Milu Privacy Policy

Effective date: November 6, 2024

What is the purpose of this Privacy Policy?

Milu Health, Inc. (“Milu Health”, “Milu”, “Company”, “we”, “us”, or “our”) recognizes that when you provide us with information about yourself, you trust us to act in a responsible manner with that information. We are committed to making sure we earn that trust. This Privacy Policy discloses Milu’s personal information gathering and disclosure practices with respect to our website (www.miluhealth.com), as well as any other websites, mobile applications, or other products and services provided by us that link to this Privacy Policy (“Services”), and other online and offline interactions with you. When we use the term “personal information” in this Privacy Policy, we mean information that on its own, or in combination with other information, could reasonably identify you.

When you use our Services, we collect, use, and disclose Protected Health Information (“PHI”), which is personally identifiable health information protected by the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”), as a “business associate” to our health plan customers that provide benefits to you (or as a “subcontractor” to one of your health plan’s service providers). This Privacy Policy does not apply to PHI. Our collection, creation, maintenance, use and disclosure of PHI is subject to your health plan’s Notice of Privacy Practices and our agreements with your health plan (or one of your health plan’s service providers). We encourage you to review your health plan’s Notice of Privacy Practices to learn how your PHI may be used and disclosed.

What personal information do we collect and how do we collect it?

The following describes the types of personal and other information Milu may collect about you:

• Direct Identifiers and records about you. If you correspond with us, including by postal, email, or completing a form on our website, we will collect direct identifiers about you such as your first name, last name, email address and other contact information, and we collect the contents of the messages you send.
• Technical information and usage information collected automatically or through tracking technologies. Like many other websites, we collect information automatically through system logs and cookies and other tracking technologies about users’ devices (such as Internet Protocol (IP) address, browser and device types, device identification numbers, or other online identifiers) and users’ utilization and navigation of our Sites. We may also use IP address to help identify you, your non-precise geolocation, and to gather broad demographic information such as age and gender. 
• Information collected from third parties and publicly available sources. We may collect personal information from third parties, such as service and content providers, social media companies or other parties who interact with us. For example, if you interact with us on LinkedIn, we may collect identifiers about you (such as first name, last name, and email address), professional information (such as job title), and contents of messages you send to us or comments you leave on our posts. We may also collect identifiers (such as first name, last name, and email address) from public profiles or websites. 
  

We may combine information that we receive from the various sources described in this Privacy Policy, including third-party sources, and use or disclose the combined information for the purposes identified in this Privacy Policy.

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How do we use personal information?

We may use personal information for the following purposes:

• To make our Services available to you, such as registering, verifying, and maintaining your account with us, communicating with you by telephone, text message, email, or direct mail. (including soliciting feedback or responding to requests, complaints, and inquiries), and providing similar services or otherwise facilitating your relationship with us.
• For our internal business purposes, such as operating and customizing the content on our Services; maintaining internal business records, such as accounting, document management and similar activities, enforcing our policies and rules, management reporting, auditing, and IT security and administration.
• For our internal research and product improvement purposes, such as verifying or maintaining the quality or safety of our Services; improving our products or services, designing new products and services, evaluating the effectiveness of our advertising or marketing efforts, and debugging and repairing errors with our systems, networks, and equipment.
• For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements, investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents and health and safety issues (including managing spread of communicable diseases); and protecting against malicious, deceptive, fraudulent, or illegal activity.
• In connection with a corporate transaction, such as if we acquire, or sell or transfer all or a portion of our business or assets, including through a sale in connection with bankruptcy and other forms of corporate change.
• For marketing and targeted advertising, such as marketing our products or services. For example, we may use personal information we collect to personalize advertising to you (including by developing product, brand, or services audiences and identifying you across devices/sites); to analyze interactions with us or our Services; or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars. You can unsubscribe to our email marketing via the link in the email, or by contacting us using the information in the Contact Information section below. 
  

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

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To whom do we disclose personal information?

We may disclose your personal information with third parties, including the categories of recipients described below:

• We may disclose information that we collect about you to our third-party contractors who perform services for us in order to provide certain services or to complete or confirm a transaction that you conduct with us.
• We may disclose information about you to advertisers, ad platforms and networks, social media platforms, and to third parties whose cookies and tracking tools we use as described in this Privacy Policy.
• We may disclose information about you as part of a merger, acquisition or other sale or transfer of its assets or business. We do not guarantee that any entity receiving such information in connection with one of these transactions will comply with all terms of this Privacy Policy.
• We may disclose information about you for purposes such as to provide services available on the Sites; to coordinate with insurance, reinsurance and excess or stop loss insurers; to enforce our Members’ rights; to protect against actual or potential fraud; to resolve Member inquiries or disputes; to receive payments; to carry out our business; to protect the confidentiality or security of our records; to administer preventive health and case management programs; to perform auditing and ratemaking functions; to enable our service providers to perform marketing services on our behalf and inform Users about our own products or services; to comply with federal or state laws and other applicable legal requirements.
• We may disclose your information, to the extent permitted by law, in court or in the stages leading to possible legal action arising from improper use of the Services or due to a dispute you initiate in connection with the related services.
• We may disclose information about you to the government or to third parties pursuant to legal obligations, such as in connection with illegal activity on our Services or to respond to a subpoena, court order or other legal process. We reserve the right to release information that we collect to law enforcement or other government officials, as we, in our sole and absolute discretion, deem necessary, appropriate or as required under law, such as your statement to hurt yourself or others.

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How does Milu use cookies or other tracking technologies?

Types of Cookies and Other Tracking Technologies We Use. Like most major online services, we or third parties we authorize may use cookies or other tracking technologies on certain pages of our website and other Services. 

• Cookies make using the Internet easier by, among other things, saving your preferences for you. For example, a cookie lets our Services remember that you’ve registered, which allows us to speed up your future activities at our Services, and which allows you to enter your registration information less frequently while visiting our Services. 
  

• Pixels, web beacons, and tags, are types of code or transparent graphics. These technologies provide analytical information about the user experience and help us customize our marketing activities. In contrast to cookies, which are stored on a user's computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages. 
  

• Session replay tools, which record your interactions with our Services, such as how you move throughout our Services and engage with our webforms. In addition to the uses described below, this information helps us improve our Services and identify and fix technical issues visitors may be having with our Services.
  

• Embedded scripts and SDKs, which allow us to build and integrate custom apps and experiences on our Services.
  
  

Purposes of these technologies. We and authorized third parties use cookies and other tracking technologies for the following purposes:

• Personalization, such as remembering language preferences and pages and products you have viewed in order to enhance and personalize your experience when you visit our Services; 
• Improving performance, such as maintaining and improving the performance of our Services; 
• Analytics, such as analyzing how our websites are used. 
• Advertising, such as conducting advertising and content personalization; tracking activity over time and across properties to develop a profile of your interests and advertise to you based on those interests (“interest-based advertising”); providing you with offers and online content that may be of interest to you; and measuring the effectiveness of advertising campaigns and our communications with you, including identifying how and when you engage with one of our ads or emails; and
• Security, such as preventing fraud and malicious behavior.
  

Your Choices. You can refuse or delete cookies using your browser settings. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. If your browser is set to reject cookies, or if your browser notifies you that you are about to receive a cookie and you reject it, then your use of the Services may not be as efficient or as enjoyable as it would be if the cookie were enabled.

Some browsers have incorporated Do Not Track preferences.  At this time, we do not honor Do Not Track signals.

What security measures does Milu employ?

Milu maintains information security safeguards to help protect the privacy of data you transmit through the Services. However, we cannot guarantee the security of any information that is disclosed online.

How long does Milu retain personal information?

Milu retains personal information, subject to this Privacy Policy, only for as long as necessary for the purposes for which the data was collected and processed unless we are required to do otherwise by applicable law. 

How can I correct or update my personal information?

You may request to correct or update information collected about you by managing your account profile (if applicable) or contacting us via the contact information below. If necessary, we may retain original and updated information for reasons such as technical constraints, dispute resolution, troubleshooting and agreement enforcement.

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What are the policies of linked websites and other third party services?

This Privacy Policy only addresses the use and disclosure of certain information Milu collects from or about you. You should be aware that our Services may link to other websites or online services that are beyond our control, and we are not responsible for the privacy practices of such third-party services. We encourage you to read the posted privacy policy of such third-party services for details about their privacy practices.

How will I know about changes to this Privacy Policy?

We may update this Privacy Policy i from time to time. Please check this page periodically for updates. Any updated Privacy Policy will effective upon posting to the Services.  If required by law, we will contact you directly to provide you with an updated Privacy Policy.

Does Milu collect information directly from children?

Milu does not knowingly collect or maintain personally identifiable information from persons under 18 years old, except when authorized and shared by parents or guardians,  and no part of our Services is directed to persons under 18.

If you are a parent or guardian and believe we have inadvertently collected information from a child under 18, please contact us using the contact information below under “Contact Us”. If we learn that we have collected personal information directly from a child under 18, we will take steps to delete the information.

International Users

Our Services are directed toward users in the United States. If you use our Services from outside of the United States, you acknowledge that information that we collect about you will be transferred to servers inside the United States.  Data protection laws of the United States may differ from data protection laws in your country.

Contact Us

If you have questions want to submit a request, have concerns about this Privacy Policy, or would like to report a violation, see the below contact options:
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You may contact us by mail at:

Milu Health, Inc.
135 West 50 Street
New York, NY, 10065

You may email us at privacy@miluhealth.com.

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