Privacy Policy

Last updated 12/14/2020

Highlander Factory, Inc. d/b/a Healthcare Innovation Solutions (“HCIS”) are committed to respecting the privacy and security of your personal information. This Privacy Policy describes the information collected on our website (www.healthcareinnovationsolutions.com) and any current or future mobile application (collectively, the “Platform”). This Privacy Policy applies only to the Platform.

By using the Platform or by providing your information to us, you consent to the collection, use, and disclosure of your information in accordance with this Privacy Policy, the Terms of Use, and any written agreement(s) executed and in effect in connection with any of our products or services.

1. What Information is Collected by HCIS or its Service Providers and When

The information we receive and how we use it depends on what you do when visiting the Platform. The Platform and related services may require registration for access. As part of registration and related services, we ask you to provide us certain information about you. You may provide us and our service providers personal information using the Platform in a number of ways, for example by entering that information into data fields on the Platform (e.g., by creating an account, participating in surveys, or requesting our newsletters) or in communications with us using the contact information at the end of this Privacy Policy or in the Terms of Use. Personal information includes data that specifically identifies you, such as your name, email address, mailing address, telephone number, and payment information. Public information is that information that you make publicly available through your account or by posting or otherwise communicating via the Platform.

We may receive personal information from other sources. For example, if you connect your social media account(s) to your account, the social media site may share information with us about your use of their services, including information about your profile, contacts, and viewed or liked content. We encourage you to read the applicable privacy policies for your social media accounts. We shall have no responsibility for the data collection and use practices of those social media sites.

If you use the Platform to make a payment, we collect information about the transaction. This includes the date of the transaction, payment information, such as your credit or debit card number and other card information, and other account and authentication information, as well as billing and contact details.

HCIS and its service providers also collect certain non-personal information, data that does not identify you as an individual person. This information tells us about how people use the Platform so that we can analyze its effectiveness and provide you with a better web experience. We collect and use this information through a variety of technologies, including “cookies” and analysis applications, as discussed below.

• Server Information

Like every website, the HCIS servers automatically and temporarily store the following information in the server log files. This information is provided by your browser, unless you have deactivated the function.

• IP address of the enquiring computer
• File query by the client
• The http response code
• The Internet page from which you visited us (referrer URL)
• The time of the server query
• The browser type and version
• The operating system used on the enquiring computer

The server log files are not analyzed with respect to individuals. At no time can this data be attributed to specific individuals.

• Platform Visit Tracking Technologies

As is standard practice on many websites, the Platform may use “cookies” and other technologies to help HCIS understand which parts of the Platform are the most popular and the preferences of wwwhealthcareinnovationsoltuions.com users. HCIS may also use cookies and other technologies to study traffic patterns on the Platform, to improve its functionality and usability as well as to improve the effectiveness of our communications with users. HCIS may also use cookies to customize your experience and provide greater convenience to you during your interactions with the Platform.

A cookie is a unique alphanumeric identifier that websites use to help identify the number of unique visitors to a website, whether or not those visitors are repeat visitors, and the source of the visits. Cookies cannot be executed as code or used to deliver a virus and thus pose no threat to you. Servers and sites other than the one placing the cookie on your hard drive cannot read the cookie, and no personal information can be gathered by other servers from the cookie. If you prefer not to enable cookies or to disable them, you may do so through your web browser’s security settings. Please note that certain features of the Platform may not be available once cookies have been disabled.

Like most websites, the Platform gathers certain information automatically and stores it in log files. This information includes internet protocol (“IP”) addresses, browser type, operating system, internet service provider (“ISP”), referring/exit pages, date/time stamp of access, and clickstream data, and information about the content you view on the Platform. When you visit the Platform, the servers automatically log your IP address, the time and duration of your visit, and the time and duration spent on the pages of the Platform which you view. If you arrive at the Platform by clicking a paid advertisement or a link in a communication, then the server will capture information that tracks your visit from that link. If you arrive at the Platform by clicking on a non-paid source, such as a search engine result or link on another website, the server may capture information that tracks your visit from that source, to the extent available.

Some of our communications to you may contain a “click-through URL” which links to content on the Platform. When you click one of these URLs, it passes information through the HCIS web server before you arrive at the destination web page. HCIS tracks this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked, simply avoid clicking text or graphic links in emails you receive from www.healthcareinnovationsolutions.com.

Certain features of the Platform may use locally stored objects to collect and store information about your preferences and navigation to, from, and on our website. Locally stored objects are not managed by the same browser settings as are used for browser cookies.

HCIS additionally may use web beacons or pixel tags, which are tiny invisible graphic images, in the Platform. Web beacons and pixel tags may be used by HCIS to count users who have visited its webpages and for related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

• Different Devices

If you use different devices (e.g., your smart phone, laptop, and/or home computer) to access the Platform, we may be provided with and collect device-specific information, including your hardware model, operating system version, unique device identifiers, phone number, location, and mobile network information. We may associate your device identifiers or phone number with your account information.

• Third-Party Analytics

We may use third-party service providers (e.g., search engines) to collect and analyze information about use of the Platform. These service providers may utilize cookies and related technologies to collect personal information.

2. Use of Information

HCIS and its service providers (e.g., payment processors, and advertising or marketing companies) may use your personal information to provide our services and to contact you in response to inquiries you submit. HCIS and its service providers may retain and use your information for as long as needed for the following purposes:

• to present our Platform and related content to you;
• to provide you with information, products or services that you request from us;
• to provide you with notices about your account;
• to process your benefits claims;
• in combination with other information for Platform improvement and marketing and promotional purposes;
• to provide more consistent and personalized services across the Platform, including to personalize our advertising, marketing, and promotional efforts;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to notify you about changes to the Platform or any products or services we offer or provide though it;
• to allow you to participate in interactive features on the Platform;
• in any other way we may describe when you provide the information;
• for any other purpose with your consent.

3. When HCIS Discloses Your Information

We may disclose aggregated information about our users without restriction. This data cannot be attributed to any specific individual. HCIS may disclose aggregated user data in order to describe our services to current and prospective affiliates, and to other third parties for lawful purposes.

HCIS and its service providers may transfer information between them for business purposes. For example, our service providers may handle technical support, payment processing, marketing, advertising delivery and tracking, or information analysis. We furnish our service providers the information they need to perform these and other services, and we work with our service providers to respect and protect your information. We may also provide your information to our affiliates. The entities with which we share information may be located in the United States or other countries.

In the event that HCIS or some of our assets are sold or transferred or used as security, or to the extent we engage in business negotiations with our business partners, the information collected on the Platform may be transferred or shared with third parties as part of that transaction or negotiation. We may also provide information or provide access to information to any of our affiliated businesses or to our business partners.

On rare occasions, we may disclose specific information without your consent and without notice to you as required to comply with laws and regulations, or to comply with court orders, subpoenas, or lawful discovery requests. Information collected from you may also be used to investigate security breaches or otherwise cooperate with authorities. We may also share information with companies assisting in fraud protection or investigation.

We may disclose information about you without your consent and without notice to you as required to enforce or apply the Terms of Use, or other agreements, including for billing and collection purposes.

4. How Your Information is Protected

HCIS has implemented reasonable physical, technical, and organizational safeguards to help protect your personal information from unauthorized access, acquisition, or disclosure, alteration, or destruction. Although we strive to keep your personal information secure, no safeguards can be guaranteed to be completely secure, so you should exercise caution when transferring personal and other sensitive information over the Internet, including in email communications. Please advise us immediately at the address listed below of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

If your communication contains sensitive information and you would prefer not to submit this information online, please contact us at 855-662-7233, using company ID 3358432440.

5. Third-Party Sites

The Platform may contain links to other websites. Please note that when you click on one of these links, you will leave the Platform and will be subject to the policies and privacy practices of the other websites, which may differ significantly. You should review the policies of other websites you visit. HCIS is not responsible for the content, technology, security, or practices of linked sites operated by others, or for your use of linked sites.

6. Children’s Privacy

The Platform is not aimed at or intended for children. We do not knowingly collect information from children under the age of thirteen through the Platform. If we obtain actual knowledge that we have inadvertently collected personal information from a child under the age of thirteen, we will delete that information from our records. If you believe we might have any information from a child under the age of thirteen, please contact us at privacy@NJII.com Please note that emancipated minors and minors who may, under applicable law, obtain health care services or health insurance without the consent of a parent or guardian, are treated the same as adults for purposes of collection and access to health information.

7. Applicable Law

You should be aware that data related to the Platform is hosted, processed, and handled in the United States. We comply with all applicable laws of the United States.

We recognize that the Platform may be accessed from anywhere in the world, and that the laws of the jurisdictions in which some users are located may differ substantially from those of the United States and the State of New Jersey. Because we cannot practicably prevent users in different jurisdictions from accessing the Platform, you are responsible for knowing and complying with the laws of your jurisdiction. If such laws conflict with your use of the Platform or any of its content or functionality, the Platform is not intended for you, and we ask you not to use it or submit any information through it.

8. Do Not Track

“Do Not Track” is a privacy setting that you may set in your web browsers. If turned on, this setting requests that websites not track information about users. At this time, we do not respond to “Do Not Track” browser settings or signals.

9. Review, Modify, or Delete Your Information

You may request that any of your information be deleted or to be unsubscribed from communications by contacting privacy@njii.com. If you request that your information be deleted or if you request to be unsubscribed from communications, we may maintain information about your transactions or inquiries for future service and recordkeeping purposes. In some

circumstances, a change in or withdrawal of consent may severely limit our ability to provide you information, products, or services. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

10. Updates to this Privacy Policy

HCIS may update this Privacy Policy and the Platform to reflect material changes in how we collect, use, share, or store your information, to satisfy legal requirements, or for other business purposes. You should review this Privacy Policy when you visit the Platform to understand our current practices. The date at the top of the page shows when this Privacy Policy was last updated.

We encourage you to refer to this Privacy Policy on an ongoing basis so that you understand our current practices. You consent to any changes we make to this Privacy Policy if you continue to use the Platform after receiving a notice of the change or upon our posting of the new Privacy Policy on the Platform.

11. Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our legal counsel. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word “including” is used, it means “including without limitation.”

This Privacy Policy does not create or confer upon any individual any rights, or impose upon HCIS any rights or obligations outside of, or in addition to, any rights or obligations imposed by applicable country, state, and other privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and applicable privacy laws, this Privacy Policy shall be interpreted in that case to give effect to, and comply with, such privacy laws.

12. Contact Us

If you have questions or comments about this Privacy Policy or the Platform, please contact us using the information below.

New Jersey Innovation Institute, Inc.

Attn: Legal and Regulatory Affairs 211 Warren Street – Venture Link Newark, NJ 07103 Email: privacy@njii.com