Monument Privacy Policy

Last modified: August 3, 2020

1. Introduction

Monument, Inc. (“Monument,” or “we,” “our,” or “us”) respects your privacy, and we are committed to protecting it through our compliance with this policy. This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the websites joinmonument.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to information we collect:

• on our Website;
• in email, text, and other electronic messages between you and our Website;
• when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by Monument or any third party;
• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Note, Monument is not a medical group. Any telemedicine consults obtained through our Website are provided by independent medical practitioners including, but not limited to, Life Now Health Group, P.A. (“Life Now Health”), an independent medical group with a network of United States based health care providers (each, a “Provider”). Life Now Health (or your own medical provider if you do not use a Life Now Health Provider) is responsible for providing you with a Notice of Privacy Practices describing its collection and use of your health information, not Monument. If you do not agree to be bound by those terms, you are not authorized to access or use our Website, and you must promptly exit our Website. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites. By accessing or using our Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates. Individuals located in California should read the important information available here.

2. Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or through the Website. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Website or on or through any of their features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at support@joinmonument.com or call us at (646)-434-2475.

3. Information We Collect About You and How We Collect It

Generally

We collect several types of information from and about users of our Website, specifically information:

• by which you may be personally identified, such your name, address, e-mail address, telephone numbers, credit or debit card number or other financial information, date of birth, credentialing information, Social Security number, Driver’s license numbers, and other government issued identification, your medical history, an health information and other information relating to treatment (“Personal Data”);
• that is about you but individually does not identify you, such as traffic data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website; or
• about your Internet connection, the equipment you use to access our Website and usage details.

We collect this information:

• directly from you when you provide it to us;
• automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; and
• From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website is:

• information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, using our Provider consultation services, or requesting further services. We may also ask you for information when you report a problem with our Website;
• records and copies of your correspondence (including email addresses), if you contact us; and
• details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

You also may provide information to be transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

• information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, browser type, and version information.
• details of your visits to our Website, such as traffic data, location, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website; and

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). We and our service providers may use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Website through your computer or mobile device. A cookie is a small file placed on the hard drive of your computer or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Website. Google Analytics uses cookies to help the Website analyze how users use the site. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps”, (located at Google partners privacy policies).

4. How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Data:

• to present our Website and its contents to you;
• to provide you with information, products, or services that you request from us;
• to process, fulfill, and administer transactions and orders for products and services ordered by you;
• to provide you with notices about your Monument account;
• to contact you in response to a request;
• to fulfill any other purpose for which you provide it;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
• to notify you about changes to our Website or any products or services we offer or provide though them;
• to advertise our services to you;
• to create anonymous data for analytics;
• in any other way we may describe when you provide the information; and
• for any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. If you wish to opt out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications or by visiting your Account Preferences page. For more information, see Choices About How We Use and Disclose Your Information.

5. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.We may disclose Personal Data that we collect or you provide as described in this privacy policy:

• to affiliates, contractors, service providers, and other third parties we use to support our business. The services provided by these organizations include providing IT and infrastructure support services, and marketing;
• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Monument about our Website users are among the assets transferred;
• to fulfill the purpose for which you provide it. For example, we may disclose your personal information to a Provider;
• for any other purpose disclosed by us when you provide the information;
• with your consent.

We may also disclose your Personal Data:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our Terms of Use (https://joinmonument.com/terms-of-use/) and other agreements, including for billing and collection purposes; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Monument, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

6. Choices About How We Use and Disclose Your Information

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. These third parties may aggregate the information they collect with information from their other customers for their own purposes.In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

• Promotional Offers from Monument. If you do not wish to have your email address used by Monument to promote our own products and services, you can opt out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or by emailing us at support@joinmonument.com. You may continue to receive service-related and other non-marketing emails.
• Tracking Technologies and Advertising. You can control what information cookies and similar technologies collect about you as described below. Please note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.
  • Browser/Device Settings: You can set your browser or device settings to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Website may then be inaccessible or not function properly. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
  • Advertising Industry Opt-Outs: You may opt out of receiving interest-based advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here.
  • Platform opt-outs. The following advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising:
    • Google
    • Facebook
  • Privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features or installing browser plugins, and configuring them to block third party cookies/trackers.
  • Do Not Track. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals, and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

7. Your Rights Regarding Your Information and Accessing and Correcting Your Information

You can review and change your account password by logging into our Website and visiting the Settings section of our Website. You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. If you wish to delete your account, you may do so by logging on to your account or by emailing us at support@joinmonument.com. We cannot delete your personal information except by also deleting your account with us. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

8. Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We use encryption technology for information sent and received by us.The safety and security of your information also depends on you. Where you have chosen a password for the use of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website, or in your operating system.

9. Changes to Our Privacy Policy

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website’s home page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Website’s home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically accessing or visiting our Website and reviewing this Privacy Policy to check for any changes.

10. Contact Information

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the “Contact Us” page on our Website.

11. Notice to California Residents

The information provided in this section applies only to California residents.We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal information, and of the rights and choices we offer California residents regarding our handling of personal information.This notice does not apply to any health or medical information we collect that is otherwise governed by California’s Confidentiality of Medical Information Act or the Health Insurance Portability and Accountability Act of 1996. This notice also does not apply to information related to our business contacts (including any partner physicians or therapists).Personal Information We Collect, Use and ShareIn addition to the information in our Privacy Policy, the following chart further describes our privacy practices with respect to the personal information of our California consumers.

Information we collect about you	CCPA-defined categories (Definitions are available here.)	Sources of personal information	Purposes for which we may collect and use the personal information	Categories of third parties to which we disclose the personal information
Account Registration Contact Information Correspondence	Identifiers Online Identifiers Commercial Information	You	To provide our Website and products/services To send you marketing communications To respond to your requests	None
Payment Information Purchases	Identifiers Financial Information	You Third Parties	To provide our Website and products/services	None
Automatically Collected Information	Online Identifiers Internet or Network Information Inferences	Automatic collection	To provide our Website and products/services To send you marketing communications To advertise our services to you To create anonymous data for analytics	Collected directly by advertising partners

Please note that we may also disclose all personal information to affiliates and service providers, or for purposes of corporate restructuring and compliance, as described in Disclosure of Your Information.California Residents’ Privacy RightsExcept as excluded from the scope of this notice above, the CCPA grants California residents the following rights.

• Information. You can request information about how we have collected, used and shared and used your personal information during the past 12 months. We have made this information available to California residents without having to request it by including it in this notice, in the above chart.
• Access. You can request a copy of the personal information that we maintain about you.
• Deletion. You can ask us to delete the personal information that we collected or maintain about you.
• Opt-out of sale of your personal information. You have a right to opt out from the “sale” of your personal information. We do not sell your personal information in the conventional sense, i.e., for money. However, like many companies, we use services that help deliver interest-based ads to you. Our use of these services may constitute a “sale” of your personal information for purposes of the CCPA because the advertising partners that provide the services may collect information from our users (e.g., the device data and online activity data described above) to help them serve ads more likely to interest you. Please click the “Do Not Sell My Info” link at the footer of the Website to manage cookies used on our Website.

You are entitled to exercise the rights described above free from discrimination.Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you. How to Submit a Request.

• To request access to or deletion of personal information:
• Email: support@joinmonument.com
• Identity verification. The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request. We may attempt to verify your identity by asking you to confirm the information that we have on file about you or your interactions with us. Where we ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.
• Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have written authorization confirming such authority.

Shine the LightIt is our policy not to disclose personal information (as defined in California’s Shine the Light Law, California Civil Code Section 1798.83) provided to us by our users (as defined in the Shine the Light Law) to third parties for their direct marketing purposes if the customer has exercised an option that prevents that information from being disclosed to third parties for those purposes. Such customers may exercise this option by submitting a CCPA opt-out request to support@joinmonument.com.