Privacy Policy

About this Privacy Policy

Your privacy is important to us. We know how important it is for you to understand how we use your data. This Privacy Policy sets out how and why we collect, store, process and share your personal data. We will always be transparent with you about what we do with your personal data.

This Policy also tells you what your rights are in relation to the personal data you give to us. If you have any questions about this Privacy Policy or your rights under it please contact support@streamlinemedicalgroup.com

1. What personal data do we collect?

This notice applies to all information collected or submitted on www.streamlinemedicalgroup.com. The personal data we collect from you directly can include your name, email address, mobile/landline telephone number, date of birth, gender, address, major symptoms, your purchasing activity, your credit, or debit card or other payment information, and information you give us when you contact our customer service team, when you engage with our social media platform (for example by tagging us in a post on Instagram) or when you sign up for text or email communications.

If you are using a mobile device and shopping with us online or browsing our website, we may collect your IP address or other device identifier, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other portable device information.

We may, where we have a lawful basis for doing so, also collect personal data about you from third parties who provide us with additional publicly available information about you.

2. When do we collect your personal data?

• When you purchase products and services from us online, or over the phone
• When you access our website
• Our website also uses cookies; to find out more about the use of cookies and how you can manage them, please read our Cookie Policy
• When you contact us or we contact you to take part in surveys, competitions or promotions
• When you contact our customer service team online or over the phone
• When you engage with us on social media (by mentioning/tagging us or by contacting us directly)

3. How do we use your personal data and what are our legal justifications for doing so?

To make our products and services available to you

We use your personal data to provide you with the information, products and services that you request or purchase from us (i.e. to complete certain tasks, processes or orders on our website, take payment online (where applicable) and deliver your products or services), and to communicate with you regarding those products that you purchase from us and respond to your questions and comments;

We may also use your personal data to measure how satisfied our customers are and provide customer service (including troubleshooting in connection with purchases or when you ask us questions on social media);

We rely on our contractual arrangements with you as the lawful basis on which we collect and process your personal data when you make an order for products. Alternatively, in some cases, we rely on our legitimate interests as a business (for example, to measure customer satisfaction and troubleshoot customer issues). Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so.

For administrative and internal business purposes

We may use your personal data for our internal business purposes, such as enhancing our site, improving our services and products and identifying usage trends. We may also use your data to monitor the use of our website and ensure that our website is presented in the most

effective and relevant manner for you and your device and setting default options for you (such as language);

It is in our legitimate interests as a business to use your personal data in this way. For example, we want to ensure our website is customer friendly and works properly and that our products and services are efficient and of high quality. We also want to make it easy for you to interact with us. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.

For security and legal reasons

We use your personal data to:

• ensure the personal and financial information you provide us is accurate;
• conduct fraud checks or prevent other illegal activity;
• protect our rights or property (or those of others); and
• fulfill our legal and compliance-related obligations.

In some cases we will use your personal data because it’s necessary for us to comply with a legal obligation (such as if we receive a legitimate request from a law enforcement agency). In other cases (such as the detection of fraud) we will rely on our legitimate interests as a business to use your personal data in this way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.

Our marketing purposes

We use your personal data to personalize your experience with Streamline Medical Group to:

• provide you with marketing material via SMS, post and email if you have given us your consent to this;
• process your registration details, account activity and purchase history to analyze how you shop and what you shop for. This may include information on products you have viewed, historical transactions and products you have added to your online basket. This allows us to provide a browsing experience which is relevant to you;
• in some instances we will send specific offers to our members based on a special occasion such as when we know it’s your birthday;
• measure the effectiveness of our marketing campaigns and our advertising;
• carry out limited automated decision-making based on the information you have given us when we segment our database to determine which offers that you may be interested in.

We rely on your consent to send direct SMS, postal and email marketing messages to you as a patient based on the consent we acquired from you when you signed up, as amended by you from time to time.

In other cases (for example, measuring the effectiveness of our marketing), we will rely on our legitimate interests as a business to communicate with our patients in an engaging and efficient way. Where we rely on our legitimate interests, we will always make sure that we balance these interests against your rights.

To personalize your shopping experience and improve our operations

We use your personal data to:

• allow you to create a profile on our website which enables you to purchase products and services online without having to fill in your personal data every time you shop online with us;
• provide you with marketing material via SMS and email;
• analyze how you shop and what you shop for. This may include information on products you have viewed, historical transactions and products you have added to your online basket. This allows us to provide a browsing experience that is relevant to you.

It is in our legitimate interests as a business to use your data in this way and we do this in order to enhance your shopping experience with us. This allows us to help you find the products and services that you may be looking for and avoids you having to browse through products or services which are not relevant to you.

When we send you marketing material via SMS, and email, we will rely on our legitimate interests as a business, always ensuring that your rights are protected.

For information on how we may use cookies, please see our Cookie Policy below.

4. Who do we share your personal data with?

We will never sell any of your personal data to a third party. However, in order for us to provide our services to you, we share your personal data with our trusted third party service providers or our group companies, as detailed below. Whenever we share your personal data, we put safeguards in place which require these organizations to keep your data safe and to ensure that they do not use your personal data for their own marketing purposes.

Third party service providers

To fulfill orders for products and services:

We work with a number of trusted service providers who carry out services on our behalf. When you purchase products and services from us, the services provided by these organizations includes delivery and processing payments. It is in our legitimate interests as a business to work with these service providers since we may not have the capabilities to provide these services ourselves. In each case, we will ensure that the service provider is only

allowed to use your personal data in order to provide the services to us and for no other purpose.

To prevent crime and comply with laws:

We share your financial information including your credit, debit card or other payment information with third parties to ensure that your payment is safe and that your details are not being used fraudulently. This data sharing enables us to conduct fraud analysis which ensures that genuine and accurate payment details are provided to us for any purchase.

There may be other scenarios where we are subject to a legal obligation to share or disclose your personal data, such as with law enforcement agencies or public authorities in order to prevent or detect crime or fulfill a legal requirement.

Other professional services:

We may need to disclose your personal data to our insurers where we believe that it is required under our contractual relationship with our insurance provider to do so.

We work with carefully selected third parties, such as our customer database-hosting provider, marketing agencies and advertising partners who assist us in providing you with a positive customer experience. We work with these third parties to place relevant content and advertisements for you on our website, other websites and online media channels and apps. In order to do this, we may use pixels and cookies. You can see our Cookie Policy below.

5. Your rights

You have a number of rights relating to your personal information and what happens to it. You are entitled to:

• have your data processed in a fair, lawful and transparent way;
• be informed about how your personal data is being used, an example being this privacy policy;
• access personal data we hold about you;
• require us to correct any mistakes in your personal data;
• require us to delete personal data concerning you in certain situations where there is no good reason for us to continue to process it;
• request that we transfer your personal data to you or another service provider in a simple, structured format;
• object at any time to processing of your personal data for direct marketing purposes;
• object to automated decision making which produces legal effects concerning you or similarly significantly affects you;
• object in certain other situations to our continued processing of your personal data; and
• otherwise restrict or temporarily stop our processing of your personal data in certain circumstances.

6. Changing your preferences

If you no longer wish to be contacted by us about our products or services, or for other marketing purposes, you can amend your preferences or unsubscribe by contacting us at support@streamlinemedicalgroup.com.

We want to ensure that all the information we have about our customers is factually correct and up to date. If you find that the personal data we have about you is inaccurate or needs updating (for instance, you may have changed your name or address) then please contact us so that we can correct it. If you have created a profile on the Streamline website, you can change the details stored about you by logging into your account.

7. Security of your personal data

Security Methods

We maintain administrative, technical and physical safeguards to protect your personal information. When we collect or transmit sensitive information such as a credit or debit card number, we use industry standard methods to protect that information. However, no e- commerce solution, website, database or system is completely secure or “hacker proof.” You are also responsible for taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.

Email Security

“Phishing” is a scam designed to steal your personal information. If you receive an email that looks like it is from us asking you for your personal information, do not respond. We will never request your password, user name, credit card information or other personal information through email.

CHILDREN’S PRIVACY

This Site is not intended for use by children under 18. We do not knowingly collect Personal Information from anyone under 18 years of age. If we become aware that we have unknowingly collected Personal Information from a child under the age of 18, we will make commercially reasonable efforts to delete such information from our database.

8. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make significant changes we will let you know but please regularly check this policy to ensure you are aware of the most updated version.

This Privacy Policy was last updated on January 29, 2019

9. Security Policy

Your payment and personal information are always safe. Our Secure Sockets Layer (SSL) software is the industry standard and among the best software available today for secure commerce transactions. It encrypts all of your personal information, including credit card number, name, and address, so that it cannot be read over the internet.

10.Payment Policy

Accepted Methods of Payment:

• U.S. issued Credit and Debit Cards (Visa, Master Card, American Express, Discover)

When placing an order online, you will need:

• Billing Address and Shipping Address (if different)
• The full card number and expiration date
• The 3 or 4 digit code found only on the card (CVV2 code)

You are entering into a legally binding agreement with Streamline Medical Group Naples LLC, a Florida limited liability company, located at 893 Vanderbilt Beach Road, Naples, Florida 34108.

11.Credit Card Charges

Your credit card will be charged when you place your order. If we are not able to fulfill your order for any reason, your credit card will be refunded.

12. Auto Ship Cancellation

Please email to cancel or modify your auto ship at any time at Support@StreamlineMedicalGroup.com without penalty. You can also modify or cancel your order at any time within your portal. By agreeing to the “auto-ship” option on our order form, you are giving Streamline Medical Group authorization to enroll you in the Automatic Shipping Program. Our manufacturer will ship your products directly to you on a monthly basis. You are also authorizing Streamline Medical Group to charge your credit card for the products you have ordered on a monthly basis. You may cancel at any time without obligation and without penalty by emailing Support@StreamlineMedicalGroup.com or canceling the order on the portal. All Auto Ship cancellations must be performed within 3 business days of the next shipment to guarantee

cancellation of that shipment. Streamline Medical group will allow a one-time grace period refund if the automatic shipping has not been canceled within the 3 business days required.

13. Order Disclaimer

Your electronic order confirmation, or any form of confirmation, does not signify our acceptance of your order. Streamline Medical Group reserves the right to accept or deny shipment to anyone for any reason. Streamline Medical Group reserves the right to require additional information before processing any order. If an order appears fraudulent in any way, Streamline Medical Group reserves the right to cancel the order, notify the card holder and the proper authorities.