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Privacy Policy

Last Updated June 28, 2021

1. Introduction :

1.1 .This Privacy Policy (this “Privacy Policy”) informs you (or the entity on whose behalf you are using a Service) what Personal Information Healow, LLC (“Healow,” “we,” or “us”) may collect, how Healow collects such Personal Information, how Healow uses such Personal Information in connection with the Services we provide to you or our customers (i.e., Providers as defined below), and your choices related to your Personal Information.

1.1.1. “Services” means Healow’s products and services, such as our websites (“Sites”), electronic medical records systems, practice management systems, healthcare provider customer portals (“Provider Portals”), patient portals (“Patient Portals,” collectively with Provider Portals, “Portals”), software and mobile applications for the foregoing, etc.

1.2 In this Privacy Policy, we do not include Protected Health Information in the definition of Personal Information because, as discussed in Section 2, Protected Health Information has different treatment under HIPAA (as defined below), other applicable laws, and the Customer Documents (as defined below). Accordingly, because Protected Health Information is handled differently under the Customer Documents, if you are a patient of a Provider (as defined below), your Protected Health Information is subject to the Customer Documents and your Provider’s terms of service and privacy practices.

1.3 This Privacy Policy applies wherever it is posted, and it is part of and incorporated into applicable Terms of Use Agreements (“Terms of Use”) for the Sites, the Portals, and other Services, and into any applicable Terms and Conditions for our software and mobile applications (“Terms and Conditions”). Any terms capitalized herein but not defined shall have the meanings assigned to such terms in the applicable Terms of Use or Terms and Conditions. By visiting or using the Services or otherwise affirming the acceptance of an agreement into which this Privacy Policy is incorporated by reference, you acknowledge and agree to accept the practices described in this Privacy Policy regarding the collection, use, disclosure and transfer of your Personal Information. If you do not agree to the terms of this Privacy Policy, please do not use the Services. This Privacy Policy is not a contract and does not create any contractual rights or obligations. Your use of the Services is governed by the applicable Terms of Use or Terms and Conditions of the respective Services.

1.4 Please note that some privacy rights and obligations may differ in certain locations based on local law, in which case Healow will comply with the local legal requirements. Healow reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share Personal Information, we will post those changes in this Privacy Policy. If we make material changes to our Privacy Policy, we may also notify you by other means prior to the changes taking effect, such as by posting a notice on our Site or sending you a notification. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. Healow will note the effective date of the latest version of our Privacy Policy at the beginning of this Privacy Policy.

2. The Personal Information We Collect :

2.1. When you access and use the Services, we may collect the following types of information:

2.1.1. “Personal Information” is information that identifies an individual or relates to an identifiable individual or household. The types of Personal Information collected and the uses thereof depend on the purposes for which we collect the Personal Information (e.g., whether you are a visitor to our Sites, a user of our Portals, or a customer of our Services).

2.1.2. “Protected Health Information” or “PHI” is individually identifiable health information that is protected by the Health Insurance Portability and Accountability Act of 1996, as amended, and its implementing regulations (“HIPAA”).

2.1.3. “Usage Data” is information that we automatically collect about your use of the Services, and includes the sort that web browsers and servers typically make available, through web server logs, web beacons, cookies and other similar tracking technologies, about the devices you use to access our Services, as well as information on how you interact with our Services. Usage Data may include the IP address of a device or internet service used to connect your device to the Internet and may provide information about your Location; computer and connection information such as your browser type and version; operating system and platform; confirmation when you open email that we send you; purchase history; and the URLs which lead you to and around the Site including the date and time of access. Usage Data may overlap with Location Information. Usage Data is generally not Personal Information, but may be in some instances.

3. The Personal Information We Collect :

3.1 Healow uses information collected from users of the Services to personalize and improve your visit and experience, to provide the Services to you or our customers, and for other purposes set out below. When you use the Services, Healow may collect Personal Information in the following ways described below.

3.2 Information You Provide to Healow: Healow collects Personal Information when you use and interact with the Services, such as when you:

3.2.1. Communicate with Healow about our Services whether by letter, email, online chat window, or telephone;

3.2.2. Complete and submit forms to us on our Sites or Provider Portals (e.g., to register for an account on a Provider Portal, authenticate yourself to verify your authorized use of the Services, to register for our events, or to subscribe to our newsletters);

3.2.3. Visit our offices; or

3.2.4. Visit our Sites or interact with us on social media and provide us Personal Information.

3.3 Information that Healow Collects Automatically: When you use the Services, Healow may automatically collect Usage Data subject to the settings of your device that you use to access the Services. With your consent, we may also collect information from your device to facilitate your use of certain features of the Services. Healow may use this data to analyze trends and statistics to improve your online experience or our customer service.

3.4 Information from Other Sources: Healow may collect Personal Information from other sources such as the Internet and other publicly-available sources and databases, data aggregators, marketing companies, and other third parties, including sources from which you authorize us to obtain Personal Information about you on your behalf. If you authorize us to collect information from a third party, or if you authorize a third party to send us information, and you later decide that you no longer want us to obtain that information, you may need to contact the third party source directly and request that they stop transmitting information to us. For example, if You submit claims to the Centers for Medicare and Medicaid Services (“CMS”) You may decide to authorize us to obtain information directly from CMS, For more information about how those third parties collected and used your Personal Information, please review the privacy policy of the respective third party.

4. Protected Health Information; Healow as a Business Associate :

4.1 Certain Services we provide to our customers or make available to their patients, such as the Portals, as well as certain support operations, involve access to, and the processing of, PHI. This PHI is provided to us pursuant to a service agreement, business associate agreement, or other document with terms and conditions for the Portals (the “Customer Documents”) that we have entered with our customers (health care providers or their firms, “Providers”) that also govern our use of PHI of their patients provided by our Provider customers or their patient users.

4.1.1 This Privacy Policy supplements the Customer Documents. Healow only uses such PHI as a “business associate” of its Providers, who are “covered entities,” in accordance with any instructions or restrictions provided to Healow by the Provider and in full compliance with the applicable provisions of HIPAA.

4.1.2 If you are a patient of a Provider, our use and disclosure of your Protected Health Information is governed by HIPAA and other applicable law and the Customer Documents with your Provider – not by this Privacy Policy. Your Provider’s collection, use, disclosure, and transfer of such PHI are governed, in turn, by your Provider’s terms and conditions and privacy practices between you and your Provider. Please submit all requests and questions related to your PHI directly to your Provider. We are not responsible for how our Provider customers treat PHI we collect on their behalf, and we recommend you review their own privacy policies.

4.1.3 Our Sites are generally not intended to collect or retain any PHI. Thus, sections of this Privacy Policy that discuss collection on the Sites do not apply to PHI, and we do not request, obtain, use or disclose any PHI through our Sites such as www.healow.com, or www.healowinsights.com.

5. Use of Information Collected By Healow :

5.1 Healow uses the Personal Information collected to provide Services to our customers and their authorized users to improve user experience with the Services, and to communicate with you about requested information. Healow may use Personal Information to help target specific offers to customers and others and to develop and improve its Services.

Additionally, Healow may share your Personal Information as discussed below in Section 7, and use your Personal Information to:

  • Respond to user service requests, user questions and concerns, and administer user accounts. We may use your information to verify your identity, register you, administer your account, or provide you the information, products, and services that you request.
  • Provide service to our customers, which include Providers. If you are a patient of a Provider, we use your information when providing the Services to the Provider.
  • To communicate with users about our products, services, and related issues. We may use your information to try to identify if you may be interested in any of the Services or our business partners’ products and services. If we think something may interest you, we may send you information and promotional materials. You may unsubscribe from receiving marketing emails from us by using the unsubscribe link included in marketing emails.
  • To administer fees and provide users with invoices or resolve billing issues. We may use your information to verify your identity in order to process your payments.
  • Conduct research and analysis. We may use your information, subject to your consent, or otherwise in de-identified or aggregate form as part of research studies.
  • In the event of a business transaction. If we are exploring or go through a business transition or financial transaction, such as a merger, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, securities offering, or sale of all or a portion of our assets, we may use your information in connection with exploring or concluding such transaction.
  • To comply with law. We may disclose your information to comply with any applicable laws and/or regulations, such as to comply with valid legal processes such as a search warrant, subpoena, or order from a court or tribunal of competent jurisdiction.

6. Data Collection Technologies :

6.1. We and our service providers may use cookies, web beacons, log files, and other technologies (collectively, “Data Collection Technologies”) to help us provide, customize and improve the Services. The Data Collection Technologies include:

6.1.1. Web Beacons: A Web Beacon is a web page element (such as a clear gif, pixel tag or single-pixel gif) that may be embedded into our Sites or e-mail communications and which may employ cookie technology to enable Healow to record clickstream data.

6.1.2. Cookies: Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. Cookies enable Healow to collect clickstream data, including traffic on the Sites. You may set your browser to reject certain cookies or to notify you when you are sent a cookie. Rejecting cookies may limit functionality of the Sites. Third parties also provide software that allows you to visit the Sites without providing certain types of this information. Our Sites may use the following types of cookies:

6.1.2.1. Essential/Strictly Necessary Cookies: These cookies are necessary for the Sites to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Sites will not then work.

6.1.2.2. Analytics/Performance Cookies: These cookies allow us to count visits and traffic sources, so we can measure and improve the performance of our Sites. They help us know which pages are the most and least popular and see how visitors move around the Sites. Information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our Sites.

6.1.3. Analytics Services: We may use third-party web analytics services (such as those of Google Analytics) and other technologies on our Services to: collect and analyze usage information through cookies and similar tools; engage in activities such as auditing, research, or reporting; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

6.2. Notice Concerning Do Not Track: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above. We do not currently use technology that recognizes “do not track” signals from your web browser. To learn more about Do Not Track, you can do so here.

7. Sharing of Information :

7.1. Healow will not rent, sell or otherwise disclose your Personal Information to unrelated third parties without authorization, except as stated in this Privacy Policy. Healow may share your information in the following ways:

7.1.1. At Your Request: Healow may disclose Personal Information to third parties at your request, direction, or authorization. For example, if you direct Healow to disclose your Personal Information to a third party entity, whether and Healow business partner or other third party to use the third party’s service, we will share your information with the third party.

7.1.2. Internal Sharing: Healow may disclose Personal Information to its affiliates (including parents, entities under common ownership, and subsidiaries, such as eClinicalWorks, LLC), and other related companies without authorization.

7.1.3. With Our Service Providers: Healow may disclose Personal Information to service providers for the purposes of operating our business, delivering, improving, and customizing our products or services, sending marketing and communications related to our business, payment processing, and for other legitimate purposes permitted by applicable law.

7.1.4. With Our Customers: Healow may disclose Personal Information, including Sensitive Personal Information, to its customers consistent with the Customer Documents. Sensitive Personal Information” refers to Personal Information regarding more sensitive areas, such as government ID and certain other financial information, gender, marriage status, race/ethnicity, or veteran or disability status.

7.1.5. Compliance with Law: To the extent permitted by law, Healow will disclose Personal Information to government authorities or third parties pursuant to a legal request, subpoena, or other legal process. Healow may also use or disclose your Personal Information as permitted by law to perform charge verifications, apply or enforce the Service’s Terms of Use or Terms and Conditions, or protect Healow’s rights, interests, or property as well as those of Healow affiliates, customers, or Service users

7.1.6 Business Transaction: If Healow sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, Healow may transfer your Personal Information to a third party as part of that transaction.

8. Biometric Data :

8.1. If you use our Portals, Healow may collect biometric data such as a fingerprint that may identify you, to use for authentication and verification of your identity. This information may be biometric data under certain laws governing the collection, use, storage, and disclosure of biometric data. By providing such information, you acknowledge that you have been advised of, and understand that, Healow, and their agents and contractors may collect, use, store, and disclose biometric data for the purposes described in this Privacy Policy, or as otherwise described in the Services.

9. Security of Personal Information :

Healow has reasonable and appropriate safeguards in place to help protect the Personal Information Healow collects from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Although Healow attempts to protect the Personal Information in our possession, no security system is perfect, and Healow cannot promise that your Personal Information will remain absolutely secure in all circumstances.

10. Retention of Personal Information :

Healow will retain your Personal Information as needed to fulfill the purposes for which it was collected. Healow will retain and use your Personal Information as necessary to comply with Healow’s business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.

11. Aggregated De-Identified Information :

Healow may provide aggregated information related to your Personal Information to some of Healow’s business partners. This information is used in a collective manner and does not identify you individually in any way. If you are a patient of a Provider, we may only create, use or disclose aggregated or certain de-identified PHI as authorized by your Provider in the Customer Documents.

12. Links to Third Party Websites :

Our Sites may contain certain links to third party websites. Healow is not responsible or liable for the privacy practices or content found on these websites. You should check the privacy notice and policies of each website you visit. Links to third party websites are provided solely for your convenience and any use or submission of data to such websites shall be at your sole risk.

13. Children’s Privacy :

Our Services are not directed toward children under the age of 13. We do not promote our Services to minors, and we do not knowingly collect any Personal Information through our Services from any person under 13.

14. United States Only :

The Services are intended for use only in the United States of America. If you use the Services or contact us from outside of the United States of America, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States of America; and (ii) by using the Services or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States of America in accordance with this Privacy Policy.

15. Changes to the Privacy Policy :

Healow may change this Privacy Policy at any time. Unless we say otherwise, changes will be effective upon the last updated date at the top of this Privacy Policy. Please check this Privacy Policy regularly to ensure that you are aware of any changes. We may try to notify you of material changes to this Privacy Policy, which if we do so may be by means such as by posting a notice directly on the Services, by sending an email notification (if you have provided your email address to us), or by other reasonable methods. In any event, if you use the Services after changes to this Privacy Policy, you have accepted the changes. If you do not agree with the changes, please stop using the Services.

16. Contact Information :

If you have any questions or concerns related to this Privacy Policy, please contact the Healow Chief Privacy Officer at:

Healow, LLC
2 Technology Drive
Westborough, MA 01581
Attn: Chief Privacy Officer
privacy@healow.com

This email address is monitored only for privacy-related inquiries. If you are a patient and have a question related to accessing the Patient Portal, please contact your healthcare provider.

Pursuant to applicable law, Healow may be required to send you notice of known or suspected security breaches that impact Your Personal Information. In the event that Healow must provide a notice of a security breach to You, Healow will send security breach notices to the contact information contained in your account information unless Healow is required by law to notify you using another method. Otherwise, if Healow needs, or is required, to contact you concerning any event that involves information about you we may do so by email, telephone, or mail.

17. Privacy Notice for California Residents :

Effective Date: January 1, 2020

Last Updated: June 28, 2021

This Privacy Notice for California Residents (this “Notice”) supplements the information contained in this Privacy Policy and applies to all visitors to our Site, users and others who reside in the State of California (“You” or as the context requires “Your”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.

17.1. CCPA Personal Information Collected By the Services :

Through a user’s interactions with the Services, Healow collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“CCPA Personal Information”). CCPA Personal Information includes any information you have provided in connection with your use of the Services.

CCPA Personal Information does not include:

  • Publicly available information from government records;
  • De-identified or aggregated consumer information; or
  • Information excluded from the CCPA’s scope, like:
    • PHI, health or medical information covered by HIPAA and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data;
    • Information we collect from our employees or business contacts pursuant to CCPA’s temporary exceptions for these categories of individuals.

In particular, through our Services, we have collected the following categories of CCPA Personal Information from consumers within the last twelve (12) months:

Category of CCPA Personal Information Examples
Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.
Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric information. If you have biometric authentication integration as part of the Services, then we may collect information concerning Your fingerprints, faceprints, and voiceprints, and iris or retina scans.
Internet or other similar network activity. Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Sensory data. Audio, electronic, visual, or similar information. Audio recordings of calls are typically in this category.
Professional or employment-related information. Current or past job history or performance evaluations.
Inferences drawn from other Personal Information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

In addition, for users of our Conference Events app, we have collected CCPA Personal Information that are protected classification characteristics under California or federal law (such as information on physical disability) and geolocation data (your location in the conference).

17.2. How We Collect Your CCPA Personal Information :

We collect each of the categories of CCPA Personal Information listed above in one or more of the following ways:

  • Directly from You;
  • Indirectly from You (e.g., information collected in course of delivering services);
  • Third party applications that are integrated with our “eManager” software;
  • Other third parties that interact with us in connection with the services we perform;
  • Other medical providers, third party payors, and government authorities;
  • Data brokers or resellers from which we purchase data to supplement the data we collect;
  • From employees; and
  • From other vendors/suppliers.

17.3. Our Use of Your CCPA Personal Information :

Healow uses the CCPA Personal Information collected in an effort to improve your experience with the Services, to provide the Services to you and to communicate with you about information that you request. Healow may also use CCPA Personal Information to help target specific offers to you and to help Healow develop and improve its Services. Additionally, Healow may use Your CCPA Personal Information for one or more of the following business purposes:

  • To respond to user service requests
  • To administer user accounts;
  • To provide service to our customers, which include Providers;
  • To respond to Your questions and concerns;
  • To market and communicate with users about our products, services, and related issues;
  • To administer fees and provide users with invoices or resolve billing issues;
  • To conduct research and analysis;
  • To carry out our obligations and enforce Company’s rights arising from any contracts entered into between You and us;
  • As necessary or appropriate to protect the rights, property or safety of us, our customers or others;
  • To provide, support, personalize, and develop our products and services;
  • To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business;
  • As described to You when collecting Your CCPA Personal Information or as otherwise set forth in the CCPA;
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; and
  • Undertaking activities to verify or maintain the quality or safety of a service of the business and to improve, upgrade, or enhance such service.

17.4. Sharing of CCPA Personal Information with Third Parties :

To facilitate the provision of Services to you and to comply with applicable law, we may disclose Your CCPA Personal Information to third parties such as our affiliates; our service providers; other medical providers, third party payors, and patients; government authorities; third parties for providing the services for which you have contracted; third parties to whom you or your agents authorize us to disclose your CCPA Personal Information or to which we must provide your CCPA Personal Information to provide services to you, such as health care clearinghouses; and third parties to comply with applicable law, such as law enforcement.

In the preceding 12 months, we have not sold your CCPA Personal Information to third parties.

We do not knowingly disclose or sell Personal Information of minors under 16 years of age to non-service provider third parties.

17.5. CCPA Data Subject Rights :

As a California resident, You have the right to certain “information requests,” that include (i) requests to obtain a copy of your CCPA information, or for additional disclosures about the CCPA Personal Information we collect, use, and disclose over the past 12 months (collectively “requests to know”); and (ii) a request for information regarding and deletion of Your CCPA Personal Information (“request to delete”). As a California resident, you also have the right to opt-out of the sale of CCPA Personal Information at any time (“right to opt-out”), which as noted above Healow does not do. Consumers who opt-in to personal information sales may opt-out of future sales at any time. Healow will not discriminate against you for exercising any of these rights, for example, by charging a different price or denying goods or services. However, Healow may charge a different price or rate or provide a different level or quality of goods or services when that difference is reasonably related to the value provided to us by the data.

You may also limit the use and disclosure of Your CCPA Personal Information by either unsubscribing from marketing communications or contacting Healow at the address listed above under Section 16 titled “Contact Information.” Please note that some information, excluding claims data information provided by CMS as part of the “Blue Button” program, may remain in ECW’s records even after You request deletion of Your CCPA Personal Information, to the extent required by applicable laws. Additionally, there may be limits to the amount of information ECW can practically provide. For example, we may limit access to CCPA Personal Information where the burden or expense of providing access would be disproportionate to the risks to an individual’s privacy or where doing so would violate others’ rights.

17.6. How to Exercise CCPA Data Subject Rights :

If you wish to exercise any of these rights please complete this web form https://healow.com/privacyrequests/. You may also call us toll-free at +1 (866) 888-6929.

We will review your requests and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain Your CCPA Personal Information only in de-identified form, we will not attempt to re-identify your data in response to a Data Subject Rights request.

If you make an information request/request to know or request to delete CCPA Personal Information about You, You will be required to supply a valid means of identification as a security precaution. We will verify your identity with a reasonably high degree of certainty using the following procedure where feasible: we will match identifying information you provide when making the request to the CCPA Personal Information maintained by Healow, or use a third-party identity verification service. If it is necessary to collect additional information, Healow will use the information only for verification purposes and will delete it as soon as practicable after complying the request. For requests related to particularly sensitive information, we may require additional proof of identification.

If you make a Data Subject Rights request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf.

We will process your request within the time provided by applicable law.

17.7. Other California Privacy Rights :

In addition to the rights already described, California’s Shine the Light law permits California residents to request certain details about how their information is shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business must either provide this information or permit California customers to opt in to, or opt out of, this type of sharing.

We may from time to time elect to share certain information about you collected by us through the Services with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. If you are a California resident, you may opt out of such future sharing of your personal information (as defined by the California Shine the Light law) by contacting our Privacy Officer at privacy@healow.com with the phrase “Do Not Share” in the subject line.

17.8. CCPA Roles :

If you are a California resident and we, as a service provider, have processed personal information about you on behalf of our customers and you wish to exercise your CCPA rights, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal information. We will refer your request to that customer and will support them to the extent required by California privacy law in responding to your request

17.9. Individuals with Disabilities :

If you have a disability and would like to access this Notice in a different format, you may contact us at privacy@healow.com with the phrase “Alternative Format California Privacy Notice” in the subject line.

17.10. CCPA Governing Law :

This Notice will be subject exclusively to the laws of the State of California within the United States of America. We make no representation that this Notice and such practices comply with the laws of any other country. Visitors who use this Site and reside outside the United States do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. If you reside outside of the United States, by using our Site, You consent to the transfer and use of your information outside your country.