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Legal | Privacy Policy Privacy Policy Close Privacy Policy IMG Online Privacy Statement Effective Date: April 15, 2020 This statement (the “Privacy Policy”) applies to IMG websites, services, products and applications that collect data and display these terms, owned and operated by International Medical Group®, Inc. and its subsidiaries and affiliates, including, but not limited to, a la carte Healthcare, Ltd., Global Response Ltd., IMG Europe, Ltd., iTravel Insured, Inc. and AkesoCare Management, Inc. (collectively “IMG”, “IMG®”, “we”, “us”, or “our”). It does not apply to other IMG products and services that are not affected by the IMG Privacy Statement. At IMG, we are committed to earning your trust by respecting and protecting the privacy of the information you provide to us online. The following describes how IMG collects, uses, shares and secures the personal information you provide, as well as the human resources data of our employees. It also describes your choices regarding use, access and correction of your personal information. EU-U.S. & Swiss-U.S. Privacy Shield The EU-U.S. and Swiss-U.S. Privacy Shield Frameworks were designed by the U.S. Department of Commerce, and the European Commission and Swiss Administration, respectively, to provide companies on both sides of the Atlantic with a mechanism to comply with data protection requirements when transferring personal data from the European Union, the United Kingdom and Switzerland to the United States in support of transatlantic commerce. International Medical Group, Inc. and its subsidiaries and affiliates, such as iTravel Insured, and Akeso Care Management, Inc. and International Medical Administrators, Inc., participate in and have certified their compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, the United Kingdom and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov IMG is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. IMG complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, IMG is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you have an unresolved privacy or data use concerns that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request . Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint , you may be entitled to invoke binding arbitration regarding your privacy concerns when other dispute resolution procedures have been exhausted. IMG has further committed to cooperate with the EU data protection authorities (DPAs) for EU employees, and the Swiss Federal Data Protection and Information Commissioner for Swiss employees, with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU or Switzerland, respectively, in the context of the employment relationship. General Data Protection Regulation (“GDPR”) IMG collects and uses your information as follows and for the following reasons. Unless stated otherwise, where and when GDPR applies to the following information, IMG is the data controller. If you are a citizen or resident of the European Union and you are visiting a website affiliated with an IMG entity, or you are an insured person through IMG, or an IMG entity administers a health plan that covers you, IMG may send your personal data to the United States for use and processing as necessary to serve you or to provide you with the best products, services and experiences possible. If this occurs, your personal information will be transferred subject to the EU-U.S. & Swiss-U.S. Privacy Shield Framework. Lawfulness of Processing If you are a citizen or resident of the European Union, for personal information we gather directly from you and for information we receive about you from third parties, if you are an insured, you have been asked, and do hereby, consent to process your personal information pursuant to Article 6(1)(a) of the GDPR. You may withdraw your consent at any time. If you are visiting our website and are not (or not yet) a customer or an insured, you have affirmatively agreed to allow us to process your information by accepting our cookie notice, which shall also qualify as consent under Article 6(1)(a). For insureds, customers and website visitors, we will: (i) process the personal information we collect from you or that we receive from third parties about you as necessary to further IMG’s legitimate interests, which shall not override any of your fundamental rights and freedoms; (ii) for all other purposes set forth below. We will only process such information in order to send you future marketing materials about products or services in which you may have interest subject only to your express consent. If you do not provide such express consent to receive marketing communications, IMG will not process your information for this purpose. If you do provide such consent, you may withdraw it at any time. Time periods for storing personal information: If you are a person insured through IMG, a subsidiary, or one of its clients; or an IMG entity administers an insurance plan that covers you, IMG shall retain your personal information subject to its retention schedules, which are determined by the nature of the personal information, how IMG will use the information will be used to serve you, any regulatory controls and any applicable legal or tax considerations. We will retain the information collected about your interactions with our websites for up to one year, or until you request deletion or opt out. If you are a European citizen or resident that has visited an IMG website, and for whom IMG has gathered personal information as described below, you have a right to request access to and rectification or erasure of personal data or restriction of processing concerning the data subject and to object to processing as well as the right to data portability. You can exercise this right by contacting our Data Protection Officer. You also have a right to lodge a complaint with the applicable EU supervisory authority. Collecting Your Information IMG collects many kinds of information in order to operate effectively and provide you the best products, services and expe...