Effective Date: 11/19/2020
Last Updated Date: 7/16/2026

Introduction

Azalea Health Innovations, Inc. (collectively referred to herein as “Azalea Health”, “we”, “our” or “us”), recognizes the importance of protecting personal data we may collect from visitors and any other individual or entity (“Users”, “you”, or “your”) who visit our web sites and who use our application. This Privacy Policy applies to data collection by Azalea Health and shall apply to your use of the website, azaleahealth.com and other Azalea Health-related sites, applications, software, communications, capabilities and services (“Services”) accessible on or by any top-level Azalea Health domain owned by us (each, a “Site” and collectively the “Sites”), but excluding services that state that they are offered under a different privacy policy.

Our Privacy Policy explains: (1) what information we collect; (2) why we collect it; (3) how we use that information; (4) how we may share it; (5) the choices we offer, including how to access and update information; (6) and the measures we take to keep your information safe.

Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Sites, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites.

Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Sites or Services.

If you have any questions or comments about this Privacy Policy, please submit a request to privacy@azaleahealth.com.

When This Privacy Policy Applies

Our Privacy Policy applies to all of the Services offered by Azalea Health and its affiliates, and Services offered on other sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Terms and Conditions

By accessing or using the Sites in any manner, you also agree to be bound by Azalea Health’s Terms and Conditions (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.

Information We Collect

We collect information, including personal data, to provide better services to all our Users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of Personal Data include: full name, email address, digital identity, such as a login name or handle, information about your device, and certain metadata.

“Sensitive Personal Data” refers to a smaller subset of Personal Data which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation.

When you use our Services, we collect Personal Data and Sensitive Personal Data in the following ways:

Information You Give to Us

Website and Online Platform

We may collect information you provide us if you access, voluntarily enter information into, or sign up for or request certain services from us on our Website. For example, if you are interested in learning more about Azalea Health and the services and products we offer, we may ask for information such as your name, alias, title, practice/organization name, size and address, email address, telephone number, type of user (patient, provider, partner), and city/state. If you have an account with us, we may also collect your username or other login information you use to log into or access your account.

The Sites offer interactive and social features that permit you to submit content and communicate with us. You may provide Personal Data to us when you post information in these interactive and social features. Please note that your postings in these areas of the Sites may be publicly accessible or accessible to other Users.

Mobile Application

Certain information is required when creating an account to use our Services on the mobile application, such as your name, email address, user name and password.

In addition, in order to improve your experience with the Services, you may choose to provide additional information such as your [gender, birth date, ethnicity, insurance provider, physical activity, and other health information]. You can choose not to provide certain information, but then you may not be able to register for the Azalea Health Services or take advantage of some features of the Services.

When your device syncs with Azalea Health’s application, certain data recorded on your device is transferred from your device to our servers.

Information We Obtain from Your Use of Our Services

We collect certain information automatically, such as your operating system version, browser type, and internet service provider. We also collect information about your interaction with the Services, such as creating or logging into your account, or opening or interacting with the Services on your mobile device. When you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; cookies that uniquely identify your browser, the referring web page and pages visited. We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.

Location Data

If you grant us access to your location, Azalea Health may collect information about your location when you use our Sites and Services. Your location can be determined by: IP address, and information about things near your device, such as Wi-Fi access points and cell towers. When you use our Services via a wireless device, we may solicit your permission to collect your location data. Some features within our application may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data to us.

Device ID

When using our Services, we or our service provider may collect your unique device ID. We may use such information for internal purposes and to provide you a better experience, such as to troubleshoot application problems you may experience. We may associate device ID with personal information you provide to us.

Financial Information

In order to provide our services, we may request payment information such credit or debit card information, name and address which allows us to process payments.

Azalea Health Partners

If you are a partner submitting a lead to us, we will collect information related to you as a partner as well as information related to the lead including details about the organization, address, contact information, needs, past purchase history, and purchaser preferences.

Health and Other Special Categories of Personal Data

Under a federal law called the Health Insurance Portability and Accountability Act (“HIPAA”), some demographic, health and/or health-related information that Azalea Health collects as part of providing the Services may be considered “protected health information” or “PHI.” HIPAA provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed. Azalea Health handles all PHI in strict accordance with applicable laws and regulations. In addition, Azalea Health Partners shall be contractually bound to protect PHI to the same degree as set forth in this Privacy Policy. All Protected Health Information that Azalea Health processes is used and disclosed by us as a Business Associate (as defined by HIPAA) according to the terms of a Business Associate Agreement between us and that healthcare provider. Azalea Health Partners, to the extent they are bound by HIPAA, are also required to describe their privacy practices.

Voice, Audio, and Video Data

When you use features within our Services that involve voice dictation, ambient AI documentation, or telehealth video, we may collect the following types of data:

• Voice audio recordings captured through microphone access, and transcriptions or notes generated from those recordings through AI-assisted documentation or dictation features (such as ambient scribing or voice-to-text tools available to clinicians within the EHR).
• Telehealth session video streams and associated session metadata (such as session duration and connection quality diagnostics) when you participate in or conduct a video visit through our platform.

Our applications may request access to your device microphone and/or camera to enable these features. Microphone and camera permissions are used only while the relevant feature is actively in use. You may revoke these permissions at any time through your device or browser settings; doing so will disable the associated voice dictation or telehealth video features.

Voice audio and telehealth video data processed through our Services may constitute Protected Health Information (PHI) when associated with an identifiable patient or encounter. Such data is handled in accordance with the HIPAA Rules and the applicable Business Associate Agreement between Azalea Health and the covered entity using our Services.

Cookies and Similar Technologies

We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third party advertising and analytics partners include Google, Lead Forensics and similar partners.

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

Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services.

Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics.

Mobile Device Identifiers and SDKs. A mobile SDK is the mobile app version of a web beacon. The SDK is a bit of computer code that app developers can include in their apps to enable ads to be shown, data to be collected and related services or analytics to be performed.

Information Collected Related to California Residents

During the last twelve (12) months, we have collected the following categories of personal information from consumers. We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from our customers or their agents.
• Indirectly from our customers or their agents.
• Directly and indirectly from activity on our website.
• From social media websites, such as Facebook, Twitter, and LinkedIn.
• From third parties that assist us in providing certain transactions and services (e.g. payment processing, hosting).

How We Use Information We Collect

We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

• To present, operate or improve the Site and Services, including analysis of Site activity;
• To inform you about Services and products available from Azalea Health;
• To authorize access to our Sites and Services;
• To provide, maintain, administer or expand the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
• To offer and administer programs;
• To personalize the Services to your health needs;
• To customize or tailor your experience of the Services, which may include sending customized messages;
• To communicate about, and administer your participation in, special programs, surveys, online campaigns and programs, and other offers or promotions, and to deliver pertinent emails;
• To secure our Services, including to authenticate Users;
• To use statistical information that we collect in any way permitted by law, including from third parties;
• To respond to and support Users regarding their use of the Sites and Services;
• To comply with all applicable legal requirements;
• To enforce our Terms and Conditions and other agreements;
• To perform data analysis and testing;
• To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our Users;
• To resolve disputes;
• To otherwise fulfill the purpose for which the information was provided.

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

Sale of Personal Information

In the preceding twelve (12) months, we have not sold any Personal Information.

Information We Share

We do not share Personal Data with companies, organizations and individuals outside of Azalea Health unless one of the following circumstances applies:

With your consent. We will share Personal Data with companies, organizations or individuals outside of Azalea Health when we have your consent to do so. When we share health Personal Data, we do so for the purpose of improving health management or for purpose of health research.

Enterprise Accounts. Your employer or your organization may offer you access to our Services. We will share Personal Data with your employer or organization. When we share health-related Personal Data, we do so for the purpose of improving health management or for purpose of health research and with your consent. Your employer or organization can review and manage your use of such enterprise Services.

Your Insurance Provider. We may share your Personal Data with the insurance provider you identify to us (and do so via our Azalea Health Partners) to determine eligibility, or otherwise obtain a benefit plan and other insurance-related information about you.

For external processing. We provide Personal Data to our affiliates or other trusted businesses or partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. These third parties include payment processors, such as financial institutions and their vendors and contractors that process transactions, marketing partners, and similar partners. It is our policy to only share Personal Data with contractors, service providers, technology partners, and other third parties who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. Under certain circumstances, you may avoid having us share your information with our business partners and vendors by not granting us permission to share your information. Not granting us permission to share your information with our business partners or vendors may limit your access to their services through the Sites.

Voice, Audio, and AI Transcription Processors. We share voice audio and AI-generated transcription or dictation output with third-party service providers that power our voice documentation features. These providers process audio and transcription data on our behalf solely to enable ambient AI scribing, clinical dictation, and voice-to-text workflows within the EHR. Current processors in this category include:

• Suki AI, Inc. — ambient AI scribing and voice documentation services.
• Nuance Communications, Inc. (a Microsoft company) — clinical AI dictation and transcription services.

These providers are contractually prohibited from using audio or transcription data for any purpose other than providing the services on our behalf. Where such data constitutes PHI, each provider operates under a Business Associate Agreement with Azalea Health and applicable covered entities in accordance with the HIPAA Rules.

Telehealth Video Processors. When you participate in or conduct a telehealth video visit through our platform, video session data is transmitted through a third-party video infrastructure provider that processes the session on our behalf solely to establish and deliver the video connection. The current provider in this category is:

• Vonage (Ericsson) — real-time video and communications infrastructure for telehealth sessions.

Vonage processes video session data solely to establish and deliver the video connection. Where telehealth session data constitutes PHI, Vonage operates under a Business Associate Agreement with Azalea Health and applicable covered entities in accordance with the HIPAA Rules. Telehealth session video content is not retained beyond what is necessary to deliver the session, unless a separate recording feature has been enabled and separately disclosed.

For Legal Reasons. We will share Personal Data with companies, organizations or individuals outside of Azalea Health if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to: meet any applicable law, regulation, legal process or enforceable governmental request; enforce applicable Terms of Use, including investigation of potential violations; detect, prevent, or otherwise address fraud, security or technical issues; or protect against harm to the rights, property or safety of Azalea Health, our Users or the public as required or permitted by law.

Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Data about our Users is often a transferred business asset. In the event that Azalea Health itself or substantially all of our assets are acquired, Personal Data about our Users may be one of the transferred assets.

Non-Personal and Aggregate Site Use Information. Azalea Health may compile and share your information in aggregated form (i.e., in a manner that would not personally identify you) or in de-identified form so that it cannot reasonably be used to identify an individual (“De-Identified Information”). We may disclose such De-Identified Information publicly and to third parties, for example, in public reports about exercise and activity, or to Azalea Health Partners under agreement with us.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:

• Identifiers;
• California Customer Records Personal Information categories;
• Protected classification characteristics under California or federal law;
• Commercial information;
• Internet or other network activity information;
• Geolocation data;
• Professional or employment-related information;
• Inferences drawn from other personal information

Your Failure to Provide Personal Data

Your provision of Personal Data is required in order to use certain parts of our services and our programs. If you fail to provide such Personal Data, you may not be able to access and use our Services and/or our programs, or parts of our Services and/or our programs.

Our Retention of Your Personal Data

We may retain your Personal Data for a period of time consistent with the original purpose for collection. For example, we keep your Personal Data for no longer than reasonably necessary for your use of our programs and Services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

We retain your Personal Data even after your business relationship with us ends if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

Privacy Rights Specific to Californians

Whenever you use our Services, we aim to provide you with choices about how we use your Personal Data. We also aim to provide you with access to your Personal Data. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes.

Under the California Consumer Privacy Act, California residents have specific rights regarding their personal information.

Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months.

Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us.

Right to Delete Your Data. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions.

Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Consumer Privacy Act.

Exercising Your Rights

If you are a California resident who chooses to exercise your rights, you can:

• Submit a request via email to privacy@azaleahealth.com
• Call 877-777-7686 to submit your request.

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.

Our Opt-in/Opt-out Policy

By providing an email address on the Azalea Health Sites or Services, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any Service related notices, or to provide you with information about our events, invitations, or related educational information.

We currently provide the following opt-out opportunities:

• At any time, you can follow a link provided in offers, newsletters or other email messages received from us to unsubscribe from the service.
• At any time, you can contact us through privacy@azaleahealth.com to unsubscribe from the service and opt-out of our right to share your Personal Data.

Third Party Links

The Sites may contain links to webpages operated by parties other than Azalea Health. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party’s website. Azalea Health strongly recommends that each User review the third party’s terms and policies.

International Transfer

We may, directly or indirectly through third-party entities around the world, process, store, and transfer the information you provide, including your Personal Information, as described in this Privacy Policy. Specifically, the information and Personal Information that we collect may be transferred to, and stored at, a location outside of your jurisdiction. By submitting your information and Personal Information using the Sites, you agree to this transfer, storing or processing. We will take all steps necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy.

How We Protect Personal Data

Azalea Health maintains administrative, technical and physical safeguards designed to protect the User’s Personal Data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk. For example, we restrict access to personal information to Azalea Health employees, contractors, business partners and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. We use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.

Children

The Site is not intended for use by children. We do not intentionally gather Personal Data from persons who are under the age of 16. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If we learn that we have inadvertently collected the personal information of a child under the minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.

Direct Marketing and “Do Not Track” Signals

Azalea Health does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.

California residents are entitled to contact us to request information about whether we have disclosed personal information to third parties for the third parties’ direct marketing purposes. Azalea Health does not disclose personal information to third parties for their direct marketing purposes. California users may request further information about our compliance with this law by e-mailing us at privacy@azaleahealth.com.

Azalea Health Partners

Azalea Health customers, including employers, and health plans (“Azalea Health Partners”), engage us to deliver Services to their employees, members and other users. Partner Information, Information about our Partner’s Contacts and Archival Information (each defined below) are governed by this Privacy Policy, the Azalea Health Terms and Conditions and any other services agreements between Azalea Health and the applicable Partner.

Azalea Health Partner Information. We collect information about individuals within our Azalea Health Partners organization. Partner Information may include information related to the Partner’s account, name, work e-mail address, work phone number, job title or similar kinds of information. We use Partner Information to support the Partner account, maintain our business relationship with the Partner, respond to Partner inquiries, or perform accounting functions.

Information about our Partners’ Contacts. We collect information about any contacts, such as practice groups, employees, insured parties, and others, that may be uploaded into the Azalea Health Platform. Information about our Partner’s Contacts may include name, e-mail address, phone number, job title, or similar kinds of information. We use Information about our Partner’s Contacts for the purposes of providing Services to such contacts.

Archival Information. We collect User information for archival purposes on behalf of, and as directed by, our Azalea Health Partners for the purpose of improving health management. This information may include User Personal Data, User communications with health coaches, User medical measurements, among other forms of data or electronic communications.

Automatically Collected Information. We collect information automatically about how our Azalea Health Partners use our services. We do this via data collection technologies such as cookies, web beacons, gifs or other tracking technologies. We collect this information in order to monitor, support and improve our services or to provide Azalea Health Partners with certain customized features.

We treat Partner Information, Information about our Partner’s Contacts, Archival Information and Automatically Collected Information as the confidential and proprietary information of our Azalea Health Partners, subject to the terms of the Azalea Health Terms and Conditions and any other service agreement between Azalea Health and the Partner.

Changes to This Privacy Policy

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

How to Contact Us

If you have any specific questions about this Privacy Policy, you can contact us via email or phone or by writing to us at the address below:

Email: privacy@azaleahealth.com
Phone: 877-777-7686
Azalea Health Innovations, Inc.
Attn: Privacy Policy Inquiry
6 Concourse Pkwy, Ste 2550
Atlanta, GA 30328