Welvie's Commitment To Protecting Your Privacy

The nation's leading decision-support company

Welvie is committed to protecting the privacy of our product users. To that end, we have established this Privacy Policy to describe how we may collect, use, or disclose information we obtain while you are using our product.

When you use Welvie, you agree to and accept the terms and practices described in this Privacy Policy with respect to any information we obtain in the course of your using the Welvie product, including your Personal or Health information, as defined below.

This Privacy Policy describes:

• What kinds of Personal Information or Health Information we may collect from you
• How and why we collect information, including a description of "cookies"
• How we may use, aggregate or disclose different types of information we obtain from your use of Welvie
• How we protect the privacy of your Personal and Health Information
• What your privacy choices are as a Welvie participant

Definitions

Reference to "Welvie" means "Welvie, LLC", including any company that Welvie controls. Welvie may share information among its subsidiaries that it owns or controls, but such information will remain protected under the terms of this Privacy Policy.

Reference to "you" means you, the assigned user, or someone authorized by you to act on your behalf.

Reference to "Personal Information" may include your name, e-mail address, city and state of residence, health plan or insurance carrier, plan subscriber or membership number, age, and certain other demographic information.

Reference to "Health Information" means self reported information which describes your physical or health status, conditions which may be of concern to you, and treatments or procedures in which you are interested.

Reference to "Protected Health Information" means your individually identifiable health information protected by the HIPAA Privacy Rule as defined by the U.S. Department of Health and Human Services (45 CFR 160.103).

Registration and Access

You may gain access to Welvie through various modes of access (e.g. your Health Plan’s Web site or directly through our URL) after an initial registration process through our Web site. We require certain information as part of the user registration, such as your name, e-mail address and date of birth. At the time you register, you are assigned an individual account for your exclusive use and access. Only you, as the assigned user of a Welvie account, can grant someone else access to your account. Welvie is not responsible for information obtained by third parties to whom you have authorized access to your account.

Information we receive directly and indirectly from you during your use of the product, may be used by Welvie to determine the types of information, which may be clinically relevant information and personalized to your Welvie experience.

Welvie's Product is Intended for Adults

Welvie's Product is intended for adult use only. A parent or guardian may use Welvie for a minor. The parent or guardian is solely responsible for providing supervision of the minor's use of Welvie. The parent or guardian assumes full responsibility for ensuring that your login information is kept secure and that the information submitted is accurate. The parent or guardian also assumes full responsibility for the interpretation and use of any information or suggestions provided through Welvie for the minor.

"Cookies" and How They Are Used

In order to deliver personalized and clinically relevant information to Welvie participants, we ask you to provide us with certain information which may include your Personal or Health Information. Welvie also uses "cookies" to make your use of our product more streamlined and individually relevant. Your computer will receive a unique signature or "cookie" when you enter the Welvie platform. The information collected by cookies (i) helps Welvie dynamically generate content on our product pages, (ii) allows Welvie to statistically monitor how many people are using our product, and (iii) helps Welvie determine for what purposes these actions are being taken.

Welvie collects non-personal information about your use of the Welvie product through the use of cookies. For example, Welvie may use cookie information to facilitate your login, as navigation aides, as session timers or to determine the popularity of certain content. We do not track your activity outside of our platform.

You may set your browser to reject our cookies, but if you do so, you will limit the usefulness of the Welvie product.

How does Welvie use your Personal Information

Welvie may obtain Personal Information and Health Information when you log into Welvie, or navigate through our product. Welvie uses that information to provide you our product and services including but not limited to personalized and clinically relevant information that may be of interest to you. Welvie may disclose your Personal Information to its vendors and/or third parties whom Welvie has contracted with to perform services including but not limited to the distribution of rewards/incentives and surveys.

In addition, at the request of your Health Plan, Welvie may disclose whether you are participating or enrolled in certain offers or programs made available by your Health Plan or Plan Sponsor through the Welvie product.

Welvie also may combine, in a non-identifiable format, the Personal and Health Information you provide with health information from other users to create "aggregate data". This aggregate data may be disclosed to your Plan Sponsor or Health Plan, its vendors and other third parties associated with your Plan Sponsor or Health Plan. Aggregate data does not contain any information that could be used to contact or identify you. Upon authorization or request of your Plan Sponsor or Health Plan, Welvie may send your Personal Health Information, or Protected Health Information subject to a Business Associate Agreement, to Plan Sponsor, Health Plan or their approved affiliates for analysis of health trends and effectiveness of health programs.

HIPAA Privacy

To the extent Welvie gathers "Protected Health Information" as defined in the HIPAA Privacy Rule, we will abide by the terms and conditions for use and disclosure of such information as established by HIPAA, the Health Information Technology for Economic and Clinical Health Act (the HITECH Act) as part of the American Recovery and Reinvestment Act of 2009, the Notice of Privacy Practices established by your Health Plan, and any applicable Business Associate Agreement.

Contacting You by E Mail and How You Can Opt-Out

Welvie has the ability to use the Personal or Health Information that you provide to send you personalized e-mail or electronic messages based upon your use and interest patterns. Your acceptance of this Privacy Policy grants Welvie permission to send you these e-mails. If you decide, after receiving an e-mail or electronic messaging that you would prefer not to receive them, then you may "Opt-Out" by following the instructions on the e-mail or other electronic communication you receive from Welvie.

Other Access to Your Information

Welvie operations and maintenance contractors sometimes have limited access to Personal and Health Information of users in the course of providing products or services to Welvie. These contractors include vendors and suppliers that provide Welvie with technology, services, and/or content related to better operation and maintenance of the Welvie product. Access to your Personal and Health Information by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for Welvie. We also contractually require that our operations and maintenance contractors: 1) protect the privacy of your Personal and Health Information consistent with this Privacy Policy, and, 2) not use or disclose your Personal and Health Information for any purpose other than providing us with products and services or as required by law.

In certain limited circumstances release of your Personal Information or Health Information may be legally compelled in response to (i) a court order, search warrant, subpoena or other legal action, (ii) in special cases, such as to protect the health and safety of you or others; or (iii) in connection with a corporate transaction or proceeding resulting in a transfer of the assets or line of business relating to such data.

Third Party Web Sites

Certain content and services offered to you through Welvie or linked to through the Welvie URL are hosted and operated by a company other than Welvie. Welvie does not disclose your Personal or Health Information to these Third Party Web sites without your consent, but you should be aware that any information you disclose once you access these other Web sites is not subject to this Privacy Policy. Welvie does not endorse and is not responsible for the privacy practices of the Third Party Web sites. You should review the privacy policy posted on each Web site to understand how that Third Party Web site collects and uses your Personal Information and your Personal Health Information. Welvie makes an effort to make it obvious to you when you leave our product and enter a Third Party Web site, either by requiring you to click on a link or by notifying you that you are leaving our product.

Reviewing and Amending Your Personal Information

Welvie allows you to correct, update or review Personal Information you previously submitted for use with the Welvie product. To do this, simply access your Account Settings page and easy-to-use functions will show you how to correct, update or review your information.

Terminating Access through Your Welvie Account

We will remove your Personal and Health Information from our active databases and other readily searchable media at your written request. Removal from our active database will also terminate your access to Welvie and the display of your Personal Health Information through your account.

In order to remove your personal data and terminate your active account, you are required to send a signed statement, including your name, address, e-mail address and birth date, to the address below authorizing Welvie to close your active account. Upon receiving your request, your Personal Health Information will no longer be displayed to you. We will notify you by e-mail after your request has been processed.

Limitations on Removing or Amending Information

After your account has been terminated, your Personal or Health Information will not be accessible to you or someone using your account via the Internet, however, you should be aware that this information may be retained in back-up media. Welvie will not use or disclose any Personal or Health Information that may be stored on backup media, except as described in this Privacy Policy or required by law.

Your ability to correct, update or remove previously provided Personal Information or Health Information only covers information within the reasonable control of Welvie.

Information Security

Though an effort is made to secure online and electronically maintained Personal and Health Information, there is always some risk that an unauthorized third party may find a way to thwart or compromise our security systems or intercept information transmitted over the Internet. Welvie employs up to date electronic security procedures, such as firewalls and passwords, to protect data held in our servers from unauthorized access. Physical security is provided by maintaining our servers in facilities that are protected from unauthorized access by pass code, key card, or key lock entry.

Changes to the Welvie Privacy Policy

Welvie reserves the right to change, modify, add, or remove portions of this Privacy Policy, or any of its supplemental policies, at any time. Welvie will post a revised Privacy Policy on our Web site to describe any material changes. Continued use of the Welvie product by you will indicate acceptance of such changes. You may of course choose to simply discontinue using the Welvie product at any time. PLEASE NOTE THAT CHANGES TO THE PLAN'S NOTICE OF PRIVACY PRACTICES AND USE AND DISCLOSURE OF YOUR PROTECTED HEALTH INFORMATION BY PLAN SPONSOR OR YOUR HEALTH PLAN PURSUANT TO ITS NOTICE OF PRIVACY PRACTICES ARE NOT COMMUNICATED TO YOU THROUGH THIS PORTAL OR PRIVACY POLICY.

Please exit Welvie immediately if you do not agree to the terms of this Privacy Policy or any revised policy.

Questions or Correspondence Concerning this Privacy Policy May Be Addressed to:

Chief Operating Officer
Welvie
1277 Treat Blvd, Ste 800
Walnut Creek, CA 94597

Last Updated: January 28, 2023.

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