Golden Phoenix Healthcare Technologies (“GPHT” or “GP”) understands how important the privacy of personal information is to our users. This Privacy Policy will tell you what information we collect about you and your use of GP and its services. It will explain the choices you have about how your personal information is used and how we protect that information. We urge you to read this Privacy Policy carefully.

This Privacy Policy applies to websites owned and operated by GP that are intended for use by consumers (non-professionals) for non-commercial personal, family, or household purposes, including gphxhealth.com, gpheart.com, and Mobile GP-RPM™ AI Applications or "Apps" (we refer to these sites and Apps collectively as the “GP Sites”). We refer to the GP Sites and Apps, along with the information and services made available to you through the GP Sites and Apps, as the “Services.”  For third-party vendors who are delivering labs and pharmacies to your home, GP only refers the services to the partnering vendors.  We will refer to these partnering vendors as GP Vendors.

This Privacy Policy also applies to the consumer-facing version of the GP RPM AI Product. However, if you are an employee, governmental payer, or health plan member who has enabled access to your health record at gpheart.com or GP-RPM™ AI app by registering at your employer's, governmental payer’s or health plan's website, the privacy policy applicable to your information at your employer's, governmental payer’s or health plan's website remains applicable to your personal health record at gpheart.com. If your employer or health plan account is no longer made available to you by your employer or health plan, you will continue to have access to your health information from the gpheart.com GP-RPM™ AI app, using the same username and password, but will be subject to this Privacy Policy.

Except where noted, statements in this Privacy Policy with respect to the GP Sites also apply to the Apps. If you do not want us to collect, use, or disclose information about you and your use of the Services as described in this Privacy Policy, then you should not use the Services. By using the Services, you must agree to the GP Terms of Use, which is the contract between us and the users of the Services.  By accepting the GP Terms of Use, you confirm that you have read and understand this Privacy Policy and the GP Cookie Policy and you acknowledge that we will store, use, and otherwise process your information in the United States where we are located.

References to "GP," “we” or “us” mean Golden Phoenix Healthcare Technologies, Inc, including any company that GP controls (for example, gpheart.com & sofinnetwork.com  a subsidiary that GP owns). GP may share information among its subsidiaries or websites that it owns or controls, but information collected under this Privacy Policy is always protected under the terms of this Privacy Policy. Except as otherwise noted in this Privacy Policy, GP is the data controller responsible for the processing of your personal information as described in this Privacy Policy. 

Information Collected About You

Some of our Services (such as certain music therapy AI for artists under Sofinnetwork.com) do not retain your personal information, while others (such as RPM AI in the GP App) store your personal information following this Privacy Policy. Even if you do not register with or provide any personal information to GP, we collect information about your use of the GP Sites and Apps and Services. We may also acquire information about our users from external sources.

When you use the Services, we collect information as follows:

Registration

While you may use most of the Services without registering, certain Services do require that you register with GP for them to function properly. If you choose to register or update an existing account with GP or access certain Services, you may be required to provide certain personal information, such as your name, address, telephone number, gender, email address and date of birth, and a username and password to access your GP account. You are responsible for ensuring the accuracy of the personal information that you submit to GP.

Interactive Services

Some of our Services, such as GP MedGenie AI and GP-RPM™ AI, are interactive and may request that you submit health-related information, along with other information such as your age and gender. You are not required to register with GP to use GP-RPM™ AI and if you are registered with GP, we will associate information that you submit to the GP-RPM™ AI with registration information that you have previously provided.

GP RPM AI 

GP RPM AI provides you with a secure place to gather, store, manage and share your personal information and provides tools and services to better manage your health and the health of your family. You are required to register with GP to use GP-RPM™ AI.  GP-RPM™ AI has the ability to use information that you provide to send you personalized emails or secure electronic messages. However, GP does not allow any third parties to gather any data about you in connection with your use of the GP RPM AI including through the use of cookies and other tracking technologies, unless you consent to the third parties' services yourself.  Furthermore, GP will deliver messages to you regarding education and valuable new features developed by GP physicians, i.e. MedGenie AI for educational purposes, but does not use any information that you submit in connection with GP-RPM™ AI to deliver any 3rd party advertisements to you on or off of the GP Sites. 

GP Vendors - Lab Testings and Pharmacy Delivery to Home (Pending Future GP Vendors):

Certain GP users located in the United States may be eligible to participate in potential future partnering GP Lab Testing, GP Pharmacy, GP Stem Cells, and other products, (i.e. PWNHealth, Everly Health, Forhers.com, hims.com, Sollagen.com, Calecim.com, etc. ), which enables you to place a secure online order for certain lab tests or medications order as potential future third-party vendors unrelated to GP-RPM™ AI. Once you’ve ordered your tests or pharmacy, you’ll visit a specific designated website for their testing center or online e-commerce pharmacy websites where: 1. For labs -  an experienced lab technician will collect your samples; 2.  For Pharmacy - a seamless qualified online order for home delivery medications. GP will select qualified vendors to provide care coordination (including independent physician review of test orders, online pharmacy orders, etc.) and other administrative services (including processing credit card payments for the lab test orders and pharmacy orders). Ordering a lab test or pharmacy orders with GP Lab Testing and GP online pharmacy partners requires you to register with GP. GP will share the personal information you use to register with GP with GP vendors for purposes of processing and administering your lab test order and/or pharmacy orders. You will be able to access your lab test orders, pharmacy orders, and results from GP Vendors through your GP account but GP will not receive your lab test results or your payment information unless you consent to enhance MedGenie AI to give you better educational advice utilizing your own lab data, then share the analyzed information with your doctors via GP vendors. Only GP vendors will have access to this information unless you consent to another party. GP vendors may disclose to GP certain personal information in the aggregate that does not identify you. GP Vendors will use your personal information and other information it collects about you in providing the GP Vendors services in accordance with its own privacy policy and terms of use available, which are not under GP‘s control. When you interact with GP Vendors you may interact with certain website pages that are hosted by GP or by GP Vendors. This Privacy Policy describes what information GP collects about you when you use GP’s Services and how that information is used, disclosed, and maintained by GP. GP Vendors’ privacy policy and terms of use will appear on any website page that is hosted by GP Vendors, not hosted by GP.. For the avoidance of doubt, this Privacy Policy only applies to the GP Site pages hosted by GP. GP and GP Vendors will use cookies and other tracking technologies to collect information about your usage of GP Vendors' services, including which lab tests you have viewed, and which medication you ordered, and to statistically analyze trends and other user behavior on the GP Vendors’ pages. Other than GPVendors, GP does not allow any third parties to gather any data about you in connection with your purchase of a lab test through GP Vendors partnered services including through the use of cookies or other tracking technologies. Furthermore, GP does not use any personal information that you submit in connection with GP Vendors to deliver any advertisements to you on or off of the GP Sites. We only use GP data to inform you about GP's new features, services, and products offered by GP Sites or GP Vendors.

Email Newsletters

At registration and at various times as you use the GP Sites, you will be given the option of providing us with personal information to receive informational/promotional newsletters – such as a newsletter relating to a specific health condition or new features – via email from GP and/or directly from third parties. From time to time GP may offer users of third-party websites the opportunity to subscribe to our newsletters through those websites. If you elect to subscribe to one of our newsletters on a third-party website, the operator of that website will provide us with the personal information you have provided in connection with the subscription request, which we may use following this Privacy Policy as though you had provided it directly to GP. 

Email and/or Text a Friend

If you use our Email and/or Text a Friend service to tell a friend about a feature on a GP Site or a newsletter, we will ask you for your name, your email address, and your friend's email address. We will automatically send your friend a one-time email inviting him or her to visit the site using your name and email address as the "from" email address. GP does not use your friend's email information for any other purpose. We will only use the information you provide to send the requested email to your friend.

If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please use the Contact Us link provided at the bottom of every page of the GP Sites.

Market Research

From time to time, GP may conduct online research surveys on behalf of itself and third parties through email invitations, pop-up surveys, and online focus groups. When participating in a survey, we may require you to provide your location, age, and if there are sweepstakes associated with the market research survey, your name and contact information for purposes of sweepstakes administration. The information you submit in a survey may be used by GP for research and measurement purposes, as described below, including to measure the effectiveness of content, advertising, or programs. The personal information you provide in connection with a sweepstakes entry will be used for the sole purpose of administering the sweepstakes and as required by applicable law. We will not knowingly invite individuals who are under the age of 13 to participate in market research surveys. Market research surveys conducted by or on behalf of GP will contain a link to this Privacy Policy.

User Reviews and Other Public Forums

In connection with the use of our GP Physician Directory, users can submit provider reviews. Our reviews feature in the Physician Directory and are open to the public and should not be considered private.

Any information (including personal information) you share in any review, or other forum is by design open to the public and is not private. You should think carefully before posting any personal information in any public forum. What you post can be seen, disclosed to, or collected by third parties and may be used by others in ways we cannot control or predict, including contacting you for unauthorized purposes. As with any public forum on any site, the information you post may also show up in third-party search engines.

Emails You Send to GP

This Privacy Policy does not apply to information, content, business information, ideas, concepts or inventions that you send to GP by email. If you want to keep content or business information, ideas, concepts, or inventions private or proprietary, do not send them in an email to GP.

Services and Device Information

When you access and use the Services, GP automatically collects and stores in its server logs information from your browser or mobile device such as your IP address or unique device identifier, browser information (including referring URL), your preferences and settings, cookies, and information about the content you have viewed and actions taken (e.g., search queries, ad engagement, clicks and the associated dates and times). GP may also collect device-specific information when you install and use an App including your device model, operating system information, advertising ID (which is a unique, user-resettable identification number for advertising associated with a mobile device), and App version and usage information. When enabled by you, we collect precise location information provided by your mobile device, which you may disable through the device settings.

Precise Geolocation Data

When enabled by you, we collect precise location information provided by your mobile device, such as latitude and longitude. We do so to provide you with more relevant content including advertising based on your location. You may disable the collection and use of your location data through your device settings. To change location settings on your device, please refer to your device’s official knowledge base.

Cookies and Other Tracking Technologies

We and our partners use cookies to collect information about your use of the Services. “Cookies” are small data files assigned to your browser when you visit a GP Site which enables recognition of your browser and collects and stores information about your use of the Services, as described above. In addition to cookies, we and our partners use other tracking technologies that collect information about your use of the Services, including mobile identifiers and "web beacons" which are small graphic files (sometimes called “clear GIFs” or “web pixels”) embedded in a web page or email typically used to monitor activity and send relevant information back to a home server (which can belong to the host site, a network advertiser or some other third party). The information collected by such tracking technologies may be combined with other information that our partners have access to, including your name, email address, and physical address, so that we can send you materials, either electronically or by direct mail, that may be of interest to you. 

Our advertising service partners may use cookies and other tracking technologies to collect information about your use of the GP Sites, including content you have viewed. These third parties may use this information to help GP deliver advertising on the GP Sites and other third-party websites based on your browsing activity on the GP Sites. GP may further tailor the advertising on the GP Sites and these other third-party websites based on additional information to the extent known by GP or these third parties. A few of the third parties that GP works with but is not limited to are Google, Microsoft, Amazon, Face Heart, YouTube, TikTok, and Facebook. We refer to them as “GP T-Vendors”. In addition to using the information it collects performing services for GP, GP T-Vendors may also use such information as described in its privacy policy. To see how GP T-Vendors may use information collected through our use of the GP T-Vendors services on the GP Sites visit Google’s as one of the few https://www.google.com/policies/privacy/partners.  While Facebook does not provide any personal information to GP, Facebook may use information that it has about you and that it collects performing services for GP (which may be associated with personal information that Facebook has about you) as described in its privacy policy available at https://www.facebook.com/about/privacy.  For other GP T-Vendors, you will need to visit its own privacy policy sites to ensure you consent to your own personal information use.   Any GP T-Vendors may use information that it has about you and that it collects performing services for GP (which may be associated with personal information that GP T-Vendors have about you) as described in its privacy policy available at its own sites, outside of GP’s control. As you review GP T-Vendors’ privacy policy, you have consented to their use of your personal information, including your personal health information (PHI) at your own risk.  

To provide you with certain personalization and advertising services described herein, when you use our GP Sites, we may share information that we may collect from you, such as your email address (in hashed form), IP address, or information about your browser or operating system, with our service provider, LiveRamp Inc., and its affiliates, which may in turn link demographic or interest-based information to your browser. To opt out of this use, visit https://liveramp.com/opt_out/.

We also work with third-party ad networks to display advertising on our GP Sites and on third-party websites. Our ad network vendors use technologies to collect information about your activities on the GP Sites and in our flagship GP App to provide you cookie-based targeted advertising on our GP Sites and on third-party websites based upon your browsing activity and your interests.

For more information about how our cookies and other tracking technologies are used in connection with the Services, please read our Cookie Policy.

When you download and install one of our Apps onto your mobile device we assign a random number to your App installation. This number cannot be used to identify you personally, and we cannot identify you personally unless you choose to become a registered user of the App. We use this random number like our use of cookies as described in this Privacy Policy and GP Cookie Policy. Unlike cookies, the random number is assigned to your installation of the App itself and not a browser, because the App does not work through your browser. Therefore, the random number cannot be removed through settings. If you do not want us to use the random number for the purposes for which we use cookies, please do not use the Apps. Our use of cookies and other tracking technologies on our mobile-optimized sites and our flagship GP App are similar to our use on our desktop sites. For your choices to reject cookies, the Network Advertising Initiative and the opt-out mechanism described below in the section "Your Choices and Rights" are available on our flagship GP App and on our mobile-optimized sites.

Cross-Device Tracking

We and our service providers collect and store information about users' interactions with unaffiliated websites and applications that use our technologies, including cookies and similar tracking technologies. This allows us to infer the presence of a common user or household behind multiple devices. We do so in order to:

• provide personalized advertising on each device or AI software services that are inferred from the browsing patterns on all of the devices;
• detect and prevent fraud;
• allow users to use our service on one device and pick up seamlessly where they left off on another device; 
• limit the number of times a user is shown the same advertisement, across known or inferred devices

For information on your advertising choices and opt-out, please see the "Your Choices and Rights" section of this Privacy Notice.

How Information Collected About You Is Used

Information about your use of the Services may be used for the following purposes:

• to provide, improve and create new Services,
• to respond to your inquiries and to send you administrative communications about the GP Sites and Services,
• to obtain your feedback about the GP Sites and Services,
• to send you secure electronic messages and personalized emails pertaining to your interests as inferred from your use of the Services, including news, announcements, reminders and opportunities from GP,
• to statistically analyze trends and user behavior and activity including how frequently areas of the GP Sites are visited, how the Services are being used and how many emails are received and opened,
• to provide you and people with similar demographic characteristics and interests with more relevant content including advertising both on and off the GP Sites and Apps,
• to offer lead generation services,
• to detect and defend against fraud and other threats to the Services and our users, 
• to identify issues with the Services,
• to conduct research and measurement activities, including those described below, and
• to administer your account.

In addition, GP may use personal information about you for other purposes that are disclosed to you at the time we collect the information and/or with your consent.

GP may combine your personal information and other information collected about your use of the Services, and also supplement with information from external sources for the purposes described in this Privacy Policy. For example, information that GP collects about you may be combined by GP with other information available to GP through third parties for research and measurement purposes, including measuring the effectiveness of content, advertising, or programs. This information from other sources may include age, gender, demographic, geographic, personal interests, product purchase activity, or other information. We may report aggregate information, which is not able to be identified back to an individual user of the GP Sites, to our current or prospective advertisers and other business partners.

Sharing Your Information

 

GP Subsidiaries and Corporate Affiliates

We may share your information with our subsidiaries, affiliates, and companies acquired by or merged with us and our affiliates for their use for the purposes outlined in this Privacy Policy. We will partner with our affiliate, PulsePoint, Inc., for the purposes set forth in this Privacy Policy, including for measurement, analytics, identification, personalization, and in connection with advertising and sponsored programs. Subject to applicable law, we may share your information with PulsePoint, which may also use cookies and other tracking technologies described herein, for behavioral or targeted advertising, and to provide us analytics, insights, actions and other information related to your use of the Services or those of third parties and to its clients to provide similar services to you. Please review PulsePoint’s privacy policy for more information on its privacy practices. In the event of a corporate change in control resulting from, for example, a sale to, or a merger with, another entity, or in the event of a sale of assets or a bankruptcy, GP reserves the right to transfer your personal information to the new party in control or the party acquiring assets. In the event of such a change, your personal information will continue to be treated following this Privacy Policy unless any changes to the Privacy Policy are made following the section below that discusses “Changes to This Privacy Policy.”

Companies and Contractors that Work with GP

GP works with third-party companies and contractors that help us provide the Services and to otherwise assist in the operation of the GP Sites and Apps, including those that provide services relating to technology, data analysis, research, email management and deployment, sweepstakes and contest administration, advertising and marketing and/or content. If you are in the United States, we may also partner with certain service providers to better understand your experience on the GP Sites, including technology that enables us to review and optimize the Services based on your interactions with certain pages (e.g., how much time you spend on which pages, which links you choose to click, what you do and don’t like, etc.) in an aggregated format. GP contractors sometimes have limited access to your information in the course of providing products or services to GP. We contractually require that our contractors not use or disclose your information for any purpose other than providing the limited service or function for GP.

Third-Party Advertisers and Third-Party Websites

We may share information that we have about you, such as a cookie ID or IP address, with third-party advertising service providers who may use this information, on our behalf, to help GP deliver advertising on the GP Sites as well as on third party websites, as further described in our Cookie Policy.

Certain content, services, and advertisements offered to you through the GP Sites are served on or contain links to, websites hosted and operated by a company other than GP ("Third Party Websites"). GP does not share your personal information with these Third Party Websites without your consent, but you should be aware that any information you disclose to these Third Party Websites once you access these Third Party Websites is not subject to this GP Privacy Policy. GP does not endorse and is not responsible for the privacy practices of these Third Party Websites. You should review the privacy policy posted on the Third Party Website to understand how that Third Party Website collects and uses your information. GP makes an effort to make it obvious to you when you leave a GP Site and enter a Third Party Website, either by requiring you to click on a link or by notifying you about the GP Site before you visit the third-party site. In addition, if you see a phrase such as "Powered by" or "in association with" followed by the name of a company other than GP, then you are on a website hosted by a company other than GP.  When you use a co-branded service (a service operated with a partner of GP, such as GP Lab Testing), or register or otherwise provide information on a co-branded site, where applicable, we may pass the collected information back to that partner, which may include third-party service providers whose services are embedded into and/or appear within the Services.

We may also include social widgets on the GP Sites which enable you to interact with the associated social media services, e.g., to share an article and written educational content created by Open AI. These widgets may collect browsing data which may be received by the third party that provided the widget and are controlled by these third parties. You may be able to manage your privacy preferences directly with the applicable social network platform.

Compliance with Law, Regulation, and Law Enforcement Requests

To cooperate with government authorities and law enforcement officials, and private parties to enforce and comply with the law, we may release personal information to third parties: (1) to comply with legal requirements such as a law, regulation, search warrant, subpoena or court order; (2) when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; or (3) in special cases, such as in response to a physical threat to you or others, to protect property or defend or assert legal rights. In addition, we may disclose personal information as described below.

How Your Information is Secured and Retained

We take reasonable security measures to protect the security of your personal information. Despite GP's efforts to protect your personal information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted.

The security of your personal information is important to us.  When you enter personal information (including personal health information in various Services and apps), we encrypt the transmission of that information or use SSL connections (Secure Socket Layer) technology.

We will retain your personal information as long as your account is active or as needed to provide you with Services. At any time you can remove your personal information or instruct us to remove it, but you should be aware that it is not technologically possible to remove each and every record of the information you have provided to GP from our servers. See “Your Choices and Rights” below for more information on how you can update or remove your personal information. We will also retain your personal information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.

Your Choices and Rights

Updating/Removing Your Personal Information

If you do not want your personal information used by GP as provided in this Privacy Policy, you should not use the GP Sites, Apps, and Services.  You can correct, update, or review personal information you have previously submitted by going back to the specific Service, logging in, and making the desired change. You can also request access, correction, or deletion of personal information by contacting us using the contact information listed below or through the Contact Us link provided at the bottom of every page of the GP Sites.

If you have registered and desire to delete any of the registration information you have provided to us from our systems please contact us using the contact information listed below in the “Contacting GP About Your Personal Information or Privacy” section or through the Contact Us link provided at the bottom of every page of the GP Sites. Upon your request, we will delete your registration information from our active databases and where feasible from our backup media. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to the GP Sites from our servers.

You can unsubscribe from an email newsletter by:

• Following the directions included at the bottom of the newsletter and using the “Unsubscribe” link found in the emails.
• Logging in to the GP Sites and unchecking the newsletters you no longer wish to receive under the “My Profile” section.

If you decide that you would prefer not to receive personalized email or secure electronic messages from the GP RPM AI tool, you may also "Opt-out" of the Service by clicking on the settings tab on your GP RPM AI app’s home page and changing your email preference or following the unsubscribe instructions included in each email.

All promotional emails that GP sends with opportunities from GP or with offers or informational materials from GP on behalf of our sponsors will contain an opportunity to unsubscribe from getting additional emails of that type in the future from GP unless you re-subscribe.

Cookies

Most browser software can be set to reject Cookies. Most browsers offer instructions on how to reset the browser to reject Cookies in the "Help" “Settings” or “Preferences” section of your browser’s toolbar.  Refer to our Cookie Policy for additional information about opting out of Cookies.

Interest-Based Advertising Opt-Out

In order to give you more control over your privacy choices we have implemented a DAA (Digital Advertising Alliance) approved opt-out mechanism for interest-based advertising. At the bottom of every page of the GP Sites, you will see an AdChoices logo (which looks like this:

).  In our flagship GP App, you can find the AdChoices option in the “Settings” screen.  By clicking on that logo on the GP Sites or following the instructions in the flagship GP App, you will be presented with a window that will identify all of the companies that GP uses to direct tailored advertisements to you, both on the GP Sites and in the flagship GP App as well as on third-party websites. If you would like to stop this tailored advertising from GP, you can manage these advertisements through the choices in that window. Please note that even if you opt out of interest-based advertising, you will continue to receive generic advertisements through the Services. Please note that your choice to stop tailored advertising is specific to the browser or mobile device that you are using so if you make a choice to opt out from one computer or mobile device and you want your opt-out to apply to a different computer or mobile device as well please opt-out from that computer or mobile device too. By clicking the + symbol next to the name of a vendor in that window you will get information about how and where that vendor assists us with the delivery of advertisements. The GP Sites do not respond to web browser "do not track" signals. This opt-out mechanism is currently not available in the flagship GP RPM AI App for iOS and Android, as well as on our mobile-optimized sites, 

Mobile Opt-out

You may also control interest-based advertising on your mobile device by enabling the “Limit Ad Tracking” setting in your iOS device’s settings or “Opt out of Ads Personalization” in your Android device’s settings. This will not prevent you from seeing advertisements but will limit the use of device advertising identifiers to personalize ads based on your interests.  If you have questions about how to reject cookies on your specific device please check with the device manufacturer.

U.S. Residents

If you are a resident of a U.S. state with applicable data privacy laws in effect, such laws may provide you with additional rights regarding our use of your personal information. For more information relevant to your opt-out, please click here.

Children

We are committed to protecting the privacy of children. The GP Sites are not designed or intended to attract children under the age of 13. The GP Sites do not collect personal information from any person we actually know is under the age of 13. A parent or guardian, however, may use GP RPM AI to establish a personal health record and a GP RPM AI home page for a minor. The parent or guardian is solely responsible for providing supervision of the minor's use of GP RPM AI. The parent or guardian assumes full responsibility for ensuring that the registration information is kept secure and that the information submitted is accurate. The parent or guardian also assumes full responsibility for the interpretation and use of any information or suggestions provided through GP RPM AI for the minor.

Note to Users Outside of the United States

GP and our technical infrastructure are located in the United States.  The personal information that you provide to us is stored on servers located in the United States. If you are located in another jurisdiction, you should be aware that in order to provide the Services to you, we must transfer your personal information to the United States where it will be stored and processed in accordance with this GP Privacy Policy. We may transfer your information outside the United States to service providers with operations in other countries. By using the Services, you consent to such collection, storage, and processing in the United States and elsewhere, though the United States and other jurisdictions may not afford the same level of data protection as considered adequate in your own country. We will take reasonable steps to protect your personal information. Note that your personal information may be available to the United States government or its agencies under legal process made in the United States.

Additional Information for GP’s Visitors from the European Economic Area (“EEA”)

When you use the Services, we collect, store, use, and otherwise process your personal information as described in this Privacy Policy. We rely on a number of legal bases to process your information, including where: (i) necessary for our legitimate interests in providing and improving the Services including offering you content and advertising that may be of interest to you; (ii) necessary for our legitimate interest in keeping the Services, Sites and Apps safe and secure; (iii) necessary for the legitimate interests of our service providers and partners; (iv) necessary to perform our contractual obligations in the GP Terms of Use; (v) you have consented to the processing, which you can revoke at any time (however a revocation does not affect the lawfulness of processing of your personal data that occurred prior to the date of revocation); (vi) you have expressly made the information public, e.g., in public forums; (vii) necessary to comply with a legal obligation such as a law, regulation, search warrant, subpoena or court order or to exercise or defend legal claims; and (viii) necessary to protect your vital interests or those of others.

If you are a GP user in the EEA, you can: (i) access personal information we have about you (we will try to provide information within 30 days of your request); (ii) have your personal information corrected or deleted (in most cases you can correct the personal information you have submitted to us by going back to the specific Service, logging-in and making the desired change); (iii) in certain circumstances, you can object to our processing of your personal information and we will discontinue such processing unless we have compelling legitimate grounds to continue; (iv) withdraw consent previously provided (however a withdrawal does not affect the lawfulness of processing of your personal data that occurred prior to the date of withdrawal); or (v) if you believe that we have not complied with applicable data protection laws, you may lodge a complaint with your local supervisory authority. If you wish to inquire as to whether we maintain any of your personal information and if so, whether you wish to exercise any of those rights that are available to you with respect to such personal information, you may contact us as described in the Contacting GP About Your Personal Information or Privacy section below. We will respond to your request within a reasonable timeframe.

Where we process your personal information for direct marketing purposes, you can opt out through the unsubscribe link in the email communications we send to you, by changing your subscription preferences in your account settings or as otherwise specified in this Privacy Policy.

We will retain your personal information for as long as necessary to provide the Services to you and fulfill the purposes described in this Privacy Policy. This is also the case for third parties with whom we share your information to perform services on our behalf.  When we no longer need to use your personal information and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it.  If you have registered with GP and you no longer want us to use your registration information to provide the Services to you, you may close your account.

Contacting GP About Your Personal Information or Privacy

Please send us an email by using the Contact Us link at the bottom of every page of the GP Sites if you have any questions about this Privacy Policy or the personal information we maintain about you. We will respond to your request within a reasonable timeframe.

You can also contact GP’s Privacy Office at:

Golden Phoenix Healthcare Technologies, Inc.
Attn: Office of Privacy
895 Dove Street, Suite 300,
Newport Beach, CA 92660
info@gphxhealth.com

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

GP users from the EEA may also contact our Data Protection Officer at info@gphxhealth.com

Changes to this Privacy Policy

We reserve the right to change or modify this Privacy Policy and any of our Services at any time and any changes will be effective upon being posted unless we advise otherwise. If we make any material changes to this Privacy Policy we will notify you by means of a notice on the GP Sites and/or by email to our registered users (sent to the email address specified when you register) prior to the change becoming effective. By continuing to use the Services after changes are made to this Privacy Policy, you agree to such changes.  We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. If you do not accept the terms of this Privacy Policy, we ask that you do not register with us and that you do not use the GP Sites. Please exit the GP Sites immediately if you do not agree to the terms of this Privacy Policy.