Privacy Policy

Introduction

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Raya Health, Inc. and its subsidiaries (“Raya,” “we,” or “us”) owns and operates websites (the “Websites”) located at www.rayahealth.co and may have previously, now or in the future own and/or operate a Raya mobile application (collectively, the “Platform”). Your access and use of the Platform, any part thereof, or anything associated therewith, including its content (“Content”), any products or services provided through the Platform or otherwise by Raya, and any affiliated website, software or application owned or operated by Raya (collectively, including the Platform and the Content, the “Service”) are subject to this Privacy Policy unless specifically stated otherwise. Capitalized terms not otherwise defined in this Privacy Policy have the same meaning as set forth in the Raya Terms and Conditions (“Terms and Conditions”).

We are committed to respecting the privacy of users of the Service. We created this Privacy Policy (“Privacy Policy”) to tell you how Raya collects, uses, and discloses information in order to provide you with the Service.

By creating, registering, or logging into an account through the Service, or otherwise accessing or using the Service, you are acknowledging the most recent version of this Privacy Policy. We will update this Privacy Policy when necessary to reflect material changes in the Service or how we use personal information, and as required by applicable law. If we make any changes to our Privacy Policy, we will post the revised Privacy Policy and update the “Last updated” date at the top of the Privacy Policy. If we make material changes to this Privacy Policy, we will provide notice or obtain consent regarding such changes as may be required by law.

If you are using the Service on behalf of an individual other than yourself, you represent that you are authorized by such an individual to act on such an individual's behalf and that such individual acknowledges the practices and policies outlined in this Privacy Policy.

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Limitations on Use by Minors

The Service is generally intended for use by individuals who are at least eighteen (18) years of age or such older age as may be required by applicable state laws in the jurisdiction in which an individual utilizes the Service. Individuals who are between the ages of thirteen (13) and eighteen (18) (or such older age of majority) may use the Service for the sole purpose of obtaining a medical consultation for the treatment of acne using topical skincare products (to the extent made available) if a parent or legal guardian provides consent to such use in accordance with the requirements set forth in our Terms and Conditions and the Service. The Service is not designed or intended to attract, and is not directed to, children under thirteen (13) years of age. If we obtain actual knowledge that we have collected personal information through the Platform from a person under thirteen (13) years of age, we will use reasonable efforts to refrain from further using such personal information or maintaining it in retrievable form.

Furthermore, if you are under sixteen (16) years of age, then you (or your parent or legal guardian if you are under age 13) may at any time request that we remove content or information about you that is posted on the Platform. Please submit any such request (“Request for Removal of Minor Information”) to either of the following:

By mail: Raya Health, Inc., Attn: Privacy Officer, 2269 Chestnut Street, #523, San Francisco, CA 94123, with a subject line of “Removal of Minor Information. If you send by mail, please send by U.S. Certified Mail, Return Receipt Requested to allow for confirmation of mailing, delivery and tracking.
By email: privacy@rayahealth.co, with a subject line of “Removal of Minor Information”
For each Request for Removal of Minor Information, please state “Removal of Minor Information” in the email or letter subject line, and clearly state the following in the body of the request:

1. The nature of your request
2. The identity of the content or information to be removed
3. The location of the content or information on the Platform (e.g., by providing the URL)
4. That the request is related to the "Removal of Minor Information"
5. Your name, street address, city, state, zip code and email address, and whether you prefer to receive a response to your request by mail or email

We will not accept any Request for Removal of Minor Information via telephone or facsimile. Raya is not responsible for failing to comply with any Request for Removal of Minor Information that is incomplete, incorrectly labeled or incorrectly sent.

Please note that we are not required to erase or otherwise eliminate, or enable erasure or elimination of such content or information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule or regulation requires Raya to maintain the content or information; when Raya maintains the content or information on behalf of your Providers (as defined in our Terms and Conditions) as part of your electronic medical record; when the content or information is stored on or posted to the Site by a third party other than you (including any content or information posted by you that was stored, republished or reposted by the third party); when Raya anonymizes the content or information, so that you cannot be individually identified; when you do not follow the aforementioned instructions for requesting the removal of the content or information; and when you have received compensation or other consideration for providing the content or information.

The foregoing is a description of Raya’s voluntary practices concerning the collection of personal information through the Service from certain minors, and is not intended to be an admission that Raya is subject to the Children’s Online Privacy Protection Act, the Federal Trade Commission’s Children’s Online Privacy Protection Rule(s), or any similar international, federal, state, or local laws, rules, or regulations.

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Protected Information

When you set up an account with Raya, you are creating a direct customer relationship with Raya that enables you to access and/or utilize the various functions of the Platform and the Service as a user. As part of that relationship, you provide information to Raya, including but not limited to, your name, email address, shipping address, phone number and certain transactional information, which we do not consider to be “protected health information” or “medical information.”

However, in using certain components of the Service, you may provide certain health or medical information that may be protected under applicable laws. Raya is not a “covered entity” under the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its related regulations and amendments from time to time (collectively, “HIPAA”). One or more of the Labs, Pharmacies or Medical Groups (as defined in our Terms and Conditions) may or may not be a “covered entity” or “business associate” under HIPAA, and Raya may in some cases be a “business associate” of a Pharmacy or Medical Group. It is important to note that HIPAA does not necessarily apply to an entity or person simply because there is health information involved, and HIPAA may not apply to your transactions or communications with Raya, the Medical Groups, the Providers, the Labs, or the Pharmacies. To the extent Raya is deemed a “business associate” however, and solely in its role as a business associate, Raya, may be subject to certain provisions of HIPAA with respect to “protected health information,” as defined under HIPAA, that you provide to Raya, the Medical Group or the Providers (“PHI”). In addition, any medical or health information that you provide that is subject to specific protections under applicable state laws (collectively, with PHI, “Protected Information”), will be used and disclosed only in accordance with such applicable laws. However, any information that does not constitute Protected Information under applicable laws may be used or disclosed in any manner permitted under this Privacy Policy. Protected Information does not include information that has been de-identified in accordance with applicable laws.The Medical Groups and Providers have adopted a Notice of Privacy Practices that describes how they use and disclose Protected Information. By accessing or using any part of the Service, you acknowledge receipt of the Notice of Privacy Practices from your Medical Group and Provider(s).

By accessing or using any part of the Service, you understand that any information that you submit to Raya that is not intended and used solely for the provision of diagnosis and treatment by the Medical Group and Providers, laboratory services by the Labs or prescription fulfillment by the Pharmacies, is not considered Protected Information, and will be subject only to our Privacy Policy and any applicable state laws that govern the privacy and security of such information. For purposes of clarity, information you provide to Raya in order to register and set up an account on the Platform, including name, date of birth, username, email address, shipping address, and phone number, are not considered Protected Information.

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