SOMOS Privacy Policy

This Policy covers information we collect through the Services. It does not cover information collected by third parties, including Providers acting outside the platform, or by any site we merely link to. Health information you share with your Provider in connection with your care is addressed specifically in our Notice of Privacy Practices, which supplements this Policy.

1. Information We Collect

Information you give us directly, such as your name, contact information, date of birth, insurance information, payment information, and information you enter in intake forms, questionnaires, and the patient portal.

Health-related information, including symptoms, sleep history, diagnoses, treatment notes, and data from at-home sleep testing devices, PAP equipment, and connected wearables (such as continuous glucose monitors or blood pressure cuffs) that you choose to link to your account.

Information collected automatically, including IP address, device and browser type, pages visited, and usage patterns, collected through cookies and similar technologies.

Information from third parties, such as your insurance carrier, a referring provider or practice, or a connected device or wearable platform, where you have authorized that connection.

2. How We Use Information

We use the information we collect to:

• Provide, operate, and improve the Services, including matching you with an appropriate Provider and supporting your care;
• Process payments and insurance claims;
• Communicate with you about appointments, your account, and your care;
• Send you service-related notices and, if you opt in, marketing communications;
• Maintain the security and integrity of the Services;
• Comply with legal and regulatory obligations; and
• Develop and improve our clinical protocols and platform, using de-identified or aggregated data that cannot reasonably be used to identify you.

3. How We Disclose Information

We disclose information:

• To your Provider and their care team, to enable your treatment.
• To service providers and vendors who support our operations (such as hosting, payment processing, and communications), under contracts that limit their use of your information to the services they provide us.
• To your insurance company, where applicable, to obtain payment for services.
• As required by law, including in response to a valid court order, subpoena, or regulatory request.
• In connection with a business transaction, such as a merger, financing, or sale of assets, subject to appropriate confidentiality protections.
• With your consent, for any other purpose you authorize.

We do not sell your personal information to third parties for monetary consideration.

4. Health Information and HIPAA

Certain SOMOS-affiliated entities are "covered entities" under the Health Insurance Portability and Accountability Act ("HIPAA"), and SOMOS's technology platform may act as a "business associate" to those entities and to independent Provider practices that use the SOMOS platform. Protected health information is used and disclosed consistent with HIPAA and our Notice of Privacy Practices, available at joinsomos.com/hipaa-notice.

5. Cookies and Tracking Technologies

We use cookies and similar technologies to operate the Services, remember your preferences, and understand how the Services are used. You can control cookies through your browser settings, though disabling them may limit some functionality. We do not use tracking technologies to serve you advertising based on anything discussed during a clinical consultation, and we do not share clinical notes, diagnoses, questionnaire responses, or messages with advertisers.

6. Data Security

We maintain administrative, technical, and physical safeguards designed to protect your information, including encryption of health information and payment data in transit and at rest. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7. Your Choices and Rights

You may review and update your information through your account, or by contacting us at the information below. Depending on your state of residence, you may have additional rights, including the right to know what personal information we have collected about you, the right to request deletion, the right to correct inaccurate information, and the right to be free from discrimination for exercising these rights. To exercise these rights, contact us using the information in Section 10; we may need to verify your identity before responding, and we will respond within the timeframe required by applicable law.

For information specific to your protected health information, including the right to access, amend, or receive an accounting of disclosures, see our Notice of Privacy Practices.

8. Children's Privacy

The Services are not directed to individuals under 18, and we do not knowingly collect personal information from children. If we learn we have collected information from a child without appropriate consent, we will delete it.

9. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will revise the "Last Updated" date and, where required, provide additional notice. Your continued use of the Services after a change takes effect constitutes acceptance of the update.

10. Contact Us

SOMOS Health, Inc. Attn: Privacy [ADDRESS], Richmond, Virginia [ZIP] [EMAIL] · [PHONE]