What this policy covers

This Website Privacy Policy (Policy) describes how Holistic Growth Media, Inc. (formerly known as Kareo, Inc.) and our affiliates and subsidiaries (Holistic Growth Media, we, us, or our) collect, use, and disclose information about you or collected from you. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

This Policy pertains to your use of the Holistic Growth Media websites at holisticgrowthmedia.com, and any related services or applications, including our learning center (Site). It also applies to any information we collect from or about you offline, including when you attend Holistic Growth Media events, or in the course of your employment at Holistic Growth Media.

We may also provide different or additional privacy notices in connection with certain activities, programs, and offerings, including additional “just-in-time” notices that may supplement or clarify our privacy practices or provide you with additional choices regarding your personal information.

This Policy does not cover information Holistic Growth Media may collect or receive through our Clinical (Electronic Health Records, or EHR), Billing (Practice Management), or Engage (including Kareo DoctorBase) modules; our Telehealth and Cloud features; or the Patient Portal (collectively, the Platform). For more information about our privacy practices regarding information collected or received through the Platform, please see our Platform Privacy Policy.

This Policy does not cover the privacy practices of third parties. Our Site may include links to websites and/or applications operated and maintained by third parties. We have no control over the privacy practices of websites or applications that we do not own and cannot guarantee that such third parties will adhere to the same privacy practices as us. We strongly encourage you to review the privacy policies of those third parties.

What Information We Collect

The types of personal information we obtain about you depends on how you interact with us and our services. When we use the term personal information, it means information that identifies, relates to, describes, or can be associated with you. We may collect the following categories and specific types of personal information when you visit our Site:

Basic Identifiers
When you use some features on the Site, such as signing up for a webinar or submitting a request for a product demonstration or pricing, we collect basic identifying information from you, including your full name, business address, email address, phone number, account name, signature, or other similar identifiers.

You may also provide personal information about other individuals, such as their name, email address and phone number. For example, if you choose to use our referral service to tell a friend about our Site, we will ask for your friend’s name and email address to send a one-time email inviting your friend to visit the Site. It is your responsibility to get permission from anyone whose personal information you provide to us. We will only use that personal information for the purpose of completing your request.

Commercial Information
When you request product information through our Site, we collect information related to the products or services about which you requested information about.

Professional Information
When you use some features of our Site, like submitting a request for product information, we collect information related to your business, such as your practice specialty and the number of providers at your practice.

User Content
When you communicate with us, we collect information you provide to us, including emails, survey responses, comments, product reviews, testimonials, and other content.

Internet or Other Network Activity
Holistic Growth Media may automatically receive and record information on our server logs from your browser, including your internet protocol (IP) address, your browsing or search history, and information related to your interactions with our Site, emails, or advertisements.

Device Information and Other Unique Identifiers
We collect data about your device and how you and your device interact with our Site, which may include your IP address, device identifiers, cookies, beacons, pixel tags, browser type, device type, operating system, and regional and language settings.

Usage and Performance Data
We collect data related to the use of our Site. This may include your interactions with our Site, error reports, and other data about the performance of our Site. This data helps us to diagnose problems with our Site and to improve various features and solutions for your future use.

Geolocation Data
We may collect information, such as your IP address, that permits us to determine your general location (e.g., your city or state). You may manually provide location information when using our provider search at holisticgrowthmedia.com or enable your mobile device to send us precise location information. In addition, some areas of our Site, like our provider search, may request your precise location information via GPS-based functionality to allow certain features to work. We will ask your permission before we collect or use precise location information, in accordance with any applicable legal requirements to the extent precise geolocation information is considered sensitive information under applicable law.

Employment-Related Information
If you apply for employment at Holistic Growth Media, we collect information from you in connection with your application and interview(s) for employment, including professional or employment-related information (such as education and employment history) and any other information you provide as part of your job application, such as your LinkedIn or other social media profiles. If we retain you as an employee, this may include, among other things, your Social Security number or taxpayer ID. For more information about how we collect and use applicant data, please see our Notice to California Job Applicants Regarding the Collection of Personal Information.

Audio and Visual Information
We may record your voice or likeness, such as when you attend a live webinar or online product demonstration, or when we record customer service calls for quality assurance. If you are an employee of Holistic Growth Media, we may collect audio and video recordings of webinars and video calls.

Provider Site Use
We may also collect personal information, such as Internet or Other Network Activity, Internet or Other Network Activity, and Usage and Performance Data about end users who visit our customers’ websites (each, a Provider Site), solely for and on our customers’ behalf.

Inferences
We may also draw inferences from any of the information identified above.

How We Collect Information

Directly from You
We collect personal information you provide to us, such as when you request product information, contact us, respond to a survey, apply for a job, or sign up to receive emails, text messages, and/or postal mailings. If you are an employee or contractor of a service provider, business partner, or third party we work with, we may collect information when you communicate with us, including basic identifiers, like your name and work email address, and professional information, like your title.

Using Cookies and Other Tracking Technologies
When you use our Site, open or click on emails we send you, interact with our advertisements, we or third parties we work with automatically collect certain information using technologies such as cookies, web beacons, clear GIF, pixels, internet tags, web server logs, and other data collection tools. For more information, please see the Cookies and Other Tracking Technologies section below.

From Social Media Platforms
If you interact with us on social media or use features, such as plugins, widgets, single sign-on, or other tools made available by social media platforms or networks (including Facebook, Twitter, Google, and LinkedIn) in connection with our Site, we collect information that you share with us, or that the social media platforms share with us. For more information about the privacy practices of those social media platforms, please review the privacy policies and settings of the social media platforms and networks that you use.

From Other Sources
We may also obtain information about you from other sources, such as data analytics providers, marketing or advertising service providers, fraud prevention service providers, vendors that provide services on our behalf, or publicly available sources. We also create information based on our analysis of the information we have collected from you.

Cookies and Other Tracking Technologies

The Site uses cookies to recognize your preferences and temporarily store session information on your browser. A cookie is a small text file, which often includes an anonymous unique identifier, that is placed on your computer’s hard drive by a webpage server. Cookies contain information that can later be read by a web server in the domain that issued the cookie. We do link the information we store in cookies to personal information you submit while on our Site.

We have cookies on our Site, but the data is only collected in the aggregate. We use a third-party tracking service that uses cookies and other tracking technologies to track non-personally identifiable information about visitors to our site in the aggregate. If you do not want the Site to deploy cookies in your browser, you can set your browser to reject cookies or to notify you when a website tries to put a cookie in your browser software. You can also manually clear the cookies within your respective browser (for instructions, click here for Firefox; ‍here for Chrome; and here for Safari). If you configure your browser to reject certain cookies, the opt-out may not function properly. If you change browsers or devices, or delete cookies, you may need to opt-out again.

• Strictly Necessary Cookies. These cookies are necessary for the Site to function and do not store any personally indefinable information. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences or submitting forms. If you reject strictly necessary cookies, you may still use our website, but your ability to use some areas of our Site may be limited.
• Performance Cookies. These cookies allow us to measure and improve the performance of our Site by telling us how visitors interact with our Site, including which pages they visit. All information collected through performance cookies is aggregated and anonymous. If you reject performance cookies, we will not know when you have visited our site and will not be able to monitor Site performance.
• Functional Cookies. These cookies enable our Site to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you reject these cookies. some or all of these services may not function properly.
• Targeting Cookies. These cookies may be set through our Site by our advertising partners. They store information that may uniquely identify your browser and device to build a profile of your interests and show you relevant advertisements on other websites. If you reject targeting cookies, you will no longer receive personalized advertisements. See the “Behavioral Targeting / Re-Targeting” section below for more information.

Web Beacons / Gifs
Holistic Growth Media uses software technology called clear gifs or Web beacons to help us better manage content on our Site by informing us what content is effective. These technologies are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. In some cases, we tie information gathered by clear gifs to our customers’ personal information; an example would be tracking emails that have been opened by recipients which allows us to measure the effectiveness of our communications and marketing campaigns.

Third-Party Tracking
The use of cookies by any tracking utility company is not covered by our privacy policy. We do not have access or control over these cookies. Tracking utility company may use session ID cookies and/or persistent cookies.

We use Local Storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon your Web browsing activity also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

Behavioral Targeting / Re-Targeting
We partner with a third-party ad network to either display advertising on our website or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out of interest-based advertising across browsers and devices that participate in the Digital Advertising Alliance or Network Advertising Initiative by visiting their websites here and here, respectively. You may also opt out of interest-based advertising through the settings on your device or within a mobile app, but your opt-out preferences may apply only to the browser or device you are using when you opt out. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

How We Use Information

We use the information we collect for the following purposes:

• Providing Services. For example, if you request a product demo and sign up for our services, we use the information you provided in your demo request to service and maintain your account, provide customer support, and communicate with you about our services.
• Business Operations. For our operational purposes and the operational purposes of our service providers and integration partners. This may include short-term, transient use, such as customizing content that we or our service providers display on the Site.
• Core Functionality and Improvement. We may use information we collect to provide core functionality on and to improve our Site, including for Site analytics.
• Security, Safety, and Dispute Resolution. We use collected information to protect the security and safety of our Site, including to detect bugs, report errors, and to detect, protect against, and prosecute security incidents and fraudulent or illegal activity.
• Communicating With You. If you contact us through the Site, we will use personal information you provide to respond to you. We may also use personal information we collect to communicate with you for other purposes, such as sharing updates about our products and services or providing relevant offers from third-party partners.
• Marketing and Promotional Purposes. We use personal information for marketing and promotional purposes, such as to send marketing, advertising, and promotional communications by email, text message or postal mail (such as promotions, new product launches, and referrals); and to show you advertisements for products and/or services tailored to your interests on social media and other websites.
• Referrals. If you choose to use our referral service to tell a colleague about our Site, we will ask you for your friend’s name and email address. We will automatically send your colleague a one-time email inviting him or her to visit the Site. Holistic Growth Media stores this information for the sole purpose of sending this one-time email. Your colleague may contact us at info@holisticgrowthmedia.com to request that we remove this information from our database.
• Analytics and Personalization. We use personal information to conduct research and analytics, including to improve our Site; to understand how you interact with our Site, advertisements, and communications with you to determine which of our products or services are the most popular, and to improve our Site, Platform, and marketing campaigns; to personalize your experience; to save you time when you use visit our Site; to customize the marketing and advertising that we show you; to understand how you use our Site; to provide services, to better understand our customers’ needs, and to provide personalized recommendations about our products and services.
• Employment Decisions. We use Employment-Related Information to make decisions about recruitment and in anticipation of a contract of employment. Providing this information is required for employment. For more information about how we collect and use applicant data, please see our Notice to California Job Applicants Regarding the Collection of Personal Information.
• Legal Obligations. We may provide access to your information, including personally identifiable information, when legally required to do so, including to comply with a court order, to cooperate with police investigations, or in connection with other legal proceedings.

Disclosed and Other Purposes. We may also use information for other purposes disclosed to you at the time we collect such information. For example, we obtain specific consent from customers prior to posting customer testimonials, comments and reviews on our Site which may contain personal information.

How We Share Your Information

In addition to the specific situations discussed elsewhere in this privacy policy, we disclose personal information in the following circumstances:

• Corporate Affiliates. We may share personal information with our corporate affiliates, including our parent company, sister companies and subsidiaries. Such corporate affiliates process personal information on our behalf as our service provider, where necessary to provide a product or service that you have requested, or in other circumstances with your consent or as permitted or required by law.
• Legal Disclosures. Holistic Growth Media may be required to disclose personal information or protected health information under special circumstances, such as to comply with subpoenas or when your actions violate our Terms of Service. It may be necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Holistic Growth Media’s terms of use, or as otherwise required by law.
• Service Providers. We use service providers to perform services to support our core business functions and internal operations, including providing customer service to you via chatbot; sending postal mail, e-mails, and text messages; analyzing data; investigating fraudulent activity; conducting customer surveys. We may share personal information with such service providers as necessary for the third party to provide that service.
• Business Partners. With your consent, we do share your name and email with certain partners we may work with. If you would not like your information shared with these partners, notify us via info@holisticgrowthmedia.com.
• Third Parties. We may share information with third parties, such as advertising networks, data analytics companies, Internet cookie information recipients, and social media networks. Our Site has features such as, plugins, widgets, single sign-on, or and other tools made available by social media platforms or networks (including Facebook, Twitter, Google, and LinkedIn) that may result in information being collected or shared between us and the third party. For example, if you use Facebook’s “Like” feature, Facebook may register the fact that you “liked” a product and may post that information on Facebook. Their use of your information is not governed by this privacy policy. Third party vendors, including Google, show our ads on sites on the Internet. Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to our Site. Users may opt out of Google’s use of cookies by visiting the Google advertising opt-out page.
• Transfers of Control. We will transfer information about you if Holistic Growth Media is acquired by or merged with another company. In this event, Holistic Growth Media will notify you by email or by putting a prominent notice on the Site before information about you is transferred and becomes subject to a different privacy policy.

In the last twelve months, we may have collected the following categories of personal information from or about you and may have disclosed, shared, or sold that information with certain categories of third parties for the purposes outlined below.

Additionally, if you are a healthcare provider, we may have collected the following categories of personal information from or about you in the last twelve months and may have sold that information to certain categories of third parties for the purposes outlined below.

Where We Store and Process Your Personal Information

Holistic Growth Media, Inc. is based in the United States and uses service providers and have corporate affiliates that may be located outside of the United States.

If you submit personal information to us, your personal information may be processed in a foreign country, where privacy laws may be less stringent than the laws in the United States. By submitting your personal information to us, you agree to the transfer, storage, and processing of your personal information in a country other than your country of residence.

How We Protect Your Information

The security of your personal information is important to us. Personal information is maintained on our servers and those of our service providers, and may be accessible by authorized employees, representatives, and agents as necessary for the purposes described in this Website Privacy Policy.

While we follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we use reasonable and appropriate physical, electronic, and organizational safeguards to protect your personal information, we cannot guarantee its absolute security in all circumstances.

For more information about our security practices, please see our Security Notice. If you have any questions about security on our website, you can contact us at info@holisticgrowthmedia.com.

Your Rights

Depending on your country or state of residence, you may be able to exercise the rights described below. You will not receive discriminatory treatment or retaliated against for exercising any of the rights described below. If you are an employee, applicant, or independent contractor of Holistic Growth Media, you will not be retaliated against for exercising any of the rights described below.

Accessing, Updating, Correcting, and Deleting Your Information
You may have the right to request access to and receive details about or a copy of the personal information we maintain or have processed about you, to update and correct inaccurate information, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. This section describes how to exercise those rights and our process for handling those requests, including our means of verifying your identity. If you would like further information regarding your legal rights under applicable law or would like to exercise any of them, please contact us here. While our contact form is the best way to reach us, you may also email us at info@holisticgrowthmedia.com or call us at (888) 733-1393.

• • Access to Your Personal Information and Data Portability. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive your request and confirm your identity, we will disclose to you:
    • The categories of personal information we collected about you and the sources from which we collected it.
    • Our business or commercial purpose for collecting or selling that personal information.
    • The categories of third parties with whom we share that personal information.
    • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
      • sales, identifying the personal information categories that each category of recipient purchased; and
      • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
    • The specific pieces of personal information we collected about you (also called a data portability request).

We will retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements.

• Updates and Corrections to Your Personal Information.You can update your account by logging into your account, contacting our support team, or calling us at (888) 733-1393. To update your personal information related to your employment at Holistic Growth Media, please email us at info@holisticgrowthmedia.com.

• Deletion of Your Personal Information. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Limiting the Use of Sensitive Personal Information
California residents have the right to limit the use of sensitive personal information. Holistic Growth Media only collects sensitive personal information, such as your social security number, financial account information, and as otherwise defined by applicable law, when you provide it to us, such as in the job application process. We only use such sensitive personal information for the use disclosed at the time you provide it to us. Holistic Growth Media does not use sensitive personal information for inferring characteristics about you.

Opting Out of Cookies and Sale/Sharing Using Online Tracking Technologies
Our use of online tracking technologies may be considered a sale or sharing under applicable law. As a visitor to our Site, you can opt out of being tracked by these third parties by clicking the “Do Not Sell My Personal Information” link at the bottom of our Site and selecting your preferences. Depending on your state of residence, you may also opt out by broadcasting an Opt-Out Preference Signal, such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). To download and use a browser supporting the GPC browser signal. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Provider Site Visitors
If you are a visitor or patient of any of our customers (Provider Site Visitor) and would like to make any requests or queries regarding your personal information, please contact your healthcare provider directly. For example, if you wish to request to access, correct, update, or delete inaccurate personal information processed by Holistic Growth Media on behalf of our customers, please direct your query to the relevant Holistic Growth Media customer who controls such data. If Holistic Growth Media is requested by our customers to remove any Provider Site Visitor personal information, we will respond to such requests in a timely manner upon verification and in accordance with applicable law.

Exercising Your Rights
You can submit a request to access, update, correct, or delete your personal information, or withdraw consent, by submitting a request through our contact form or calling (888) 733-1393.

You may only submit a request to know twice within a 12-month period. Your request must:

• • • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your first and last name and email address.
    • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Identity Verification
For security purposes, we may request additional information from you to verify your identity to enable us to process some requests. In such cases, we may contact you by email to verify your request. Depending on your request, we will ask for information such as your name and the email address associated with your account.

Authorized Agent
If you are a resident of California, Colorado, or Connecticut, you may designate an authorized agent to submit a request on your behalf to exercise your privacy rights described herein. To authorize an agent to do so, you must: (1) provide to such agent your signed permission to submit such request; and (2) verify your own identity directly with us. We may deny a request from an authorized agent if the agent does not provide adequate proof that they have been authorized by you to act on your behalf.

Responding to Requests
Upon receipt of your request, we will respond within the time frame permitted by the applicable law.

Appealing Requests
If you are a Colorado, Connecticut, or Virginia resident, you may appeal our decision to your request regarding your personal information. To do so, please contact us in any of the ways listed in the “Your Rights” section. We respond to all appeal requests as soon as we reasonably can, and no later than legally required.

Promotional Emails
To stop receiving promotional emails, you can click on the “unsubscribe” link at the bottom of any promotional email you receive from us.

Children’s Privacy

Our Site is not intended for or directed to children under the age of 18. We do not knowingly collect personal information through our Site directly from children under the age of 18 without parental consent. If we become aware that a child under the age of 18 has provided us with personal information through our Site, we will delete the information from our records.

We do not knowingly “sell,” as that term is defined under the California Consumer Privacy Act, the personal information of minors under 16 years old who are California residents.

California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you would like more information, please submit a written request to us at: Holistic Growth Media, Inc., Attn: Legal, 1111 Bayside Drive, Corona Del Mar, CA 92625.

Changes to This Website Privacy Policy

Holistic Growth Media may update this Website Privacy Policy at any time for any reason. We encourage you to periodically review this page for the latest information on our privacy practices. We will provide additional notice to you if we make any changes that materially affect your privacy rights.

Questions

If you have questions or suggestions, you can contact us at:

Holistic Growth Media
11226 NE 15th St, STE 6, Bellevue, WA 98004
Phone: (888) 733-1393
Email: info@holisticgrowthmedia.com