Privacy Policy

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Effective as of March 12, 2025  

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This Privacy Policy describes how Concentra AI Inc. ("Concentra AI," "we", "us" or "our") processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, My Connect Post-Op web-application product, our mobile application, website and social media pages as well as our marketing activities and other activities described in this Privacy Policy (collectively, the “Service”)). At or near the time we collect personal information, Concentra AI may provide additional or supplemental privacy policies to individuals for specific products or services that we offer.

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Our Service is intended to provide a platform for patients recovering from surgery (“Patients”) to connect with their physicians and care team (“Physicians”) and utilize our Services’ artificial intelligence capability for normal recovery questions so that such Patients may obtain information and guidance from the Service and their Physician throughout the Patient’s recovery process. For purposes of this Privacy Policy, we refer to Patients, Physicians and others collectively as “Users.” If you are a Patient, your personal information may be subject to our agreement with the relevant enterprise customer (the “Covered Entity,” as such term is defined under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”)) through which your Physicians provide their services. Please read the relevant Covered Entity’s Notice of Privacy Practices to understand how your personal information can be used and disclosed by such Covered Entity. If you have  questions regarding how the Covered Entity may process your personal information or how we do so in service to the Covered Entity, please direct your question to that Covered Entity. If you are a participant in a clinical trial that Concentra AI sponsors, your personal information may be subject to additional notices, consents and documentation such as the relevant clinical trial protocol and/or informed consent. Depending on the nature of your relationship with us, we may have different collection, use and sharing purposes. For example, we will not use personal information that we collect in the context of clinical trials for which we are a sponsor for product development and commercialization purposes. 

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Index

Personal information we collect

Information Patients provide to us or that we may generate about Patients. Personal information you may provide to us through the Service or otherwise or that we may generate about you includes:

  • Contact data, such as your first and last name, salutation, email address and phone number.
  • Demographic data, such as your city, state, country of residence, postal code and age.
  • Patient Profile data, such as the username and password that you may set to establish an online account on the Service, physicians’ names, date of birth and any other information needed for your account profile.
  • Communications data, such as when you use the Service to communicate with your Physician, contact us through the Service, chat features including chat prompts, or otherwise. 
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  • Patient-generated content data, such as reviews, chat prompts, comments and other content or information that you generate or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that Patients can add or can have added to their content, such as keywords, geographical or location information, and other similar data. 
  • Health related data, such as reported recovery status, symptoms, activity levels, sleep patterns, medication usage, diet information, and other information uploaded to the Service and provided to Physicians to inform them about Patients’ recovery progress.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Information Physicians provide to us or that we may generate about Physicians. Personal information you may provide to us through the Service or otherwise or that we may generate about you includes:

  • Business contact data, such as your first and last name, email address, and medical entity affiliation, and phone number.
  • Physician profile data, such as the username and password that you may set to establish an online account on the Service, photograph or picture, biographical and any other information that you add to your account profile.  
  • Communications data, such as when you use the Service to communicate with your Patients, contact us through the Service, social media, chat features (including chat prompts), or otherwise. 
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  • Other data, not specifically listed here which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

  • Public sources, such as public records, social media platforms, and other publicly available sources.
  • Private sources, such as your employer or the medical entity with which your affiliated.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

  • Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
  • Communication interaction data, such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails. 

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

Tracking technologies

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

  • Cookies, which are small text files that websites store on User devices and that allow web servers to record Users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers’ place. 
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications. 
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked. 
  • Session-replay technologies, such as those provided by LogRocket and Google Analytics that employ software code to record Users’ interactions with the Services in a manner that allows us to watch video replays of those User sessions. The replays include Users’ clicks, mobile app touches, mouse movements, scrolls [and keystrokes/key touches]* during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about LogRocket at https://logrocket.com/privacy and Google Analytics at https://marketingplatform.google.com/about/analytics/terms/us/
  • Chat and other artificial intelligence (“AI”) technologies, such as those provided by us or another party that employ cookies and other software code to operate the chat features that you can use to communicate through the Service and interact (including provide inputs and other prompts) with our AI service features. To operate the chat and AI features, we and the relevant other party may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats for the purposes described in this Privacy Policy.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

  • provide, operate and improve the Service and our business;
  • enable security features of the Service;
  • establish and maintain your profile on the Service;
  • communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
  • enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in; and
  • provide support for the Service, and respond to your requests, questions, and feedback.

Service personalization, which may include using your personal information to:

  • understand your needs and interests;
  • personalize your experience with the Service and our Service-related communications; and
  • remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand User activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as User interactions with our emails, and to develop new products and services. 

Marketing. We and our service providers may collect and use your personal information for marketing purposes:

  • Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.

We do not use personal information that we collect in the context of clinical trials that we sponsor for advertising purposes.  

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  • enforce the terms and conditions that govern the Service; and 
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.  

Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

  • Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
  • Functionality. To enhance the performance and functionality of our services.
  • Analytics. To help us understand User activity on the Service, including which pages are most and least visited and how visitors move around the Service, for example, we may use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.   

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.  

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as artificial intelligence large language model, hosting, information technology, customer support, online chat functionality providers, email delivery, marketing, consumer research and website analytics). 

Third parties designated by you. We may share your personal information with third parties, such as insurance companies (to verify coverage) and Covered Entities, where you have instructed us or provided your consent to do so. 

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above. 

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in or financings of Concentra AI, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Concentra AI as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Other Users. Your profile and other User-generated content data may be visible to other Users of the Service such as the Physicians you share your personal information with on the Service. For example, Patients receive and otherwise use certain Physician personal information and Physicians receive and otherwise use certain Patient information. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others, and we are not responsible for any such use of this information.

Your choices 

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account. Please contact your Physician to assist with updating other account information not amendable through your account. 

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. 

Cookies.  Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

Other sites and services

The Service may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, and online services you use.

Security 

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information. 

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.  

Children  

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy 

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

Email: Support@concentra.ai