Privacy Policy - Echo Health Ventures

Welcome to the Echo Health Ventures LLC website. Please read these Terms of Use carefully before using this website. By accessing this website in any manner, you agree to be bound by these Terms of Use, and any additional terms and conditions that are referenced below or otherwise may apply to specific areas of this site.

We reserve the right to change these Terms of Use at any time. Such changes will be effective when posted. By continuing to use the site after we post any such changes, you accept the Terms of Use as modified.

NO OFFER, SOLICITATION OR ADVICE

Nothing on this Website is intended to constitute (i) an offer, or solicitation of an offer, to purchase or sell any security, other asset or service, (ii) investment advice or an offer to provide such advice, or (iii) a basis for making any investment decision. This website does not make any effort to present a comprehensive or balanced description of Echo Health Ventures LLC or its investment activities.

DISCLAIMER OF PROFESSIONAL OR FINANCIAL ADVICE

NOTHING IN THIS SITE CONSTITUTES PROFESSIONAL AND/OR FINANCIAL ADVICE, NOR DOES ANY INFORMATION ON THIS SITE CONSTITUTE A COMPREHENSIVE OR COMPLETE STATEMENT OF THE MATTERS DISCUSSED OR THE LAW RELATING THERETO. ECHO HEALTH VENTURES IS NOT AN INVESTMENT ADVISOR AND DOES NOT MAKE ITS SERVICES AVAILABLE TO THE GENERAL PUBLIC. NO ACTION SHOULD BE TAKEN OR NOT BE TAKEN IN RELIANCE UPON INFORMATION ON THIS SITE.

NOTHING ON THIS SITE CONSTITUTES OR FORMS A PART OF ANY OFFER FOR SALE OR SUBSCRIPTION OF, OR ANY INVITATION TO OFFER TO BUY OR SUBSCRIBE FOR, ANY SECURITIES, NOR SHOULD IT OR ANY PART OF IT FORM THE BASIS OF, OR BE RELIED UPON IN ANY CONNECTION WITH ANY CONTRACT OR COMMITMENT WHATSOEVER.

RULES OF CONDUCT

There are a few rules of conduct that you are required to follow when you use this website:

Do not “harvest” (or collect) information from the site using an automated software tool or manually on a mass basis (unless we have given you separate written permission to do so). This includes, for example, information about other users of the site and information about the offerings, products, services and promotions available on the site.

Do not use automated means to access the site, or gain unauthorized access to the site or to any account or computer system connected to the site. This prohibition does not apply to search engines accessing the site solely for web indexing purposes.

Do not “stream catch” (download, store or transmit copies of streamed content).

Do not obtain, or attempt to obtain, access to areas of the site or our systems that are not intended for access by you.

Do not “flood” the site with requests or otherwise overburden, disrupt or harm the site or its systems.

Do not circumvent or reverse engineer the site or its systems.

Do not restrict or inhibit another user or users from using and enjoying this site.

You also must comply with all applicable laws and contractual obligations when you use this site.

OWNERSHIP OF SITE CONTENT

We or our licensors or partners own the intellectual property rights in the content and materials displayed on this website. You may use this site (including such content and materials) for your own personal, non-commercial use, but you may not exploit it commercially. You may not modify, copy, reproduce, republish, upload, post, transmit, translate, sell, create derivative works, exploit, or distribute in any manner or medium (including by email or other electronic means) any material from this site unless explicitly authorized in these Terms of Use or by the owner of the materials. You may, however, download and/or print one copy of individual pages of the site for your personal, non-commercial use, provided that you keep intact all copyright and other proprietary notices.

DMCA Notice

Echo Health Ventures respects the intellectual property of others. If you believe that your work has been copied in a way that constitutes copyright infringement, please follow our Notice and Procedure for Making Claims of Copyright Infringement.

If you believe that your work has been copied in a way that constitutes copyright infringement, please provide us with this information:

A physical signature of the person authorized to act on behalf of the owner of the copyright interest;
A description of the copyrighted work that you claim has been infringed upon;
A description of where the material that you claim is infringing is located on the site;
Your address, telephone number, and e-mail address;
A statement by you that you have a good-faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law;
A statement by you, made under penalty of perjury, that the above information in your notice is accurate and that you are the copyright owner or authorized to act on the copyright owner's behalf.

Echo Health Ventures Copyright Agent for notice of claims of copyright infringement on its site can be reached as follows:

Echo Health Ventures LLC

100 SW Market Street

Portland, OR 97201

Attn: Legal Department

e-mail: legal@echohealthventures.com

CALIFORNIA CITIZEN RIGHTS

Individuals who reside in the state of California, a “consumer,” as that term is defined under California law, have additional rights reserved under the California Consumer Privacy Act (CCPA) and the California Shine the Light law:

Right to Opt-Out. We do not sell personal information.

Right to Request Personal Information. As a consumer, you have the “right to know” and request that we disclose what personal information we collect, use, and disclose. See the instructions below for submitting a verifiable request, including through the online request form offered by us. You have the right to request the categories of personal information, as detailed under the CCPA, we have collected and store about you. In addition, you have the right to request categories of sources of personal information we collected about you, the business or commercial purpose for collecting, the categories of third parties with whom we share that personal information, and the specific pieces of personal information we have collected about you. Categories of personal information that we disclosed about you for a business purpose may also be requested, with the appropriate lists provided under the CCPA. Upon receipt of a verifiable consumer request, described below in this Privacy Statement/Notice, from you to access personal information, we will promptly take steps to disclose and deliver, free of charge to you, the personal information required by this section and within the timeframes permitted for responding to exercise of this or other applicable right(s). The information may be delivered by mail or electronically, dependent on portability and technical considerations under the CCPA. We may provide personal information to you at any time following a verified request, but shall not be required to provide personal information to you more than twice in a 12-month period.

Right to Delete Personal Information. You have the right to request we delete personal information we, or our service providers, store about you. Please keep in mind our response to such a request, upon verification, may include an explanation of the business purpose under which we may retain your information (for example, we would need to retain copies of a business transaction for financial records) in accordance with the CCPA.

Non-Discrimination. If you elect to exercise any right(s) under this section of our Privacy Statement, we will not discriminate or retaliate against you.

If you are a California consumer and would like to submit a request based on this section of our Privacy Statement, please use this web form, email us at compliance@cambiahealth.com, or call us toll-free at (877) 878-2273. Also, be sure to check this policy for updates as we will review it at least every 12 months and make updates as necessary.

Identity Verification Requirement. We are required by law to verify that any data access request submitted under the authority of the CCPA was made by someone with the legal right to access the personal information requested. Therefore, prior to accessing or divulging any information pursuant to a data subject access request, under the terms of the CCPA, we may request that you provide us with additional information in order for us to verify your identity, your request, and legal authority (ex. authorized representative). Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. Please indicate in your request if either of these apply, as additional verification may apply (ex. verify consumer’s identify and confirm with impacted person(s) that the authorized agent has permission to submit the request).

A verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. A verifiable request must also include sufficient detail that allows us to properly understand, evaluate, and respond to it.

In general, our verification process includes reviewing the information submitted in the request, comparing it to the right(s) requested; the number of verification points/methods required by the CCPA; and the type, sensitivity, and risk of information requested, including to the consumer, from unauthorized disclosure or deletion. An account is not required with us in order to make a request. We will use personal information provided in a verifiable consumer request to verify the requestor's identity and authority to make the request, or otherwise as permitted by the CCPA (ex. record retention). We will respond to a verifiable consumer request within 45 days of its receipt, and if we require more time (up to 90 total days), we will inform you of the reason of the extension in writing. A response to a consumer request will be provided as required by the CCPA, such as through an account (if one exists), or otherwise by mail or electronically.

Access Request Responses. Under the CCPA, there may be certain circumstances where we would deny your request to access, receive, or delete personal information we hold. For example, we would deny requests where any such access or disclosure would interfere with our regulatory or legal obligations, where we cannot verify your identity, and/or where exemptions/exceptions permitted by the CCPA apply. We also have the ability under the CCPA to deny requests if it would result in our disproportionate cost or effort. Further, certain rights granted by the CCPA will not be effective until January 1, 2021. However, even where we will not substantively complete a request made under the CCPA, we will still provide a response and explanation to your request within a reasonable time frame and as required by law.

Disclosure of Categories. As defined by the CCPA, categories of personal information collected from consumers by us within the past 12 months include:

Category (A) – Identifiers. Collected? Yes. Examples include 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.
Category (B) - Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Collected? Yes. Examples include 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.
Category (C) – Protected classification characteristics under California or federal law. Collected? Yes. Examples include age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Category (D) – Commercial information. Collected? Yes. Examples include records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Category (E) – Biometric information. Collected? Yes. Examples include genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, face prints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Category (F) – Internet or other similar network activity. Collected? Yes. Examples include Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Category (G) – Geolocation data. Collected? Yes. Examples include physical location or movements.
Category (H) – Sensory data. Collected? Yes. Examples include audio, electronic, visual, thermal, olfactory, or similar information.
Category (I) – Professional or employment-related information. Collected? Yes. Examples include current or past job history or performance evaluations.
Category (J) – Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Collected? No. Examples include education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Category (K) - Inferences drawn from other personal information. Collected? Yes. Examples include profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Personal information may also be collected in the course of a natural person acting as a current or former job applicant, employee, director, officer, or contractor within the context of that natural person’s role. Additional information collected may include emergency contact and information to administer benefits, including to another person.

“Personal information” does not include publicly available information, meaning information that is lawfully made available from federal, state, or local government records. “Publicly available” does not mean biometric information collected by a business about a consumer without the consumer’s knowledge. “Personal information” also does not include consumer information that is deidentified or aggregate consumer information. This Notice addresses online and offline practices by us. Information excluded from the CCPA’s scope includes health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Other information excluded includes those covered by the California Confidentiality of Medical Information Act (CMIA) or clinical trial data, and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Personal information is collected and may be used to provide the services to you, to perform obligations under agreements, to provide information and notifications to you or an authorized representative, to protect the rights and safety of you and/or others, to comply with court and other legal requirements, for business purposes and as otherwise set forth in the CCPA, to conduct organizational and operational needs, and as otherwise described when collecting personal information or within this page. A request for personal information collected and/or deletion, noted above, may involve categories and/or specific pieces of information. However, certain exemptions and exceptions may apply in responding to a request.

This business has not sold categories of personal information within the meaning of the CCPA, including minors under 16 years of age.

Categories of personal information from our consumers disclosed for a business purpose within the past 12 months include:

(A) Identifiers such as real name, alias, postal address, unique identifiers, online identifiers, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or similar identifiers;

(B) Categories of personal information as described in California Civil Code 1798.80(e);

(C) Characteristics of protected classifications under California or federal law;

(D) Commercial information, including records of personal property, products or services purchased, obtain, or considered, or other purchasing or consuming histories or tendencies;

(E) Biometric information;

(F) Internet or other electronic network activity information, including but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement;

(G) Geolocation data;

(H) Audio, electronic, visual, thermal, olfactory, or similar information;

(I) Professional or employment-related information; and

(K) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Business purposes may include auditing (ex. auditing and legal/regulatory compliance), security (ex. detecting security breaches), debugging (ex. identifying and fixing technical errors), short-term uses (ex. ad customization), performing services (ex. processing transactions), internal research (ex. product development), and testing/improvement (ex. improvement of technology).

Categories of sources from which personal information was directly and indirectly collected in the past 12 months include from you and/or authorized agents (ex. documents provided to us related to the services for which you/they engage us, and information we collect in the course of providing services to you/them); interaction with our platforms and services (ex. website portal); and third parties (ex. those that provide services such as purchased information, advertising networks, internet service providers, operating systems and platforms, social networks, and data brokers). This could include information obtained on websites and services from third parties that interact with us in connection with the services we perform or are linked to.

Categories of third parties with whom the business shared personal information in the past 12 months include authorized agents, affiliates, service providers (such as those described previously), contractors, and authorized third parties.

Annual reporting. As required by the CCPA, for the prior calendar year the following information is provided. Number of Requests to Know that we received (0), complied with in whole (0) or in part (0), and denied (0). Number of Requests to Delete that we received (0), complied with in whole (0) or in part (0), and denied (0). Number of Requests to Opt-Out that we received (0), complied with in whole (0) or in part (0), and denied (0). The mean number of days within which we substantively responded to Requests to Know (28 calendar days), Requests to Delete (0 calendar days), and Requests to Opt-out (0 calendar days).

Finally, you may be able to request information contained in the California Citizen Rights section in another language where we provide such notices in the ordinary course of business or in an alternative format if you have a disability. Please see our contact information contained within our Privacy Policy.

Echo Privacy Policy Results

Year: 2021

	Request To Know	Request To Delete	Request to Opt Out	Average days to respond
Denied	0	0	0	N/A
Complied in part	0	0	0	N/A
Complied in whole	0	0	0	N/A
Total	0	0	0
Average days to respond	N/A	N/A	N/A	N/A

Contact Us. To make a request please contact us at please contact the us at compliance@cambiahealth.com with “CCPA Personal Information Request” in the subject line, and provide us with full details in relation to your request, including your contact information, the specific name of this business, and any other detail you feel is relevant. You can also use the other contact methods mentioned previously. If you are from another area (ex. state) and believe you are entitled to exercise applicable right(s), please use the email address and/or phone number given and include relevant details. If you have questions or concerns about our privacy policies and practices, you can use the contact methods mentioned above (ex. telephone, email) in this Notice to contact us.

CHANGES TO THIS SITE

We reserve the right to make changes to, or to suspend or discontinue (temporarily or permanently), this site or any portion of this site. You agree that we will not be liable to you or to any third party for any such modification, suspension or discontinuance.

SUSPENSION OR TERMINATION OF ACCESS

We have the right to deny access to, and to suspend or terminate your access to, the site, or to any features or portions of the site, at any time and for any reason, including for any violation by you of these Terms of Use. In the event that we suspend or terminate your access to and/or use of the site, you will continue to be bound by the Terms of Use that were in effect as of the date of your suspension or termination.

LINKING POLICIES

This site may contain links to other websites or to third-party sellers of products and services. Such links are provided for your convenience only, and you access them at your own risk. We are not responsible for, and do not endorse, the content of any such sites, or the products and services sold on them, nor do we take responsibility for the accuracy of any such sites. When you visit a linked site, you should read the terms of use and privacy policy that govern that particular linked site.

We welcome links to this site so long as: (i) this site opens in a new browser window which displays the full version of a page of this site (e.g., not merely one of its frames, and not an "in-line" link to a particular image or object on this site), (ii) the link to this site does not state or imply any sponsorship of your website or service by us or by this site; and (iii) this site is not display-framed within or obfuscated by other content. You may not use on your site any trademarks, service marks or copyrighted materials appearing on this site, including but not limited to any logos, without our express written consent. We reserve the right to revoke your right to link to this site upon notice. If you receive such a notice from us, you agree to discontinue your link to the site.

JURISDICTIONAL ISSUES

We control and operate this website from our facilities in the United States of America, and unless otherwise specified, the materials displayed on this website are presented solely for the purpose of promoting products and services available in the United States, its territories, possessions, and protectorates. We do not represent that materials on this site are appropriate or available for use in other locations. If you choose to access this site from other locations, you are responsible for compliance with local laws, if and to the extent local laws are applicable.

APPLICABLE LAW; NO WAIVER; SEVERABILITY

These Terms of Use, and the relationship between you and us, will be governed by the laws of the United States and the State of Delaware, without giving effect to any principles of conflicts of law. Our failure to exercise or enforce any right or provision of these Terms of Use will not constitute a waiver of such right or provision. If any provision of these Terms of Use is found by a court of competent jurisdiction to be invalid, you and we nevertheless agree that the court should endeavor to give effect to intentions as reflected in the provision, and the other provisions of these terms and conditions will remain in full force and
effect.

GOVERNING JURISDICTION

ANY DISPUTE NOT INITIATED IN SMALL CLAIMS COURT WILL BE LITIGATED BY EITHER PARTY IN A COURT OF COMPETENT JURISDICTION ONLY IN THE UNITED STATES DISTRICT COURT FOR THE STATE OF DELAWARE, OR, IF SUCH COURT WOULD NOT HAVE JURISDICTION OVER THE MATTER, THEN ONLY IN A STATE COURT SITTING IN DELAWARE. EACH PARTY SUBMITS TO THE EXCLUSIVE JURISDICTION OF THESE COURTS AND AGREES NOT TO COMMENCE ANY LEGAL ACTION UNDER OR IN CONNECTION WITH THE SUBJECT MATTER OF THIS TERMS OF USE IN ANY OTHER COURT OR FORUM. EACH PARTY WAIVES ANY OBJECTION TO THE LAYING OF THE VENUE OF ANY LEGAL ACTION BROUGHT UNDER OR IN CONNECTION WITH THE SUBJECT MATTER OF THIS TERMS OF USE IN THE FEDERAL OR STATE COURTS SITTING IN DELAWARE, AND AGREES NOT TO PLEAD OR CLAIM IN SUCH COURTS THAT ANY SUCH ACTION HAS BEEN BROUGHT IN AN INCONVENIENT FORUM.

DISCLAIMER OF WARRANTIES

WE PROVIDE THIS SITE ON AN "AS IS" AND "AS AVAILABLE" BASIS, WITHOUT WARRANTY OF ANY KIND WHETHER EXPRESS OR IMPLIED (INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR ANY PARTICULAR PURPOSE AND NON-INFRINGEMENT). THIS MEANS THAT WE MAKE NO PROMISES THAT:

THE SITE WILL BE AVAILABLE AT ANY PARTICULAR TIME,

THE SITE WILL MEET ANY PARTICULAR REQUIREMENTS OR PROVIDE ANY PARTICULAR RESULTS,

THE INFORMATION ON THE SITE WILL BE ACCURATE OR UP-TO-DATE,

THE SITE OR THE INFORMATION TRANSMITTED TO OR FROM IT OR STORED ON IT WILL BE SECURE FROM UNAUTHORIZED ACCESS, OR

THE SITE WILL BE UNITERRUPTED OR ERROR-FREE OR WILL BE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS, OR THAT DEFECTS WILL BE CORRECTED.

YOU AGREE THAT USE OF THIS SITE IS AT YOUR OWN RISK. ALTHOUGH WE TRY TO ENSURE THAT THE INFORMATION POSTED ON THIS SITE IS ACCURATE AND UP-TO-DATE, WE RESERVE THE RIGHT TO CHANGE OR MAKE CORRECTIONS TO ANY OF THE INFORMATION AT ANY TIME. WE CANNOT, AND DO NOT, GUARANTEE THE CORRECTNESS, TIMELINESS, PRECISION, THOROUGHNESS OR COMPLETENESS OF ANY OF THE INFORMATION AVAILABLE ON THIS SITE, NOR WILL WE BE LIABLE FOR ANY INACCURACY OR OMISSION CONCERNING ANY OF THE INFORMATION PROVIDED ON THIS SITE. NO ADVICE, RESULTS OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM US OR THROUGH THE SITE SHALL CREATE ANY WARRANTY NOT EXPRESSLY MADE HEREIN. WE HEREBY DISCLAIM, AND YOU HEREBY WAIVE, ANY AND ALL WARRANTIES AND REPRESENTATIONS MADE ON THE SITE OR IN CORRESPONDENCE WITH US OR OUR AGENTS. WE ARE NOT RESPONSIBLE FOR ANY CONTENT OR MATERIALS POSTED TO OUR SITE BY USERS, NOR FOR DISPUTES BETWEEN USERS, OR BETWEEN USERS AND THIRD PARTIES.

THESE DISCLAIMERS APPLY TO US AND OUR AFFILIATED AND RELATED COMPANIES AS WELL AS THIRD PARTIES THAT ARE INVOLVED IN THE CREATION, PRODUCTION OR DISTRIBUTION OF THE SITE, AND ANY OF THEIR EMPLOYEES AND AGENTS.

LIMITATIONS OF LIABILITY

Except as specifically agreed by Echo Health Ventures LLC in writing, NO ECHO HEALTH VENTURES LLC INDIVIDUAL OR ENTITY SHALL HAVE ANY LIABILITY BASED UPON YOUR USE OF, OR RELIANCE UPON, THIS WEBSITE OR THE MATERIALS. Some jurisdictions limit our ability to disclaim liability. With regard to those jurisdictions, our liability shall be limited to the greatest extent permitted by applicable law

YOU AGREE THAT REGARDLESS OF ANY STATUTE OR LAW TO THE CONTRARY, ANY CLAIM OR CAUSE OF ACTION THAT YOU MAY HAVE ARISING OUT OF OR RELATED TO USE OF THIS WEBSITE, OR THESE TERMS OF USE, MUST BE FILED BY YOU WITHIN ONE YEAR AFTER SUCH CLAIM OR CAUSE OF ACTION ACCRUED OR BE PERMANENTLY BARRED.

OTHER

If any provision of these Terms of Use is found to be unlawful, void, or for any reason unenforceable, then that provision will be deemed severable from these Terms of Use and will not affect the validity and enforceability of any remaining provisions. These Terms of Use are not intended to benefit any third party, and do not create any third-party beneficiaries. Accordingly, these Terms of Use may only be invoked or enforced by you or us.

CONTACT INFORMATION

Any questions, concerns or complaints regarding these Terms should be sent to legal@echohealthventures.com.

Effective Date: November 15, 2016

Last Updated: August 18, 2021