Welcome to Enter—a company that builds powerful tools to lower the cost of healthcare. This Privacy Notice explains how Enter, Inc. (“Enter”) collects, uses, discloses, and otherwise processes personal data in connection with Enter’s healthcare platform and the enter.health website. We may also choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions, or states. 

This Privacy Notice does not address our privacy practices relating to Enter job applicants, employees, and other employment-related individuals, nor data that is not subject to applicable data protection laws (such as deidentified or publicly available information). 

Our Role in Processing Personal Data

Data protection laws sometimes differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (the why and how) of processing personal data. A “processor,” which is sometimes referred to as a “service provider,” processes personal data on behalf of a controller subject to the controller’s instructions. 

This Privacy Notice describes our privacy practices where we are acting as the controller of personal data. However, this Privacy Notice does not cover or address how our customers may process personal data when they use our services, or how we may process personal data on their behalf in accordance with their instructions where we are acting as their processor. We refer to this type of personal information as “Customer Data.” We collect and process Customer Data on behalf of our business customers subject to restrictions set forth in our contracts with them, including, but not limited to, HIPAA business associate agreements. We recommend referring to the privacy notice or HIPAA notice of privacy practices of the business customer with which you have a relationship for information on how they engage service providers, like us, to collect and process Customer Data on their behalf.. 

Our Collection and Use of Personal Data

The categories of personal data we collect depend on how you interact with us and our services. For example, you may provide us your personal data directly when you contact our sales department or support department. 

We also collect personal data automatically when you interact with our websites and other services and may also collect personal data from other sources and third parties. 

Personal Data Provided by Individuals

We collect the following categories of personal data individuals provide us: 

• Contact Information, including first and last name, phone number, email address, mailing address, and communication preferences. We use this information primarily to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.
• Identification Information, including your driver’s license or passport information, age, and the last four digits of your social security number or employer identification number. We use this information primarily to verify your identity to establish your account. 
• Account Information, including first and last name, employment information and title, email address, phone number, account credentials or one-time passcodes, and the products or services you are interested in, purchased, or have otherwise used. We use this information primarily to administer your account, provide you with our products and services, communicate with you regarding your account and your use of our products and services, and for customer support purposes.

• Payment Information, including payment card information, billing address, and other financial information (such as, routing and account number). Please note that we use third-party payment processing providers[,including Stripe,] to process payments made to us. We do not retain any personally identifiable financial information, such as payment card number, you provide these third-party payment processing providers in connection with payments. Rather, all such information is provided directly by you to our third-party payment processing providers. The payment processing provider’s use of your personal data is governed by their privacy notice. [To view Stripe’s privacy policy, please click here.]
• Feedback and Support Information, including the contents of custom messages sent through the forms, chat platforms, email addresses, or other contact information we make available to customers, as well as recordings of calls with us, where permitted by law (including through the use of automated tools provided by us or our third-party providers). We use this information primarily to investigate and respond to your inquiries, to communicate with you, and to improve our products and services.

If you choose to contact us, we may need additional information to fulfill the request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the request we receive or personal data we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time. 

Personal Data Automatically Collected

We, and our third-party partners, automatically collect information you provide to us and information about how you access and use our products and services when you engage with us. We typically collect this information through the use of a variety of our own and our third-party partners’ automatic data collection technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. Information we collect automatically about you may be combined with other personal data we collect directly from you or receive from other sources. 

We, and our third-party partners, use automatic data collection technologies to automatically collect the following data when you use our services or otherwise engage with us: 

• Information About Your Device and Network, including the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). We employ third-party technologies designed to allow us to recognize when two or more devices are likely being used by the same individual and may leverage these technologies (where permitted) to link information collected from different devices.
• Information About the Way Individuals Use Our Services and Interact With Us, including the site from which you came, the site to which you are going when you leave our services, how frequently you access our services, whether you open emails or click the links contained in emails, whether you access our services from multiple devices, and other browsing behavior and actions you take on our services (such as the pages you visit, the content you view, the communications you have through our services, and the content, links and ads you interact with). We employ third-party technologies designed to allow us to collect detailed information about browsing behavior and actions that you take on our services, which may record your mouse movements, scrolling, clicks, and keystroke activity on our services and other browsing, search or purchasing behavior. These third-party technologies may also record information you enter when you interact with our products or services, or engage in chat features or other communication platforms we provide.
• Information About Your Location, including general geographic location that we or our third-party providers may derive from your IP address, as well as more precise geolocation when you grant us access through your device settings.

All of the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our products and services, and to improve the effectiveness of our products, services, offers, advertising, communications and customer service. We may also use this information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our products and services.

For information about the choices you may have in relation to our use of automatic data collection technologies, please refer to the Your Privacy Choices section below.

Personal Data from Other Sources and Third Parties

We may receive the same categories of personal data as described above from the following sources and other parties: 

• Our Affiliates: We are able to offer you the products and services we make available because of the hard work of our team members across all Enter entities. To provide our products and facilitate our services, Enter entities receive personal data from other Enter entities for purposes and uses that are consistent with this Privacy Notice. For example, we may receive your contact information to process and fulfill your order from a representative at your local Enter entity.
• Employers: If you interact with our services in connection with your employment, we may obtain personal data about you from your employer or another company for which you work. For example, we may obtain your contact information from your employer to allow us to communicate with you about your employer’s customer relationship with us.
• Other Customers: We may receive your personal data from our other customers. For example, a customer may provide us with your contact information as a part of a referral.
• Advertisers and Publishers: We engage in advertising both on our services and through third-party services. Advertisers and publishers may share personal data with us in connection with our advertising efforts. For example, we may obtain information about whether an advertisement on our services led to a successful engagement between you and a third-party advertiser.
• Service Providers: Our service providers that perform services on our behalf, such as analytics and certain marketing providers, collect personal data and often share some or all of this information with us. For example, we receive personal data you may submit in response to requests for feedback to our survey providers.
• Other Sources: We may also collect personal data about you from other sources, including publicly available sources, third-party data providers, brand partnerships, or through transactions such as mergers and acquisitions.
• Inferences: We may generate inferences or predictions about you and your interests and preferences based on the other personal data we collect and the interactions we have with you.

Additional Uses of Personal Data

In addition to the primary purposes for using personal data described above, we may also use personal data we collect to:

• Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to facilitate payment for our products and services, or to deliver the services requested;
• Manage our organization and its day-to-day operations; 
• Communicate with you, including via email, text message, chat, social media and/or telephone calls;
• Facilitate the relationship we have with you and, where applicable, the company you represent; 
• Request you provide us feedback about our product and service offerings; 
• Address inquiries or complaints made by or about an individual in connection with our products or services; 
• Create and maintain accounts for our users;
• Verify your identity and entitlement to our products and services;
• Register you for and provide you access to events, contests, sweepstakes, and surveys;
• Market our products and services to you, including through email, phone, text message, push notification, and social media;
• Administer, improve, and personalize our products and services, including by recognizing you and remembering your information when you return to our products and services;
• Develop, operate, improve, maintain, protect, and provide the features and functionality of our products and services; 
• Identify and analyze how you use our products and services;
• Infer additional information about you from your use of our products and services, such as your interests;
• Create aggregated or de-identified information that cannot reasonably be used to identify you, which information we may use for purposes outside the scope of this Privacy Notice; 
• Conduct research and analytics on our user base and our products and services, including to better understand the demographics of our users;  
• Improve and customize our products and services to address the needs and interests of our user base and other individuals we interact with;
• Test, enhance, update, and monitor the products and services, or diagnose or fix technology problems; 
• Help maintain and enhance the safety, security, and integrity of our property, products, services, technology, assets, and business;
• Defend, protect, or enforce our rights or applicable contracts and agreements (including our Terms of Service), as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
• Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Enter and others; 
• Facilitate business transactions and reorganizations impacting the structure of our business; 
• Comply with contractual and legal obligations and requirements; and
• Fulfill any other purpose for which you provide your personal data, or for which you have otherwise consented.

Our Disclosure of Personal Data

We disclose or otherwise make available personal data in the following ways: 

• To Our Affiliates: We are able to offer you the products and services we make available because of the hard work of our team members across Enter entities. To provide our products and facilitate our services, Enter entities disclose personal data to other Enter entities for purposes and uses that are consistent with this Privacy Notice. For example, the Enter entity responsible for our website may disclose your contact information to a Enter entity in your region to facilitate communications between you and a local Enter representative.
• To Your Employer: If you interact with our services in connection with your employment, we may disclose personal data to your employer or another company for which you work. For example, we may provide information to your employer about your usage of our services in connection with your work for them.
• To Marketing Providers: We coordinate and share personal data with our marketing providers in order to advertise and communicate with you about the products and services we make available.
• To Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our services, on other websites and services, and across other devices. These parties may collect information automatically from your browser or device when you visit our websites and other services through the use of cookies and related technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. 
• To Service Providers: We engage other third parties to perform certain services on our behalf in connection with the uses of personal data described in the sections above. Depending on the applicable services, these service providers may process personal data on our behalf or have access to personal data while performing services on our behalf.
• To Other Businesses as Needed to Provide Services: We may share personal data with third parties you engage with through our services or as needed to fulfill a request or transaction including, for example, payment processing services.
• In Connection with a Business Transaction or Reorganization: We may take part in or be involved with a business transaction or reorganization, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose, transfer, or assign personal data to a third-party during negotiation of, in connection with, or as an asset in such a business transaction or reorganization. Also, in the unlikely event of our bankruptcy, receivership, or insolvency, your personal data may be disclosed, transferred, or assigned to third parties in connection with the proceedings or disposition of our assets.  
• To Facilitate Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement: some text
  • in connection with the establishment, exercise, or defense of legal claims; 
  • to comply with laws or to respond to lawful requests and legal process; 
  • to protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
  • to detect, suppress, or prevent fraud; 
  • to reduce credit risk and collect debts owed to us; 
  • to protect the health and safety of us, our customers, or any person; or 
  • as otherwise required by applicable law.
• With Your Consent or Direction: We may disclose your personal data to certain other third parties or publicly with your consent or direction. For example, with your permission, we may post your testimonial on our websites. 

Your Privacy Choices

The following privacy choices are made available to all individuals with whom we interact. You may also have additional choices regarding your personal data depending on your location or residency. 

Communication Preferences

• Email Communication Preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in any of our email communications. Please note you cannot opt-out of service-related email communications (such as, account verification, transaction confirmation, or service update emails). 
• Phone Communication Preferences: You can stop receiving promotional phone communications from us by informing the caller you no longer wish to receive promotional phone calls from us, following the instructions provided on the call for opting out of promotional phone calls (where available), or replying STOP to any one of our promotional text messages. Please note we may need to continue to communicate with you via phone for certain service-related messages (such as, sending a verification code to your phone via call or text for purposes of verifying the authenticity of a log-in attempt). 
• Push Notification Preferences: You can stop receiving push notifications from us by changing your preferences in your device’s notification settings menu or in the applicable service-specific application. Please note we do not have any control over your device’s notifications settings and are not responsible if they do not function as intended. 
• Direct Mailing Preferences: You can stop receiving promotional direct mail communications from us by contacting us at privacy@enter.health. Please note this opt-out does not affect any mailings that are controlled by third parties that may feature or mention our services.

Automatic Data Collection Preferences

Where an Enter-specific preference manager or privacy setting is not available, you may be able to utilize third-party tools and features to further restrict our use of automatic data collection technologies. For example, (i) most browsers allow you to change browser settings to limit automatic data collection technologies on websites, (ii) most email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies, and (iii) many devices allow you to change your device settings to limit automatic data collection technologies for device applications. Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using our services, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.  

Targeted Advertising Preferences

We engage third parties to help us facilitate targeted advertising designed to show you personalized ads based on predictions of your preferences and interests developed using personal data we maintain and personal data our third-party partners obtain from your activity over time and across nonaffiliated websites and other services. The data we and our third-party partners use for purposes of facilitating targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research, are primarily collected through the use of a variety of automatic data collection technologies, including cookies, web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help link the personal data we and our third-party partners collect to the same person, or otherwise target advertising to an individual on a third-party website or platform. 

In addition to taking the steps set forth in the Automatic Data Collection Preferences section above, you may be able to further exercise control over the advertisements that you see by leveraging one or more targeted advertising opt-out programs. For example:

• Device-Specific Opt-Out Programs: Certain devices provide individuals the option to turn off targeted advertising for the entire device (such as Apple devices through their App Tracking Transparency framework or Android devices through their opt out of ads personalization feature). Please refer to your device manufacturer’s user guides for additional information about implementing any available device-specific targeted advertising opt-outs. 
• Digital Advertising Alliance: The Digital Advertising Alliance allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://optout.aboutads.info/?c=2&lang=EN for browser-based advertising and https://www.youradchoices.com/appchoices for app-based advertising to opt out of targeted advertising carried out by our third-party partners and other third parties that participate in the Digital Advertising Alliance’s self-regulatory program. 
• Network Advertising Initiative: The Network Advertising Initiative similarly allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://optout.networkadvertising.org/?c=1 to opt out of browser-based targeted advertising carried out by our third-party partners and other third parties that participate in the Network Advertising Initiative’s self-regulatory program. 
• Platform-Specific Opt-Out Programs: Certain third-party platforms provide individuals the option to turn off targeted advertising for the entire platform (such as certain social media platforms). Please refer to your platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs. 

Please note that when you opt out of receiving interest-based advertisements through one of these programs, this does not mean you will no longer see advertisements from us or on our services.  Instead, it means that the online ads you do see from relevant program participants should not be based on your interests.  We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, program participants may still use automatic data collection technologies to collect information about your use of our services, including for analytics and fraud prevention as well as any other purpose permitted under the applicable advertising industry program.

Partner-Specific Preferences

Certain of our third-party providers and partners offer additional ways that you may exercise control over your personal data, or automatically impose limitations on the way we can use personal data in connection with the services they provide: 

• Device-Specific / Platform-Specific Preferences: The device and/or platform you use to interact with us (such as your mobile device or social media provider), may provide you additional choices with regard to the data you choose to share with us. For example, many mobile devices allow you to change your device permissions to prevent our products and services from accessing certain types of information from your device (such as your contact lists or precise geolocation data), and many social media platforms allow you to change your platform permissions to prevent integrated products and services from accessing certain types of information connected with your profile. Please refer to your device or platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs. 

Children’s Personal Data

Our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 13. If an individual is under the age of 13, they should not use our services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 13 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 13, we will promptly delete that personal data.

Investor Personal Data

In addition to the personal data practices outlined above, we also collect personal data from shareholders and investors of our company, including share purchasing history, number of shares held, value of the shares, and the holder of record’s name and address. We use this information primarily to manage investor relations and investments in our company, including by providing you information about our company and related investments, processing investment transactions, preparing tax returns and other investor-related documents, and managing our cap table. We may also use this information for the purposes set forth in the Additional Uses of Personal Data section above and disclose this information to third parties in furtherance of these purposes as set forth in the Our Disclosure of Personal Data section above, as permitted by law.

Security of Personal Data

We have implemented reasonable physical, technical, and organizational safeguards that are designed to protect your personal data. However, despite these controls, we cannot completely ensure or warrant the security of your personal data. 

Third-Party Websites and Services

Our services may include links to third-party websites, plug-ins, applications and other services. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to any personal data practices of third parties. To learn about the personal data practices of third parties, please visit their respective privacy notices. 

Updates to This Privacy Notice

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on this website or our other platforms, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please contact us at privacy@enter.health.com.

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