Primary Care Membership

SHIFT Online Privacy & Security Policy

At Shift Sciences, LLC (“SHIFT”), we appreciate the trust you place in us when you choose to use Shiftlife.com (the “Website”) and we are committed to preserving our clients’ privacy. We have provided this Privacy Policy (“Policy”) to you to describe information collection and use practices when you use the Website and the choices you can make about the way your personal information is collected and used. In this Policy, “you” means anyone who uses our Website, applications, or other services and “us” or “we” means SHIFT. If you have questions or complaints regarding our Policy please contact us at info@shiftlife.com or as provided in the “Contact Us” section in this Policy. For California residents, there is an “Information Specific to California Residents” section in this Policy.

Please note that this Policy solely governs information regarding your privacy and security when you use our Website. Your access and use of the Website is in all respects subject to our standard terms of use, as amended from to time to time. This Policy does not cover any medical information that you may provide to an affiliate of SHIFT as part of the medical services such Shift affiliate renders to you. You agree not to use the Website to transmit any personal health information to us.

Effective Date

This Policy is effective March 10, 2020. We may revise this Policy from time to time. By accessing our Website, you agree to the terms of this Policy, as amended from time to time. Any changes in our Policy will appear on this page so that you are aware of the data we collect and how we use it. We will update this “Effective Date” section to indicate when those changes will become effective.

How and What Information We Collect

SHIFT wants you to understand how your information is collected and used. When you access Shiftlife.com, interact with the Website, correspond directly with us through our Website, postal mail, e-mail, customer service or dispute resolution mechanisms, call us, post a comment on our Website, subscribe to a blog, newsletter or promotional alerts or otherwise interact with us we collect a variety of information about you and the services you use. Examples of some information collected include:

• Identifiers and Contact Information: your name, address, phone number, or email address. The Website does not collect identifying information about you unless you voluntarily submit that information to us through our Contact Us page or our “Make a Shift” option, if provided or obtained when you requested more information or contacted us, or by other means.
• Preference information: your contact and marketing preferences.
• Communications and interactions: email messages and phone calls (including recordings) that we exchange or engage in with you.
• Demographic information: your age or birthdate, gender, ZIP code, and other information about you to the extent you provide the same to us.
• Location or geolocation information, including the location of your device that you use to access our Website, if your device settings allow us to collect location information;
• Device, server and browsing information and other Internet activity information, including information about your phone, tablet, computer, or device, and online browsing activity. Such information may include IP addresses, unique device identifiers, cookie identifiers, device and browser settings and information, and Internet service provider information.
• Cookies and Similar Technology. “Cookies” are small data files that are sent from a website’s server and are stored on your device’s hard drive either for only the duration of your visit or for a fixed period of time. Cookies may store user preferences and other types of information. We use cookies to provide features and services, such as: remembering your preferences, presenting information targeted to your interests; measuring the effectiveness of our Website, services, content and advertising; and providing other services and features that are available only through the use of cookies.
  
  
  • Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. Please note, however, that certain features of the Website might not function if you delete or disable cookies. THE WEBSITE’S COOKIES DO NOT AND CANNOT INFILTRATE A USER’S HARD DRIVE TO COLLECT ANY INFORMATION STORED ON THE HARD DRIVE. The options and/or settings section of most internet browsers will tell you how to manage cookies and other technologies that may be transferred to your device, including how to disable these technologies.
  • A “Web Beacon” is an electronic image placed in the code of a webpage, application, or email that send information about your computer, tablet, phone, or other device used to visit the website or open an email sent to you. We may use web beacons to monitor the traffic patterns of users from one page to another and to improve website performance, and in our emails to understand when our email communications are opened or discarded.
  • We may use or engage a third party that uses local stored objects, sometimes referred to as “Flash Cookies,” and other technologies to collect and store information about the use of our services. A Flash cookie is a small data file placed on your computer or device using Adobe Flash technology. Flash cookies are different from the cookies discussed above because cookie management tools provided by your browser will not remove Flash cookies. To limit the websites that can store information in Flash cookies on your device, you must visit the Adobe website.

How We Use Your Information

We use the information that we collect to conduct our business and to provide you with the best possible products, services, and experiences. Examples of how we use information include:

To provide you with products and services, to assist in your requests, and to provide you with products and services that we think you will like.

• To respond to you, such as when you request services, call us, make a request or inquiry or share a comment or concern.
• For personalization of your experiences with us, including to remember your interests and preferences, customize the products and services we share with you, track and categorize your activity and interests on our Website, including by identifying the different devices you use.
• For marketing and advertising, such as to send you marketing and advertising communications, and to customize the marketing and advertising that we show you.
• For analytics, such as to understand how you use our Website, determine the methods and devices used to access our Website, and improve our Website.
• For our business purposes, such as to operate and improve upon our business and lawful business activities, to maintain our programs, accounts, and records, for research, to determine your satisfaction with our products and services, to detect and prevent fraud or misuse of our services, and for any other business purpose that is permitted by law.
• For legal and safety purposes, such as to defend or protect us, our clients, you, or third parties, from harm or in legal proceedings, protect our rights, protect our security and the security of our clients, employees, and property, respond to court orders, lawsuits, subpoenas and government requests, and address legal and regulatory compliance.

How We Share Your Information

We do not directly sell your personal information to any third parties. We do share personal information with third parties other than as described below. Examples of how we share personal information are described below.

• Internally. We may share your information internally and/or with our affiliated entities.
• When We Work with Third Parties.
  • We may share your information with affiliated and unaffiliated companies that perform tasks on our behalf related to our business. Such tasks include analyzing website usage data, customer service, electronic and postal mail service, and social and other media services.
  • We may work with other companies who place cookies, tags, and web beacons on our Website. These companies help operate our Website and provide you with additional products and services.
  • We may also use third-party advertising networks to serve advertisements on our behalf. The cookies received with the banner advertisements served by these networks may be used to collect and build behavioral profiles by these companies to deliver targeted advertisements on our Website and unaffiliated websites.
  • We may work with other companies who operate their own websites, to allow them to offer our clients the ability to connect to their services.
• Social Media: Our online services may use social media plugins to enable you to easily interact with certain social media websites (such as Facebook, Twitter, Instagram) and share information with others. When you visit our Website, the operators of the available social media plugins can place a cookie on your device enabling such operators to recognize individuals who have previously visited our services. If you are logged in to these social media websites while visiting our services, the social media plugins allow the relevant social media websites to receive information that you have visited our Website or other information. The social media plugins also allow the applicable social media websites to share information about your activities on our Website services with other users of the social media website. We do not control any of the content from the social media plugins. We may also interact with you on social media platforms. If you contact us on one of our social media platforms, request services, or otherwise communicate directly with us on social media, we may contact you to interact with you. For more information about social media advertising and social media plugins from other social media websites, please refer to those websites’ privacy and data sharing statements.
• When Sharing is Required by Law or Helps Us Protect Our Interests. We will disclose your information as necessary or appropriate under applicable law, to comply with legal process, to respond to such requests from public and government authorities, to enforce our Website terms and conditions, including investigations of potential violations, to detect, prevent or otherwise address fraud, security or technical issues, to protect our rights, privacy, safety or property, and to allow us to pursue available remedies to limit the damages that we may sustain. In matters involving claims of personal or public safety or in litigation where the data is pertinent, we may use or disclose personal information without your consent or court process.
• When We Work On Business Transactions. As we continue to develop our business, we might sell or buy assets, or engage in mergers, acquisitions or sale of company assets. Personal information may be disclosed in connection with the evaluation of and entry into such transactions, or in the course of providing transition of services to another entity as permitted by law. In such transactions, client information generally is one of the transferred business assets. Additionally, in the event that substantially all of our assets are acquired, client information will likely be one of the transferred assets as is permissible under law.
• Non-identifiable or Aggregate information with Third Parties. We may share non-identifiable or aggregate information with third parties for lawful purposes.
• With Your Consent. At your direction or request, or when you otherwise consent, we may share your information.

All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

Your Choices

By interacting with our Website, you consent to the practices described in this Policy. However, we want you to know that you do have certain choices with regard to how your information is collected and used.

• Social Media Platforms and Networks. We encourage you to review your privacy options and settings with the social media platforms and networks you use to understand what choices you have about sharing information from those platforms and networks with us.
• Mobile Location Choices. You may choose not to provide your location to us in connection with your use of our mobile application by declining any prompt requesting location information, and by customizing your mobile device settings to prevent sharing of location information.
• Do Not Track Signals. Our Website respects enhanced user privacy controls. We support the development and implementation of a standard “do not track” browser feature, which signals to websites that you visit that you do not want to have your online activity tracked. Please note that at this time the Website does not interpret or respond to “do not track” signals. However, you may set your Web browser to not accept new cookies or web beacons, be notified when you receive a new cookie, or disable cookies altogether. Please note that by disabling these features, your experience on the Website will not be as smooth and you will not be able to take full advantage of our Website’s features. Please see the Help section of your browser for instructions on managing security preferences.]
• Updating Your Personal Information. You can review and update any of the information you have given us by emailing us or calling 312-566-4209.
• Links to Third-Party Websites. Our Website may contain links to, or otherwise make available, social media websites and other third-party services, websites and mobile applications that are operated and controlled by third parties. We do not take responsibility for the content or the privacy practices employed by other websites. Unless otherwise stated, any information you provide to any such third-party website will be collected by that party and not by us, and will be subject to that party’s privacy policy (if any), rather than this Policy. In such a situation, we will have no control over, and shall not be responsible for, that party’s use of the information you provide to them.
• Web Site Analytics Services. The Website uses a tool called “Google Analytics” to collect information about use of the site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our Website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to our Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to our Website by disabling cookies on your browser.
• Minors. If you are under eighteen (18) years old, you or your parents or legal guardians can request that we remove content or information that you have posted to our Website or other online services. To request removal of content or information, please contact us.

Security

We recognize the importance of maintaining the security of your information. Since any information transmitted via the internet cannot be perfectly secure, we are not able to provide a guarantee of such security. However, we take commercially reasonable steps to protect the confidentiality and security of personal information you share with us through our Website.

• Email Security. Please be cautious of “phishing”, which is a common email scam where your email address is used to contact you and ask for personally identifiable or sensitive information. Always be cautious when opening links or attachments from unsolicited third parties. Also know that we will not send you emails asking for your credit card number, social security number or other personally identifiable information. If you are ever asked for this information, you can be confident it is not from us.
• Children’s Information. We recognize the importance of protecting children’s online privacy. Our Website and mobile services are intended for a general audience and are not directed to children. We do not knowingly collect personal information online from children under the age of thirteen (13).

Information Specific to California Residents

If you are a California resident, the information below also applies to you. Certain terms used in this section have the meanings given to them in the California Consumer Privacy Act of 2018 (“CCPA”).
As a California resident, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please contact us as described in the Contact Us section, below. Indicate in your email or letter that you are a California resident making a “California Shine the Light” inquiry.

Effective January 1, 2020, if you reside in California, then you have the following rights:

• You have the right to opt-out of the sale of your personal information.
• You have the right to request the deletion of your personal information.
• You have the right to request us to disclose to you, no more than twice in a twelve (12) month period, the personal information about you that we collect, use, disclose, and sell (if at all) during the preceding twelve (12) months.

We have tried to explain our privacy practices in full in the other sections of this Policy. In this section, we supplement those descriptions for California residents by providing a list of categories of personal information as set forth in the CCPA that have been collected or disclosed for a business or commercial purpose during the preceding twelve (12) months, as well as certain other information. Please see the other sections of the Policy for additional information and context.

As discussed in the other sections of our Policy, we collect this type of information from you, through our interactions with you and others, and from third parties, and we disclose these categories of personal information internally and externally as described in this Policy. Your personal information may also be shared with third parties with whom you interact and third parties that you direct us to share your information with through our services. You may learn about your choices for third-party advertising cookies and similar technologies in our cookie policy as further explained above. We do not sell your information to third parties for purposes of California law.

As noted above, some web browsers may transmit “Do Not Track” signals to the Website and other online services with which a user communicates. We currently do not take action in response to these signals.

Any requests related to this policy shall be submitted to info@shiftlife.com. In addition, we may be contacted as described in the Contact Us section, below.

We will not discriminate against you because you exercised your rights under this section of the Policy.

We do not knowingly collect personally identifiable data from persons under the age of 18, and strive to comply with the provisions of COPPA (The Children’s Online Privacy Protection Act). If you are a minor, parent or legal guardian and think your child has provided us with information, please contact us at info@shiftlife.com. You can also write to us at the address listed at the end of this Policy. Please mark your inquiries “COPPA Information Request.”

International Clients

If you provide personal information through our Website, you agree that the personal information will be transferred to and processed in the United States of America and any other country or jurisdiction at our sole discretion. The laws that apply to the use and protection of personal information in the United States or other countries or jurisdictions in which we transfer or process personal information may be different than the laws and protections in your country.

Public Forum

Our Website may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from any blog or community forum available on our Website, contact us at info@shiftlife.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Links

The Website may contain links to other third-party sites (such as social media websites or applications) that are not governed by this Policy. If you click on a link to a third-party site, you will be taken to a site we do not control. We are not responsible for the privacy practices used by third-party sites. We suggest that you read the privacy policies of those sites carefully. We are not responsible for these third-party sites.

Retention of Your Information

We will retain your personal information for as long as you have a relationship with us, and for a period after your relationship with us has ended. When determining how long this retention period will last, we take into account the length of time personal information is required to:

• Continue to develop, tailor, upgrade, and improve our services;
• Maintain business records for analysis and/or audit purposes;
• Comply with record retention requirements under the law;
• Defend or bring any existing or potential legal claims; or
• Address any complaints regarding the services.

Contact Us

Mailing Address:

SHIFT
435 N LaSalle Dr, Suite 300
Chicago, IL 60654

Phone: (312) 566-4209
Fax: 312.277.5252

Inquiries: info@shiftlife.com