Originally Effective Date: May 22, 2019 

Last Updated: August 2026

1. Introduction 

This Privacy Policy describes the privacy practices of ChiroUp, Inc. d/b/a HealthCom and its affiliates (referred to collectively as the “Company,” “us,” “we” and “our”) related to the use, storage, and disclosure of personal information we collect from or about you when you interact with us in the course of our providing our Service. Our “Service” consists collectively of our HealthCom platform, including any content,  functionality, and Service offered on or through our website HealthCom.io (the "Website"), our Apps available on iTunes or Google Play (the “Apps”), our two-way text messaging service, and all content, functionality, and Service offered on or through any of them. Except where noted, statements in this Privacy Policy with respect to the Website also apply to the Apps.

Some components of the Service, including text messaging, may be operated by or branded under your provider's healthcare practice. In those cases, your healthcare provider is the primary data controller or HIPAA-covered entity for the messages and patient information exchanged through that account, while HealthCom acts as its HIPAA-compliant Business Associate and data processor under a Business Associate Agreement. When these features are used, your healthcare provider controls the purpose and content of patient communications and is the HIPAA covered entity or other applicable data controller, while HealthCom acts as a Business Associate or processor where applicable.

For activities involving protected health information (PHI) that we process on behalf of provider customers, we act solely as a Business Associate/processor, following their instructions and applicable law. For all other activities (such as operating our public websites, mobile applications, analytics, and marketing properties that do not involve PHI processed on behalf of a provider), we act as an independent controller/business responsible for our own data processing activities under applicable privacy laws.
We reserve the right to modify this Privacy Policy at any time and without prior notice. We will post any changes to our Website and note the effective date of the updated Policy.

If you are using the Service on behalf of a company, organization, government, or other legal entity, or through an association or affiliation with one of these entities, your use certifies to us that an authorized person from your organization has accepted this Privacy Policy on your behalf, that you are authorized to use the Service, and that your use is within the scope of that relationship.
As a condition to your access to and use of the Service, you must agree to our Terms of Use, which includes this Privacy Policy. If you do not want us to collect and use information about you as described in this Privacy Policy, then you must not use the Service. Please be aware that the privacy laws and standards in certain countries may differ from those that apply in the country in which you reside.
 

2. Privacy Laws 

Some of the information we collect and use is subject to specific state and federal privacy laws. For example, many of our customers in the United States healthcare industry are subject to regulations issued under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"). Among other things, HIPAA outlines the ways health care providers, health plans, certain data processors, and companies they hire to perform certain functions on their behalf (such as ChiroUp) may use and share personally identifiable information about a patient. When we receive information that is subject to privacy laws, such as HIPAA, we may be legally or contractually obligated to follow those laws. If there is a conflict between this Privacy Policy and privacy laws to which we are bound, the privacy laws shall govern.

3. Information We Collect 

We collect both personally identifiable and non-identifiable information as part of our Service. Personally identifiable information means information that identifies you, such as your name, address, birthdate, phone number, e-mail address, social security number, medical or health record number, or other health or medical-related information about you.

Information You Provide

We collect information from you when you create an account with the Service or provide information as part of our identity verification process. This information may include personally identifiable information, as well as account authentication information like username, password, and security questions.

We collect the information that you upload or enter when you use the Service. For example, you may enter information, which may include personally identifiable information, about you or others as part of:

• an individual care plan;
• a referral request; or
• a consultation with an outside health care provider.
• photographs, images, electronic signatures, completed forms, documents, profile information, and other materials that you or your provider upload to or create through the Service;
• audio and temporary transcripts processed through AI-assisted clinical documentation features, where enabled; or
• a telephone call answered by, or a text message conversation handled by, the AI Receptionist, including your name, date of birth, contact information, appointment preferences, the reason for your visit, or the content of any message you leave.
   

4. Information We Collect When You Access Our Service 

We collect information about the Service you use and how you use it. This information includes:

Log Files and Device Information: Log files include information such as your IP address (a number that identifies your computer or other device connected to the internet), internet browser type, pages visited,  and search terms. We may also collect information about the device you use to connect to our Service,  including your device type and operating system.

Cookies. We use Cookies (small text files placed on your device) to provide our Service and help collect data. We use Cookies for four main purposes: (1) confirmation of your identity during sign-in to access your account; (2) security and Service integrity, (3) store your preferences and settings; and (4) analyzing how our Service are performing.

We also collect limited information from your participation in our text messaging services, including message content, delivery status, and device metadata. These data are used to provide and monitor message delivery, ensure compliance with applicable communication laws, and enhance the reliability of our messaging system.

When you call a provider whose line is answered by the AI Receptionist, or exchange text messages handled by the AI Receptionist, we also collect communication metadata, including the phone number you called or texted from, the date, time, and duration of the call or conversation, and the outcome (such as whether an appointment was scheduled or a message was taken). We use these data to provide the Service, route and document your communication, support billing between us and your provider, and monitor system quality and reliability. We do not use your voice to identify you.
 

5. Information We Receive from Other Sources 

We receive and store information, which may include information about you, including personally identifiable information, from your chiropractic provider and his or her staff and other third parties.

Your Provider: We may receive information about you from your chiropractic provider or other personnel in his or her office. For example, your provider may use our Service to help coordinate your care or treatment plan. We may receive information about you when your provider enters or uploads patient information into the Service. We execute a HIPAA-compliant Business Associate Agreement with each provider to safeguard your protected health information as required by law.

Third Parties: We may receive information about you from third parties. For example, we may receive  information about you from:

• government agencies, such as the Centers for Medicare and Medicaid Services, that is used to  improve health care decisions; or
• an identity provider/authenticator when you enable single sign-on to access your account (such as using your Google account to sign in to our Service).
   

6. How We Use Information We Collect 

We may use the information we receive to: 

• provide, operate, maintain, improve, extend, and test the Service;
• provide and create documentation, training, and professional services related to the Service;
• fulfill our legal and contractual obligations;
• create and deliver analyses of data; and
• develop de-identified data analyses for our own, or providers’ quality improvement purposes.
   

Examples of ways we use the information for the reasons described above include:

• to display your account information;
• to ensure that Service users only see the information they are authorized to see;
• monitoring our systems to ensure that they are working as intended and to detect and fix errors;
• accessing log information to investigate problems or unauthorized use; and
• analyzing data and usage patterns to make the Service easier to use.
   

We may use the information we collect to contact you. For example, we may send you: 

• notifications and reminders when you are mentioned or assigned an action in the Service;
• appointment reminders;
• send and receive text messages related to scheduling, exercise instructions, educational materials, patient satisfaction surveys, and limited promotional content where permitted by law;
• news and information about the Service or your account;
• information about exercise plan updates, exercise reminders, automated feedback on  compliance; educational topics;
• requests for online reviews;
• requests for information and feedback on clinical outcome and satisfaction surveys; and
• news and information about your provider’s practice, including services and marketing materials.
   

We may also use the information we collect to: 

• protect our rights or property, or the security or integrity of our Service;
• enforce the terms of the Terms of Service;
• verify your identity;
• protect us, users of our Service, or the public from harm or potentially prohibited or illegal  activities;
• investigate, detect, and prevent fraud, security breaches; or
• interact with law enforcement authorities and comply with any applicable law, regulation, legal process, or governmental request.
   

In addition, we may use personal information about you for other purposes that are disclosed to you at the time we collect the information and/or with your consent.

We may share your information with our subsidiaries, affiliates and entities acquired by or merged with us and our affiliates. In the event of a corporate change in control resulting from, for example, a sale to, or a merger with, another entity, or in the event of a sale of assets or a bankruptcy, we reserve the right to transfer your personal information to the new party in control or the party acquiring assets. In the event of such a change, your personal information will continue to be treated in accordance with this Privacy  Policy unless any changes to the Privacy Policy are made in accordance with the section above that discusses our right to modify this Privacy Policy.

7. AI-Assisted Clinical Documentation

Your healthcare provider may use AI-assisted clinical documentation features, including Voice-to-Chart, to assist with preparation of clinical documentation. When these features are used, audio from the clinical encounter and a temporary transcript may be processed to generate draft documentation. The audio and temporary transcript are deleted when the resulting clinical note is signed. The resulting signed note may remain in the medical record maintained by your provider. Your provider is responsible for providing any notice or obtaining any consent required by applicable law and for reviewing and approving clinical documentation before it becomes part of the medical record.

We do not use identifiable patient information or protected health information to train artificial-intelligence models, except as expressly permitted by applicable law. We may use information that has been de-identified in accordance with applicable law, including HIPAA where applicable, to develop, evaluate, secure, and improve our products and services.
 

8. Provider Access 

Your chiropractic provider’s office has the ability to track and review various metrics – limited to that practice’s patients – including:

• who downloaded the App;
• message open rates;
• exercise video views;
• patient-reported exercise compliance; and
• clinical outcome and satisfaction survey results.
   

9. Your Choices 

Your Account Information 

If you have an account, you may access, change, or correct your personal account information at any time by logging into your account. You may also make the request to us using the contact details below, in which case we may need to verify your identity before granting access or otherwise changing or correcting your information.

Email Communications

You may manage your newsletter subscriptions within the newsletter subscriptions area within your account settings. Note that certain email communications that we send to members are service-related and as long as you are a user of the Service, you may not unsubscribe from such emails. Also, if you have provided us more than one email address, we may continue to contact you using the other email address not associated with the emails from which you have unsubscribed, until you unsubscribe from emails sent to that other address.

Push Notifications

We may send you push notifications from time to time to notify you of upcoming events or promotions we think may be relevant to you. If you no longer wish to receive these types of notifications, you may turn them off at the device level. 

10. Text messaging

We provide optional two-way text messaging (“SMS/MMS”) features that allow you and your provider to communicate about your care, appointments, and related educational content. Your participation in this feature is voluntary. Your healthcare provider controls the content and purpose of messages sent through its account and is responsible for obtaining any consent required by applicable law for marketing or promotional communications.

Information We Collect via Text Messaging

When you use text messaging features, we may collect:

• Contact Information: your phone number, name, and any other details you voluntarily share in a message or related form.
• Usage Information: timestamps, delivery and open status, and message content.
• Device and Network Data: carrier name and device type (for troubleshooting or compliance tracking).

How We Use Text Messaging Information

We may use information collected through text messages to:

• Deliver operational communications such as appointment reminders, exercise instructions, or satisfaction surveys.
• Send informational or educational messages related to your care.
• Deliver promotional content about a provider’s services when directed by the provider and when the provider has obtained any consent required by applicable law.
• Improve message delivery, response tracking, and overall system performance.
• Fulfill legal and regulatory obligations, including maintaining contact logs for compliance.
   

Opt-Out and Frequency

You may opt out of receiving text messages at any time by replying “STOP” to any message. After you opt out, you will no longer receive messages unless you re-subscribe. Message frequency may vary depending on your provider’s communication preferences and your interactions. Standard message and data rates may apply.

SMS Program Disclosures

• Keywords: Reply HELP for help; reply STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to stop.
• Rates: Message and data rates may apply.
• Frequency: Message frequency varies based on your interactions and your provider’s preferences.
• Support Contact: For help with messaging, contact your healthcare provider.
• Carrier Liability: Mobile carriers are not liable for delayed or undelivered messages.

We register and maintain our messaging program in accordance with 10DLC and CTIA guidelines and may restrict content that violates carrier or industry rules.
 

Security and Sensitive Content

Messages and any images (MMS) you send are transmitted through standard mobile networks and are not encrypted in the same way as data transmitted through our secure HealthCom platform. You should avoid sending or including any sensitive personal, financial, or medical information via text message. When sensitive information must be exchanged, providers will offer a a secure alternative within the HealthCom platform or another approved method. Access to care is not conditioned on consenting to SMS.

Retention

We retain text message records as long as necessary to support operational or legal purposes, consistent with our overall data retention policy. Once no longer needed, data is securely deleted or anonymized.

Telephone Consumer Protection Act (TCPA) Notice

By providing your mobile number and opting in to receive text messages, you consent to receive messages from your provider or through the Service as permitted by law. Your consent is not a condition of purchase or service. You may withdraw consent to receive text messages at any time by replying “STOP” to any message.

Healthcare and Marketing Text Communications (HIPAA and TCPA)

Your provider is responsible for determining the legal basis and obtaining any consent required for text messages sent through its account, including treatment, operational, informational, and marketing or promotional communications.

• Healthcare, Treatment, and Operational Messages: Your provider may use the Service for non-marketing health-related and operational communications, such as appointment reminders, exercise instructions, outcome assessments, patient-experience or satisfaction surveys, and invitations following such surveys to provide feedback or leave a public review, subject to applicable law and the provider’s communication practices.
• Marketing or Promotional Messages: Your provider is responsible for obtaining any prior express written consent or other authorization required by applicable law before sending marketing or promotional messages. HealthCom does not independently determine or control the content of messages selected and sent by a provider.

We honor opt-out requests submitted by replying STOP. Message frequency and quiet-hours practices may vary based on your provider’s settings and applicable law.

11. AI Receptionist (Automated Phone and Text Assistant)

Your healthcare clinic may use the Service’s optional automated assistant powered by artificial intelligence (the “AI Receptionist”). If your clinic enables it, the AI Receptionist may answer telephone calls placed to the clinic and may respond to text messages you send to the clinic in order to schedule, reschedule, or cancel appointments, answer general questions about the clinic, take messages, and transfer calls.

The AI Receptionist does not provide medical advice. It cannot answer questions about your symptoms, condition, or treatment. If you are experiencing a medical emergency, hang up and dial 911.

Information we collect. When you interact with the AI Receptionist by phone or text, we collect the information you provide on behalf of your clinic, which may include your name, date of birth, phone number, email address, appointment preferences, the reason for your visit, or the content of any message you leave. For telephone calls, audio is processed transiently to create a transcript. HealthCom does not retain an audio recording of AI Receptionist calls.

Identity verification. To help protect your privacy, the AI Receptionist may ask you to verify your identity, such as your name and date of birth, before discussing existing appointment details.

How your information is used. Information collected by the AI Receptionist is collected on behalf of, and shared with, your clinic to schedule and manage appointments, deliver messages and questions to clinic staff, send appointment confirmations by text message where applicable, maintain a record of the interaction for operational, quality-assurance, and dispute-resolution purposes, and support operation of the Service. Your healthcare provider is the HIPAA-covered entity for information exchanged through the AI Receptionist, and we act as its Business Associate where HIPAA applies.

Recording, transcription, and notice. AI Receptionist calls are not retained as audio recordings. Audio is processed to create a transcript. Our default AI Receptionist greeting identifies the assistant as automated or AI-powered and provides notice that the call will be transcribed. A provider may modify its greeting and is responsible for providing any notice and obtaining any consent required by applicable law.

Retention. AI Receptionist transcripts and related communication logs are generally retained for 24 months and then deleted or de-identified, subject to legal holds, disputes, security investigations, applicable law, and other legitimate legal or operational requirements.

Medical record. HealthCom does not automatically incorporate an AI Receptionist transcript or communication log into your clinical medical record. Your provider determines what information, if any, must be documented or retained as part of your medical or other legally required record.

Your choices. You may ask to speak with a person or leave a message for clinic staff. If you receive text confirmations, you may opt out at any time by replying “STOP,” as described in the Text Messaging section above. Your use of the AI Receptionist is voluntary; you may contact your clinic by other available means. For questions about your health information or to exercise rights concerning provider-controlled patient records, contact your clinic directly.
 

12. Deactivating Your Account 

If you wish to deactivate your account, you may make the request to us using the contact details below. We generally retain information about you only as long as reasonably necessary to provide you with the Service. However, even after you deactivate your account, we may retain archived copies of information about you for a period of time that is consistent with applicable law, or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Service, to assist with investigations, to enforce our Terms of Service, for analytics purposes, or to take any other actions consistent with applicable law.

13. Your Personal Information 

If you believe that we have information about you that should be changed or corrected, you may make the request to us using the contact details below, in which case we may need to verify your identity before granting access or otherwise changing or correcting your information. However, due to legal, contractual,  and technical restrictions, we may not be able to make the change or correction.

For example,
Requests involving protected health information or medical records controlled by your healthcare provider may need to be directed to the provider and may be subject to applicable medical-record retention, amendment, and other legal requirements.

• If we receive information about you from one of our customers and that information is subject to HIPAA, we are legally and contractually required to refer your request to the customer.
• In the event of legal action or dispute, we may be prohibited from altering any information.
• We maintain regular backups and archives of our data, and changing archived data may be impractical.
   

14. Cookies 

Most web and mobile device browsers are set to accept cookies automatically by default. However, you can change your browser settings to prevent the automatic acceptance of cookies, or to notify you each time a cookie is set.

You can also learn more about cookies by visiting http://www.allaboutcookies.org, which includes additional information on cookies and how to block cookies on different types of browsers and mobile devices. Blocking or deleting cookies used in the Service, however, may prevent you from being able to use or take full advantage of the Service.
 

15. Do Not Track 

Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking across websites. We currently do not respond to DNT signals. We may continue to collect information in the manner described in this Privacy Policy from web browsers that have enabled  DNT signals or similar mechanisms.

16. Security 

We work hard to maintain the security, reliability, accuracy, and completeness of our Service and the information we hold. In particular, we:

• Implement administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction.
• Encrypt the online transmission of personal information (including personal health information) you provide through the Service or use SSL connections (Secure Socket Layer)  technology.
• Review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to systems.
• Restrict access to personal information to employees, contractors and agents who need to know that information to process it for us, and who are subject to contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
• Require our third-party service providers to store and transmit personal information in compliance with this Policy, require them to agree to appropriate confidentiality and security measures, and undergo industry-recognized independent third-party data security audits.
• Provide our employees job-specific training on how to protect and respect your personal information, including protecting your health information as required by HIPAA.

For communications transmitted via standard SMS or MMS, encryption and other technical safeguards may not apply in the same way they do to communications within the secure HealthCom platform. While we and our providers use reasonable safeguards and approved vendors to transmit messages, you acknowledge that text messaging inherently carries privacy risks beyond our control.

Calls and text messages handled by the AI Receptionist are transmitted over standard telephone and wireless carrier networks, which may not be encrypted end-to-end. AI Receptionist transcripts, communication logs, and related information retained by HealthCom are stored and processed within secured systems using the safeguards described above.

If we discover a breach of unsecured PHI as defined by HIPAA, we will investigate, mitigate where practicable, and provide the notifications required by 45 C.F.R. Part 164, Subpart D, without unreasonable delay and no later than 60 days after discovery. Our subcontractors must notify us of incidents so we can meet these obligations.

Since much of the information we collect is provided by our Users, we cannot guarantee the authenticity or accuracy of any data that these Users provide.

Despite our efforts to protect your personal information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted.

We will retain your personal information as long as your account is active or as needed to provide you Service. At any time you can remove your personal information or instruct us to remove it, but you should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our servers. We will also retain your personal information as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

17. Links to Other Websites 

While using the Service, you may be directed through links to third-party websites or Services. For  example, you may be linked to:

• A site maintained by your chiropractic provider
• A third-party authentication site;

We are not responsible for the terms of service or privacy policies of those websites or Services. You are responsible for reading and understanding the third-party terms of service and policies before using their Service.

18. Children 

We protect and limit the collection of information from children under the age of 18 in accordance with applicable laws. Our Service, including our Website, is not targeted or directed at children under 18 for independent use without appropriate authorization. Information about a minor may be provided by, or communications may be directed to the minor when authorized by, a parent, guardian, legal representative, healthcare provider, or other person with legal authority, or as otherwise permitted by applicable law. A parent or guardian may authorize a minor to receive forms or other communications directly. Access to particular health information remains subject to the provider’s determination and applicable law.

If a caller identifies as a parent or legal guardian scheduling care for a minor, the AI Receptionist collects information necessary to schedule the appointment or take a message, and such information is handled as described in this Policy and as permitted by law.

Text Messaging to Minors

If a patient is under 18, we send text messages related to care only with the authorization of a parent or legal guardian or as otherwise permitted by law. Content and timing of such messages are limited to treatment-related communications, and marketing texts to minors require the applicable prior express written consent.

19. U.S. State Privacy Rights

We provide the disclosures and rights required by current U.S. state privacy laws (including the California Consumer Privacy Act (CCPA/CPRA), Colorado Privacy Act, Connecticut DPA, Utah CPA, and Virginia CDPA). We describe the categories of personal information collected, the purposes of use, and the categories of disclosures. We do not sell or share personal information for cross-context behavioral advertising. Residents of these states may request to access, correct, delete, opt out of sale/share/targeted advertising, or limit use of sensitive personal information by contacting support@chiroup.com. We honor Global Privacy Control signals where required and will not discriminate against anyone for exercising these rights.

20. Location of Data 

We and our technical infrastructure are located in the United States. The personal information that you provide to us is stored on servers located in the United States. If you are located in another jurisdiction, you should be aware that in order to provide the Service to you, we must transfer your personal information to the United States where it will be stored and processed in accordance with this Privacy Policy.

We may transfer your information outside the United States to service providers with operations in other countries. By using the Service, you consent to such collection, storage and processing in the United States and elsewhere, though the United States and other jurisdictions may not afford the same level of data protection as considered adequate in your own country. We will take reasonable steps to protect your personal information. Note that your personal information may be available to the United States government or its agencies under legal process made in the United States.

21. Additional Information for Visitors from the European Economic Area (“EEA”)

When you use the Service, we collect, store, use and otherwise process your personal information as described in this Privacy Policy. We rely on a number of legal bases to process your information, including where: (i) necessary for our legitimate interests in providing and improving the Service including  offering you content and advertising that may be of interest to you; (ii) necessary for our legitimate interest in keeping the Service, Sites and Apps secure; (iii) necessary for the legitimate interests of our service providers and partners; (iv) necessary to perform our contractual obligations in our Terms of Use; (v) you have consented to the processing, which you can revoke at any time (however a revocation does not affect the lawfulness of processing of your personal data that occurred prior to the date of revocation);  (vi) you have expressly made the information public, e.g., in a Company message board or other public forums; (vii) necessary to comply with a legal obligation such as a law, regulation, search warrant,  subpoena or court order or to exercise or defend legal claims; and (viii) necessary to protect your vital interests or those of others.

If you are a user of our Service in the EEA, you can: (i) access personal information we have about you (we will try to provide information within 30 days of your request); (ii) have your personal information corrected or deleted (in most cases you can correct personal information you have submitted to us by going back to the specific Service, logging-in and making the desired change); (iii) in certain circumstances, you can object to our processing of your personal information, and we will discontinue such processing unless we have compelling legitimate grounds to continue; (iv) withdraw consent previously provided (however a withdrawal does not affect the legality of our processing your personal data that occurred prior to the date of withdrawal); or (v) if you believe that we have not complied with applicable data protection laws, you may lodge a complaint with your local supervisory authority. If you wish to inquire as to whether we maintain any of your personal information and if so, whether you wish to exercise any of those rights that are available to you with respect to such personal information, you may contact us. Any request you make must be in writing and include your name and address and any other information that may identify you. Where we do not carry out your request, we will tell you without delay and in any event within one month of receipt of the request, and we will explain our reasons for not taking the action requested.

Please send your written requests to our Data Protection Officer at support@chiroup.com or contact us at the following address:

ChiroUp, Inc. (d/b/a HealthCom)
4460 North Illinois St, Suite 8
Swansea, IL 62226
Attention: Data Protection Officer

Where we process your personal information for direct marketing purposes, you can opt-out through the unsubscribe link in the email communications we send to you, by changing your subscription preferences in your account settings or as otherwise specified in this Privacy Policy.

We will retain your personal information for as long as necessary to provide the Service to you and fulfill the purposes described in this Privacy Policy. This is also the case for third parties within whom we share your information to perform Service on our behalf. When we no longer need to use your personal information, and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or anonymize it. If you have registered with us and you no longer want us to use your registration information to provide the Service to you, you may close your account.

Some of the countries where we provide Service may not have the equivalent level of data protection laws as those in your location. If we need to transfer personal data outside the EEA, we will take steps to make sure your personal information is protected and safeguarded once it leaves the EEA. In particular, we require third parties to whom we transfer your data to agree to abide by the Standard Contractual Clauses (SCCs) approved by the European Commission and permitted under Article 46 of the European Union General Data Protection Regulation ("GDPR"). If you would like to obtain the details of such safeguards, you can request them from the Data Protection Officer at support@chiroup.com (mailto\:support@chiroup.com). In some limited circumstances, we may also transfer your information outside the EEA if the GDPR (under Article 49) allows this. This includes where it is necessary for the performance of a contract between us and you and where the transfer is necessary in connection with legal proceedings.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us as indicated below.
 

Contact Us 

If you have any questions regarding this Privacy Policy, please contact our Data Protection Officer at support@chiroup.com or contact us at the following address:
ChiroUp, Inc. (d/b/a HealthCom)
4460 North Illinois St, Suite 8
Swansea, IL 62226
Attention: Data Protection Officer