PRIVACY
POLICY

Last Modified: May 9, 2023

Welcome to the Two Sisters Acquisitions, LLC, in partnership with Deborah Abeles, M.D., PLLC dba Abeles Wellness Experience (“PLLC” or “We” or “Us”) we are committed to protecting your privacy and we take great care with your personal information that we gather when you access or use website (“PLLC Site” or “Site”) and related websites, applications, and services owned and operated by PLLC and that link to this Privacy Policy (collectively, the “Services”). This Privacy Policy is meant to help those that use our Services (“Users”, “you,” or “your”) understand how we treat your personal information.

BY USING OR ACCESSING THE SERVICES IN ANY MANNER, YOU ACKNOWLEDGE THAT YOU ACCEPT THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY, AND YOU HEREBY CONSENT THAT WE WILL COLLECT, USE, AND SHARE YOUR INFORMATION IN THE FOLLOWING WAYS. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU MAY NOT USE THE SERVICES. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF.

Any use of PLLC’s Services is at all times subject to the Agreement (as the term “Agreement” is defined in our website Terms of Use and portal Terms of use, which incorporates this Privacy Policy).

We take your privacy seriously, and we want you to know how we collect, use, share, and protect your information. In addition to this privacy policy (“Privacy Policy”), users of the PLLC Site should consult the PLLC Site Terms of Service as well as any product-specific terms and conditions that apply.

Information Collected & Sources

We may collect the following information from you:

Contact and registration information (such as name, email address, postal address, phone number, professional licenses, education history, specialties and certifications and birthday, if you provide it to us)
Payment information (such as the credit or debit card numbers and expiration dates),
Protected classification (your gender, gender identity, age, date of birth, race, sexual orientation, if you provide it to us)
Health Information (health conditions, healthcare providers visited, reasons for visit, dates of visit, medical history and health information you provide us, insurance carrier, insurance plan, member ID, group ID, payer ID, provider information, appointment procedure, if you provide it to us)
Internet activity (including but not limited to, (a) how you interact with our sites, referring webpage/source through which you access the Services, non-identifiable request IDs, statistics associated with the interaction between device or browser and the Services; (b) information about your interactions on social media that identifies us through hashtags or using our social media handles, and (c) technical data received from your device, such as IP address, username, IP address, and device ID of individuals that visit our site, referring websites, and similar technical data),
Geolocation data (your city and state it is apparent from the address you provide, the internet address from which you visit our sites, or the phone number used to call us),
De-identified data. We may generate and use de-identified data (or anonymized or aggregate information) which cannot reasonably be used to identify you. We will maintain and use this data only in a de-identified form and will not attempt to re-identify such data, except as permitted by applicable law. The aggregated or anonymized data is no longer personal information governed by this Privacy Policy, and
Commercial information. We may generate internal user identifiers (like a user or account ID) to keep track of and manage your transactions online or by phone and relationships with us and collect commercial information, requested, considered, exchanged, or returned, and other purchasing or consuming histories and tendencies. We may draw inferences about you from the other types of information we collect reflecting your interests, preferences, online behaviors, and characteristics.

All of the above have been collected and disclosed to our service providers for a business purpose during the last 12 months, such as:

provide the services you request
respond to your inquiries and provide user service
operate and improve online services
personalize online content and experiences
market and advertise
maintain safety in our stores and combat illegal activities
comply with legal obligations

We may collect your personal information from the following sources:

From you, when you provide it to us. We collect your information when you utilize our services online or over the phone, contact our user support, fill out forms on our website, create an account with us, sign up for mailing lists, participate in surveys, or otherwise provide us your information.
When you use our sites. We use tools that help us improve our business by analyzing how our users interact with us and our sites.
From our service providers and business partners. When you interact with our service providers and business partners, they may collect information from you and provide that information to us. We may then use that information according to this Privacy Policy.
When transmitted automatically by your browser or device. Internet-connected devices that visit our sites automatically transmit technical and device data, settings, software and hardware versions, referring websites, and unique device identifiers (depending on your settings).
Other third parties. Third-party data suppliers (such as data aggregators and data resellers) may supply us with internet and network activity information, demographic information, and other information that helps us recognize and learn more about you and other users of our online services.

Information that you provide to PLLC is not PHI or subject to HIPAA. To provide just a few examples, when information provided by you is not subject to HIPAA (i) create an account, (ii) complete general request forms (“General Request Forms”); (iii) post reviews; or (iv) provide device/IP Information or web analytics information by browsing our websites (see below).

Purposes for Collection and Use of Information

PLLC collects information in an effort to improve your experience and that allows us to communicate with you about our products and services. In the case of resubmitting your request, we require your personal information because without it, we cannot process your request. Providing us other information may be voluntary, and you can instruct us not to use your information for marketing purposes by following instructions in this Privacy Policy.

We may use your personal information in the following ways:

To create and manage your account or other user profiles.
To process, confirm, and fulfill the reason you provided the information to us. We may contact you via email, mail or phone if we have questions about your request or if applicable for payment.
To remarket our products through advertising networks.
If you joined our email marketing list, to communicate with you by email about our products and services.
To administer and fulfill the reason you provided the information to us.
To inform others of user satisfaction with the quality of our products and services.
To help us learn more about your general preferences, personalize online content and experience.
To show you advertisements, including interest-based or online behavioral advertising.
To help us improve and address problems with our site design, products and services.
To enhance your experience.
To analyze trends and statistics.
To protect the security and integrity of our websites and our business.
To detect, protect against and investigate fraud, theft or threats to any individuals.
For system administration.
To contact you for reasonable business purposes, including for material changes to our privacy policy.
To meet our legal obligations, protect our legal rights, respond to court orders and other legal process, and as permitted by law, resolving disputes, enforcing any agreement with you, make disclosures to address unlawful or other act that may endanger the health, safety or privacy of other users or the general public.

If we use service providers outside the United States, then your personal information may be sent outside U.S. borders and may be subject to additional local laws regarding personal information.

Request to opt-out of certain uses of your personal information:

We may share personal information with other parties to provide analytics services and serve ads on our behalf targeted to your interests and based on your online activities. Information may be linked to your browser or device (like cookies and similar tracking technologies) and related to you if you have a user account or interact with us in other ways. These parties may use the information for their own marketing and to offer products and services on our online services.

Your personal information is not shared for money, but certain uses may be deemed the “sale” or “sharing” of personal information under applicable privacy laws.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). We and our service providers may use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Sites through your computer or mobile device. A cookie is a small file or piece of data sent from a website and stored on the hard drive of your computer or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access or use certain parts of our Sites. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or use our App.
Pixels and Web Beacons. Pages on our Sites, or our e-mails, may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related Sites statistics (for example, recording the popularity of certain Sites content and verifying system and server integrity). We use this information to assist us in improving our user experience.
Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Sites. Google Analytics uses cookies, which are text files placed on your computer, to help our Sites analyze how users use the Sites. You can find out more about how Google uses data when you visit our Sites by visiting “How Google uses information from sites or apps that use our services” (located at Google Policies. We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as Google Privacy.
Do Not Track Signals. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals. However, we do not track your online activities on or across third party websites or other online services for any purpose, including advertising.

Email communications

Our Sites provide you with the opportunity to receive communications from us or third parties.

Email communications that you send to us via the email links on our Site may be shared with a customer service representative, employee, medical expert, or agent that is most able to address your inquiry. We make every effort to respond in a timely fashion once communications are received. Once we have responded to your communication, it is discarded or archived, depending on the nature of the inquiry. Note, that email communications that you send us via the email links on our Site are not automatically encrypted, and it is possible that unencrypted email communications with us may be accessed or viewed by another internet user while in transit to us.

Data retention

We will retain your information for as long as needed to provide you services, comply with our legal obligations, resolve disputes, and enforce our agreements. You may request that we delete your data by contacting us as provided below. However, we may not be able to honor that request in all instances given the laws and regulations that apply to us. For example, under state and federal law, we may be required to maintain some data that is specific to you and that may identify you, such as your medical records or other information. We may also have a legal basis or obligation to maintain medical and other information about you to provide care and treatment or to comply with our professional, legal, and other obligations.

Disclosure of your information

Our third party service providers are our vendors that provide services to us directly or to you on our behalf and that receive your personal information provided by you in request to provide those services. We may share your information with third parties with your consent or at your request. For example, we run our online platform through a service provider that may receive your personal information to help us run our business. When applicable we use a third party payment provider to process your cardholder data when you utilize the services online or over the phone. We also use an e-mail list to conduct marketing for products and services, which may be shared with third party service providers that provide us email distribution, digital marketing, and other services. (For more information on marketing, see the section below titled “Marketing email communications”.) If you’ve signed up for mobile text messaging offers, with your consent, we may send push notifications or alerts to your mobile device. If decide later you no longer wish to receive these offers, simply follow the opt-out instructions included in the mobile message. If you interact with social media widgets, share content using social media share buttons or access features of our online services that contain content or features provided by social media platforms, the relevant social media platforms may collect or have access to personal information. (Please review the privacy policies of the social media platforms you interact with as we are not responsible for their privacy policies.). We also use a third-party service provider that use information provided by you to perform website analytics that help make intelligent product recommendations for you while you use our site based on the pages and products you view. We also engage advertising networks as service providers to provide online advertising and marketing services. Other purposes of using the information provided by you include but are not limited to: detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; perform operational services (such as hosting, billing, fulfillment, data storage, security, insurance verification, web service analytics) and/or make certain services, features or functionality available to you; perform services on our behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling request, verifying customer information, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

Some of our third party service providers also provide services directly to consumers. If you use any consumer-facing applications or services from businesses that collect personal information and also happen to be our service providers, this Privacy Policy will not apply to that information. We encourage you to read the privacy notices of every business to which you provide your personal information.

We reserve the right to transfer any of the information we have about you to proceed with the consideration, negotiation, or completion of a sale or transfer of all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition, or other disposition, or in connection with a bankruptcy reorganization, dissolution, or liquidation.

We may also disclose your information:

to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which information held by PLLC about our Sites users are among the assets transferred;
to fulfill the purpose for which you provide it;
for any other purpose disclosed by us when you provide the information;
with your consent;
to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
to affiliates to market their products or services to you if you have purchased one of our products and if you have not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information;
to enforce or apply our Terms of Service and other agreements, including for billing and collection purposes; and
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of PLLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices about how we use and disclose your information

We do not control the use of cookies provided by other third parties, nor do we manage the information collected by other third parties. These third parties may aggregate the information they collect with information from their other customers for their own purposes and in accordance with their own respective privacy policies.

In addition, we strive to provide you with choices regarding the Information you provide to us. We have created or you have available mechanisms to provide you with control over your Information:

Cookie Settings and Advertising. You can set your browser or operating system to refuse all or some cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Sites may then be inaccessible or not function properly.
Promotional Offers from PLLC. If you do not wish to have your email address used by us to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or submitting a request to our customer service team. This opt-out does not apply to information provided to PLLC as a result of a product purchase or your use of our services. If you wish to opt-out of such sharing, please email us at compliance@aw.clinic

Marketing email communications

Our website provides you the option to join our email list and receive information about our products, services and offers. If you do not wish to receive PLLC marketing emails, you may use any of several options to unsubscribe: click the “Unsubscribe” link in our marketing emails, call us at (516) 207-2801 during regular east coast business hours, or email us at compliance@aw.clinic with the following:

- The phrase “Unsubscribe” in the subject line
- Your name and email address

Please be aware that it can take several business days to remove you from our email marketing list.

NOTE: You will continue to receive request confirmation, or other transactional emails.

Links to Other Sites

Our website may contain links to sites other than our own. Those sites may have their own privacy policies. Neither we nor any of our service providers shall have any responsibility for those sites and we provide these links solely for the convenience of our visitors. We encourage you to review the privacy policies and terms of use of any third-party sites or services before providing any of them with any of your personal information.

Your rights regarding your information and accessing and correcting your information

You can Contact Us through the Contact Information below to access and/or find out what information we have about you and to correct that information. You may also notify us through the Contact Information below of any changes or errors in any Information we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We will make reasonable efforts to the extent practicable to delete your account, subject to applicable laws. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or if we have a legal basis or obligation to maintain it, or if it would cause the information to be incorrect.

If you are a patient of PLLC, you can access the patient-related information that we maintain about you through our third party patient portal or through our health information management department. For more information about requesting your medical records, ask us. You also can request a correction to your patient information through our third party patient portal and we will maintain your patient-related information as required by HIPAA and other federal and state laws.

Security

Whether you are visiting the PLLC Site or our clinic location, we use reasonable security measures to protect the confidentiality of personal information under our control, and we appropriately limit access to it. We use a variety of information security measures to protect your online transactions with us. The PLLC Site uses encryption technology, such as Secure Sockets Layer (SSL), to protect your personal information during data transport. SSL protects information you submit via our website, such as information including your name, address, and credit card number. That being said, PLLC cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. We have taken reasonable steps to ensure the integrity and confidentiality of personally identifiable information that you may provide. You should understand, however, that electronic transmissions via the internet are not necessarily secure from interception, and so we cannot absolutely guarantee the security or confidentiality of such transmissions.

Protecting Children’s Privacy

Our Sites are not intended for users under 18 years of age. No one under age 18 may provide any information to or through the Sites. We do not knowingly collect information from users under 18. If you are under 18, do not use or provide any information on or in our Sites or on or through any of their features, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received information from a user under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a user under 18, please contact us at the contact information below.

Our Patient Online Services is available to patients 18 years of age and older. It is also available to patients who are between the ages of 13 years old and 17 years old with the permission of their parents or legal guardians.

Links to other websites

Our Sites may link to other websites that have their own privacy policies. Be sure to review the privacy policy on the site you’re visiting.

Privacy policy updates

We may need to update our Privacy Policy as technology changes and PLLC evolves. If we make significant changes to this Privacy Policy, we’ll post a prominent message on our websites.

Contact information

If you have a question or concern regarding your privacy, please contact PLLC’s Privacy Officer using the contact information below:

Abeles Wellness Experience
(516) 207-1801
compliance@aw.clinic

California Privacy Disclosures and Rights Granted to California Residents

Your Rights Under California Law. If you are a resident of California, you have the following rights concerning your personal information over the past 12 months, including the following:

- Right to be informed about the (1) types of personal information we collect about you, (2) specific pieces of information that we have collected about you, (3) sources and purposes of the collection, and (4) third parties that receive your data.
- Right to request deletion of your data.
- Right to know to whom we’ve sold or disclosed your data.
- Right to opt out of the sale of your data.
- Right against discrimination if you do not provide us your data, unless the goods and services we provide you are related to the value of the data you provide us.

Exercising Your Rights

Opting Out of “Sales” Information

We may share your personal information by allowing certain third parties to collect your personal information via automated technologies on our Services for cross-context behavioral advertising purposes. This kind of sharing may be considered a “sale” under the CCPA/CPRA when the personal information is exchanged for non-monetary consideration. You have the right to opt out of these types of disclosures of your information.

Opting Out of Information Disclosures to Unaffiliated Third Parties

In addition to the rights mentioned above under California law, we provide you with a cost-free means to opt-out of our sharing your information with third parties with whom we do not share the same name, if that third party will use it for its own direct marketing purposes.

If you would like to exercise this right under California law, please click here to fill out our online form to indicate your sharing preferences.

If you have general questions about your rights, contact us via:

Call us (516) 207-1801 during regular east coast business hours

Email us at compliance@aw.clinic with your request

Verification Process. You may submit your California rights requests using any of the methods above. However, for certain requests, California law permits or requires us to take additional steps to verify the identity and authority of the individual making certain requests information. This is so we can protect your privacy and data. Depending on the request or the sensitivity of the request, PLLC may ask that you provide two, three or more pieces of personal information that matches information in our records, so that we may confirm your identity prior to processing your request.

Authorized Agent. If you wish to submit a request through an authorized agent, then you may designate your authorized agent in writing by contacting us using any of the methods above and providing the following information:

Your full name and date of birth
Current address and telephone number
Name of the authorized agent
State whether the requested information should be delivered to the agent or to you.
State the types of requests that you authorize your agent to make, for example, Request to Know, Request to Delete, or Request to Opt-Out of Sales of Personal Information
Sign and date the agent authorization

If any of the above information is missing or cannot be verified, then we may request the information before processing your request. We may request additional verification information depending on the nature or sensitivity of the request.

Third Party Marketing. Under California law, users of PLLC who are residents of California may request certain information about our disclosure of personal information during the prior calendar year to third parties for their direct marketing purposes. During the last 12 months, we may have used the personal information we collect for the following business or commercial purposes:

Performing services, including maintaining or servicing accounts, providing user service, processing or fulfilling requests and transactions, verifying user information, processing payments, providing financing services, providing analytics services, providing storage or providing similar services;
Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us;
Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes;
Debugging to identify and repair errors that impair existing intended functionality;
Undertaking internal research for technological development and demonstration;
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

To make specific request regarding disclosure of personal information, please write to us at the following address:

Deborah Abeles, M.D., PLLC.
Customer Relations
C/O Corporate Service Company
80 State Street
Albany, NY 12207-2543

Alternatively, you may send us an email at compliance@aw.clinic with the words “California Privacy Rights” in the subject line.