Privacy

PRIVACY POLICY

Last Updated: May 5, 2024

This privacy policy (“Privacy Policy”) describes how WG Holdings Corp. and its owners and affiliates (collectively “Company,” “our,” “we,” or “us”) collect, use, disclose and protect information about you that you provide through the websites located at www.joinyara.com (collectively, the “Site”) or that we collect from your use of the Site.
This Privacy Policy applies only to information that is collected by us in connection with your use of the Site and any materials, information, products or services provided by us through the Site (collectively, the “Services”). It does not apply to any other offerings, products or services offered or provided by a third party. If you do not want us to collect, use or disclose information about you and your use of the Site or the Services as described in this Privacy Policy, then you should not use the Site or the Services. By using the Site or the Services, you are accepting the practices set out in this Privacy Policy and our Terms of Use.
If you are a resident of California, please see our section relating to California residents. If you are a resident of Colorado, Connecticut, Nevada, Virginia or Utah, please see our section relating to Other State residents.

About the Site

The Site gathers several types of information from and about users of the Site, including medication information, geographic location and user preferences. Among other things, this allows the Site to:

Help you to schedule an appointment with a telemedicine provider;
Provide non-clinical patient education regarding products and services relevant to you or of interest to you;
Collecting information about you to support your telemedicine providers and pharmacy in providing services to you;
Show you comparable prices for your medication using information received from third parties;
Send you a discount card if requested; and
Provide coupons for your use at the pharmacy of your choice.

Categories of Information We Collect

The information we collect from or about you (collectively, “Your Information”) allows us to provide our Services and helps us personalize and improve your experience on the Site. You may print or download a discount card to use our Services. Depending on how you use the Site, we may collect the following categories of information directly from you:

Information about you, including your name, date of birth, address and other demographic information.
Information about medications you are seeking to fill or are currently taking or have taken in the past, including medication names, dosage, reactions and your preferred pharmacy.
Information for billing purposes, including billing address, credit or debit card numbers, verification numbers and expiration dates. Please note that such information may be collected by third-party payment processors or vaulted.
Applicable health and lifestyle information, including information about your past and present health conditions, weight, prescribed medications, pregnancy conditions, supplements and blood pressure.
Information about your purchase transactions, including purchases using our discount card, medication name and pharmacy location.
Geographic location information from you or your device, including your geolocation data, zip code, region, city, street address, time zone, latitude and longitude information. Please note that we will not access precise geo-location information from your device, unless you grant the Site permission to do so.
User preferences.
Technical data and related information, including information about your device, system and application software, peripherals and other data related to your interactions with the Site.
Metadata and other information associated with or stored on your device.

We may also collect Your Information outside of the Site if you provide it to us through other means, including communications with our Customer Service team by phone or email. When you use the Site, we automatically collect some categories of information from you, such as information about your use of the Site, including features used, content viewed, dates and times of interactions, and technical data about your device, including operating system, model, device identifier and IP address. We may also automatically collect certain technical information relating to you that your web browser automatically sends whenever you visit a website on the Internet, or that is collected when you use a mobile application (see the section “Cookies and Similar Tools” below for more information). For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect information relating to your use of the Site. Google Analytics uses “cookies,” which are text files placed on your device, to help us analyze how you use our Site. You can find out more about how Google uses data by visiting its website for more information, currently located at https://policies.google.com/technologies/partner-sites.

How We Use the Information We Collect

We may use Your Information for the following purposes:

Operating the Site, including to provide you the Services and Site features.
To provide you the information and Services you request when you use the Site.
To customize your experience when you use the Site, such as providing you with interactive or personalized elements or providing you with content based on your interests, requests and location.
Improve the Site and Services, including by developing new products and services, performing quality control activities or conducting research or analytics.
Provide account management or customer service.
Engaging in system maintenance.
Deliver marketing communications, such as promotional materials, discount codes or advertisements, including materials and advertisements for Services offered by us and/or services and products offered by third parties that might be of interest to you, either directly to you or through third party apps or websites.
Communicate service-related or required notices about the Site to you, which may include communications by email or by text messages at the mobile device number you provide us.
Detect, prevent and respond to suspected fraud, intellectual property infringement, violations of our Terms of Use, violations of law or other misuse of the Site or Services.
Perform data analytics, including to compile, synthesize, generate and analyze anonymous usage and other aggregated statistics and information.
Monitor your use of information we provide to you.

When permitted by applicable law, we may also:

Combine Your Information, or information that we collect from third parties, with other information maintained by us, and use that combined information for any of the above purposes.
De-identify Your Information by removing information typically used to identify you and use that de-identified information for any purpose permitted by law.

How We Share Information We Collect

Your Information may be disclosed to the following third parties:

Telehealth service providers and their associated healthcare providers.
Pharmacies and other partners who help us provide the products or services available through the Site to you.
Business partners, who may deliver marketing communications, promotional markets, advertisements or other information, including about other Services offered by us or services or products offered by third parties that may be of interest to you. You will be given the option to opt out of marketing messages.
If required to do so by law or if we have a good faith belief that disclosure is necessary to (1) comply with the law or with legal process served on us, (2) protect and defend our rights or property, or (3) to protect someone’s safety.
Advisors, potential transactional partners or other third parties related to the consideration, negotiation or completion of a corporate change of control including a sale to, or merger with another entity. If all or substantially all Company assets or stock is acquired by a third party, we may transfer our user database, including Your Information contained in it, to the third party.
Service providers who work on our behalf or partner with us to provide or improve the Site or Services or carry out activities on our behalf. Our service providers are required to agree to protect Your Information consistent with this Privacy Policy. We and our service providers may share reports on user demographics and traffic patterns that do not identify you, as well as other information that does not identify you with third parties.

Your Protected Health Information

This Privacy Policy does not apply to information collected from you if you register and log-in to the password-protected and secure portions of our Site or Services, which are intended to be used by potential patients of independent licensed clinicians for the provision of their respective professional services (the “Platform”). The Platform allows eligible patients to access certain Services, including the access to medical professionals. All information collected and stored by us or disclosed by you within the Platform may be considered Protected Health Information (“PHI”) and/or medical information, and shall be governed by applicable state and federal laws that apply to such information, including the Health Insurance Portability and Accountability Act (“HIPAA”). Privacy practices with respect to PHI and/or medical information are set forth in the Notice of Privacy Practices, which is available to users of the Platform at https://joinyara.com/hippa-notice.

Information Security

We take reasonable steps to protect your personal information, which is any information that identifies you or could reasonably be linked to you. We also use encryption technology, called Secure Sockets Layer (SSL), to help protect personal information in certain areas of our Site during transport across the Internet. The presence of SSL encryption may be indicated by “https” in the browser URL or the image of a closed lock or solid key in the browser window.
Unfortunately, there is always some risk that an unauthorized or malicious third party may find a way around our security measures. We cannot guarantee that the Internet or any other device or technical system will be 100% secure or error-free. We are not responsible for the security of information you transmit over networks that we do not control, including the Internet and wireless networks. Please note that emails and other communications you send to us are not encrypted, and by communicating with us by email you accept the risk that any personal information contained in the email may be intercepted or accessed by unauthorized parties.

Your Choices

You may opt out of receiving marketing emails by using the unsubscribe information available in any marketing email, or by emailing us at [email protected]. To the extent that you use the Site, there are certain messages you may not opt out of receiving, such as non-promotional email messages about Services you have registered for or certain administrative, technical or safety notices about the Site or our Services.
The Site does not currently respond to “do not track” signals or other mechanisms that provide a method to opt out of the collection of information over time and across websites and online services you may use. If we do so in the future, we will describe how we do so in this Privacy Policy.

Information About Minors

The Site and the Services are intended for adults only and are not directed to, nor do we knowingly collect information from, individuals under the age of 18. If you become aware that your child or any individual under your care who is under the age of 18 has provided us with information without your consent, please contact us at [email protected].

Links to Other Websites

Our Site may include links to external third-party websites and online services that are not under our control. We are not responsible for the collection, use and disclosure of Your Information on those websites and other online services provided by those third parties. We encourage you to review the privacy policies and terms of use of each website you use and other online services you access. The inclusion of links to external third-party websites and online services does not imply endorsement of, or association with, such websites and online services by us, or any warranty of any kind, either express or implied.

Cookies and Similar Tools

We use cookies to collect, store and sometimes track information from your computer or mobile device automatically for statistical purposes to improve the Site. If you use our Site, we will use a cookie, web beacons and other similar technologies on our website to save your settings and to provide customizable and personalized services. A cookie is a unique numeric code that we transfer to your computer that lets us know your location, the information visited while on our website and the third-party websites you visited before accessing our website. Web beacons are small pieces of code placed on our website that allow us to obtain information about website usage. We retain the information we receive from the cookies we place on your computer. These cookies do not enable third parties to access any of your personal information. If you prefer not to receive cookies from the Site, then set your browser to refuse all cookies from any websites that you may visit. This will provide you with more control over the acceptance of cookies on your computer. However, it is possible that some portions of the Site will not function properly or may perform more slowly. By using our Site and not disabling cookies, you consent to their use. Please note that other tracking technologies may still function.

Retention

We will retain your personal information in accordance with our record retention policies and as permitted by applicable law unless you instruct us to remove it by contacting us at [email protected]. We will also retain your personal information as necessary to comply with legal obligations, resolve disputes and enforce our agreements. You can update the personal information you have provided to us at any time by writing to the program administrator:
Attn: Privacy Team/Regulatory Compliance,
WG Holdings Corp.
[email protected]
joinyara.com/support
Access from Outside the United States
If you access the Site from outside the United States, please be aware that personal information may be transferred to, stored in and processed in the United States. Certain governmental authorities may not consider the level of protection of personal information in the United States to be equivalent to that required by the in other jurisdictions.

Additional Terms Applicable to California Residents

Pursuant to California Civil Code Section 1798.83, if you are a California resident, you have the right to request information about how and to whom we disclose certain categories of your personal information for their direct marketing purposes, once per calendar year. You can make this request to us via email at: [email protected]‍.
Information We Collect: We have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples
A. Identifiers and Contact Information.	Your name, postal address, telephone number or email address.
B. Medical and financial Information.	Your credit card, debit card or health plan.
C. Protected classifications.	Age, gender, race, medical condition, disability.
D. Commercial information.	Records of products or services you have purchased.
E. Internet or other similar network activity.	Browsing history, search history, or your interaction with the Website.
F. Geolocation data.	Your physical location or movements

Use of Personal Information: We use this personal information for one or more of the following business purposes:

To provide our products and services, such as to process requests for telehealth consultations and for fulfilling orders.
To provide customer care, customer service, respond to inquiries and requests, verify your identity and maintain your account.
To analyze use of our Site and Services as well as customize and improve them.
For marketing, such as to provide you with email or text message alerts about products or services offered by us and/or third parties that may be of interest to you.
To maintain the security of our products, services and systems, such as detecting security breaches or fraudulent activity.
To keep our website and other services functioning properly, such as debugging and fixing errors.
To comply with our legal obligations.
To protect our rights, property and safety or the rights, property and safety of others.

We do not sell your personal information.

Sharing of Personal Information: We may share personal information that we collect with third parties for a business purpose, such your telehealth provider or pharmacies that fill your prescriptions, marketing partners, advertising networks, third parties that sponsor discount cards and service providers that help us operate or provide our services, including but not limited to payment processors, data storage companies and internet service providers. When we share personal information with our service providers, we require that they agree to protect the personal information and use and disclose it only to provide their services to us and for limited business purposes, such as to detect security breaches and comply with their legal obligations.

In the past twelve (12) months, we have shared the following categories of personal information for a business purpose with the following categories of third parties:

Category	Third Parties
A. Identifiers and Contact Information.	Service providers; Pharmacies and other health care providers; Product providers and distributors; Operating systems and platforms; Social networks; Marketing partners; Clients
B. Medical and Financial Information.	Information Service providers; Pharmacies and other health care providers; Product providers and distributors; Operating systems and platforms; Social networks; Marketing partners; Clients
C. Protected classifications.	Service providers; Pharmacies and other health care providers; Product providers and distributors; Operating systems and platforms; Social networks; Marketing partners; Clients
D. Commercial information.	Records of products or services you have purchased.
E. Internet or other similar network activity.	Service providers
F. Geolocation data.	Service providers

Your Rights and Choices: This section describes your privacy rights and explains how to exercise them.
Right to Know: You have the right to know, subject to certain exceptions, the following about the personal information we collected about you over the past 12 months:

The categories of the personal information;
The categories of sources of the personal information;
The business or commercial purpose for collecting that personal information;
The categories of personal information shared for a business purpose; and
The categories of third parties with whom the personal information is shared.

Right to Delete: You have the right to request that we delete the personal information that we collected from you, subject to certain exceptions.
Right to Opt-Out of the Sale of Personal Information: You have the right to opt-out of the sale of your personal information. We do not sell personal information.
The Right to Non-Discrimination: You have the right not to be discriminated against for exercising these rights.
Submitting Requests to Know and Delete Personal Information: You may submit a request to know or delete by submitting a request to us by either emailing us at [email protected] or visiting our website www.joinyara.com.
To process your request, we must be able to verify your identity so that we know whether the person making the request is the person about whom we collected the personal information, or is someone authorized to act as the authorized agent on that person’s behalf. We will verify your identity by asking that you provide certain information to us that will allow us to confirm you are who you say you are, such as contact information, account information and/or health information.
You may designate an authorized agent to make a request on your behalf. When you use an authorized agent to submit a request for access or deletion, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.
Only a parent or legal guardian may submit a request to know or delete the personal information of a child under the age of 13. We may ask a requestor on behalf of a child under 13 to sign a consent form under penalty of perjury or to speak by telephone to trained personnel to confirm that the requestor is the parent or legal guardian of the child.
You may only make a request to know or delete your personal information twice within a 12-month period.
Response Timing and Format: We will confirm receipt of your request to know or delete within 10 business days and will provide information on how we will process your request, including our verification process and when you can expect a response.
Additional Terms Applicable to Other State Residents (Colorado, Connecticut, Nevada, Virginia and Utah)
Colorado, Connecticut, Virginia and Utah each provide their state residents with rights to:

Confirm whether we process Your Information;
Access and delete certain parts of Your Information;
Data portability;
Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut and Virginia also provide their state residents with rights to:

Correct inaccuracies in Your Information, taking into account the information's nature and processing purpose;
Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Nevada provides its residents with a limited right to opt-out of certain sales of Your Information. Company does not sell Your Information to third parties as defined in Nevada law, and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law. If you have any questions regarding our data privacy practices or our compliance with Nevada data privacy law, please contact us at [email protected].
To exercise your state-specific privacy rights, please contact us at [email protected].

Changes and Updates

We may make changes to our Privacy Policy from time to time. When we do so, we will post the revised Privacy Policy on our Site and change the “last updated” date. Please check the “last updated” date at the top of this page to determine if the policy has been modified since you last reviewed it. Your continued use of the Site after that date means you agree to this Privacy Policy and any updates.
We may change this Privacy Policy at any time, as set forth herein, but we will not use personal information that we have already collected for a new purpose that is materially different from those stated in our Privacy Policy at the time that personal information was collected without first obtaining your explicit consent to use it for the new purpose.

Contact Us

If you have any questions about this Privacy Policy, please send them to [email protected]. You may also write to us in care of our administrator at:
Attn: Privacy Team/Regulatory Compliance
WG Holdings Corp.
[email protected]
joinyara.com/support