conveniently and efficiently providing further product support services and information to you.
.
Push Notifications. If you have opted-in to receive push notifications on your device, you can opt out at any time by adjusting the permissions in your device or uninstalling our mobile application.
Analytics. Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.

OTHER U.S. PRIVACY RIGHTS.
Several U.S. states have passed comprehensive privacy laws that are in effect as of the date this Privacy Policy was last updated or are scheduled to go into effect in the near future. Some municipalities have also passed specific laws protecting certain privacy rights. These laws, as well as federal laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA), may or may not apply to Copay. Copay’s policy and intent is to comply with all applicable obligations under federal, state and local privacy laws.

LINKS TO AND PRIVACY POLICIES OF OTHER WEBSITES:
Our websites, from time to time, may contain links to third-party websites and services. Please note that these links are provided for your convenience and information, and may operate independently from us and have their own privacy policies and/or notices. You are strongly encouraged to review such policies or notices. We do not endorse or make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other materials available on other websites, even if one or more pages of the other websites are framed within, or linked to, a page of our websites.

CHILDREN’S DATA:
Our website is not intended or designed to be used by anyone under the age of 13 and children’s personal information should not be shared with us. Copay does not collect personal information from any person it knows to be under the age of 13. Additionally, if you are between the ages of 13 and 17, do not transact with us through this website or otherwise, and do not send any personal information, unless you are supervised by a parent/guardian or have received permission from your parent/guardian.

COPAY CONTACT INFORMATION:
If you have any questions about this Privacy Policy or your personal information that we hold, would like to cease receiving marketing materials from us, have any complaints, or would like to exercise any of your other rights related to your personal information, please contact us:

Copay Technologies, LLC
Contact: Customer Service
Address: 617 Warren Avenue
Ho-Ho-Kus, NJ 07423
E-mail: [email protected]