Wellfit’s Privacy Policy

1. General. Wellfit Technologies, Inc. (the “Company”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the personal information we collect from Users of our online portal, online bill pay, and/or mobile application (each, an “Application” and the services available therein the “Services”). The Services enable patients (each, a “Member”) and other users of the Services (collectively, “Users”) to pay for dental services in accordance with the treatment summary determined by their provider of dental services (each, a “Dental Provider”) and approved by the User. If applicable, the Member’s share of payment will be determined in accordance with the terms of their dental discount plan or a dental benefit plan offered by their employer (each, a “Plan”). Through the Services, the Dental Providers whose dental practices (“Sub-Merchants”) have been approved by a Plan, if applicable, and the Company, may submit treatment summaries and costs to Members. Members may pay the Sub-Merchants for their Dental Provider’s services through approved payment sources linked to the Member’s Account. Please note that this Privacy Policy does not apply to any protected health information (“PHI”) (as defined by the Health Insurance Protectability and Accountability Act of 1996, as amended) that may be disclosed by Dental Providers or Sub-Merchants to the Company, which will be governed by a separate Business Associate Agreement between the Company and the Dental Provider or Sub-Merchant. Terms not defined herein shall have the meanings set forth in the General Terms.

2. Questions; Contacting the Company; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or phone number:

Wellfit Technologies, Inc.

433 E. Las Colinas Blvd., Suite 900,
Irving TX 75039

With a copy to:

Wellfit Legal Department
Address: 433 E. Las Colinas Blvd., Suite 900, Irving TX 75039
Email: support@wellfit.com
(855) 493-5534 (Business Hours: 7:00 am to 6:00 pm CST)

3. A Note About Children. We do not intentionally gather personal information from visitors who are under the age of 13. If a child under 13 submits personal information to the Company and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 13, please contact us at: support@wellfit.com.

4. Types of Data We Collect. We collect personal information from Users, as described below.

(a) Information You Provide to Us.

(i) We collect and store the information you give to us when using our Services. We may collect personal information from you and your dependents, including those dependents under age eighteen (18), such as first and last name, e-mail, home address, zip code, phone number, date of birth, username and password when you create an account to log in to our Services (“Account”), as well as your payment information when you use our online bill pay, such as credit card type, credit card number, credit card expiration date and billing zip code (your “Bill Pay Information”). If you purchase a Plan membership or pay for dental services through our Services, we collect and store information about the transaction for your future transactions. This can include your payment information (including credit card, HSA, FSA or ACH information), purchase activity and contact details.

(ii) If you are a Member, the information you upload about yourself, including your name, age, and gender, as well as the type of payment method(s) you have associated with your Account will be saved to your profile (“Profile”).

(iii) To the extent necessary to provide the Services, a User’s payment method or information may be disclosed to a trusted partner, such as Vantiv, LLC, or Fifth Third Bank, or a successor thereof, or Visa, MasterCard, Discover or any other card organization or third party vendor (all of the foregoing, the “Third Party Vendors”).

In addition, we will collect each Member’s treatment code(s) associated with any procedure you inquire about or obtain from any Dental Provider via the Services. As a Member, you acknowledge and agree that you and your dependents will share certain PHI with the Company during the course of the Services. Your PHI may be used by a Dental Provider to create a Treatment Summary, by Company for the approval of the Treatment Summary via SMS to the phone number listed in your Account, and via e-mail notifications to the e-mail address listed in your Account. To the extent necessary to deal with a dispute, chargeback, compliance case or other issue with a Third Party Vendor, Company may be required to share a User’s PHI with such Third Party Vendor. In such event, only the minimum amount of PHI will be shared in order to resolve the dispute, chargeback, compliance case or other issue.

(iv) If you are a Dental Provider, we will collect the pricing information you make available via the Services regarding the costs of certain dental procedures (“Pricing Information”).

(v) If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

(vi) If you sign up for our newsletter we will collect your email address.

(vii) When you participate in any survey on our Services, we will collect your answers and add it to your profile.

(viii) If you participate in a sweepstakes, contest or other promotion on our Services, we may ask you for your e-mail address and/or home number (to notify you if you win or not). We may also ask for first and last name, and sometimes postal address to verify your identity. In some situations we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules for each sweepstakes and contest that you enter.

(ix) We also collect personal information at other points in our Services that state that personal information is being collected.

(b) Information Collected via Technology.

(i) Log Files. As is true of most websites and mobile applications, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Services, track Users’ movements around the Applications, gather demographic information about our User base as a whole, and better tailor our Services to our Users’ needs. Except as noted in this Privacy Policy, we do not link this automatically-collected data to personal information.

(ii) Mobile Services. We may also collect non-personal information from your mobile device if you have downloaded any of our Applications. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the Applications, and information about the type of device you use. In addition, in the event our Applications crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Applications.

(iii) Cookies. Like many online services, we may use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services. This type of information is collected to make the Services more useful to you and to tailor the experience with us to meet your special interests and needs.

(iv) Pixel Tags. In addition, we may use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies that are used to track online movements of Web users. In contrast to Cookies, which are stored on a User’s computer hard drive, Pixel Tags are embedded invisibly in Web pages and emails. Pixel Tags also allow us to send e-mail messages in a format Users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our Users. We may use this information to reduce or eliminate messages sent to a user.

(v) Traffic Analytics. We may use a number of third party service providers, such as Google Analytics, to help analyze how Users use the Services and Members utilize their benefits (“Analytics Companies”). These Analytics Companies uses Cookies to collect information such as how often users visit the Services, and what features they use on our Applications. We use the information we get from these Analytics Companies to improve our Applications and Services. These Analytics Companies collect the IP address assigned to you on the date you visit the Services, rather than your name or other personally identifying information. We do not combine the information generated through the use of our Analytics Companies with your personal information. Although these Analytics Companies may place a persistent Cookie on your web browser or mobile device to identify you as a unique User the next time you visit the Services, the Cookie cannot be used by anyone but the Analytics Company that placed the applicable Cookie. This Policy does not apply to and we are not responsible for the Cookies used by these Analytics Companies.

(c) Information Provided by Your Employer.
We will gather information from your Employer or Plan for purposes including determining Member eligibility, benefits plan determinations and dependent status. Such information may include personal information such as your first name, last name, date of birth, social security number, salary, place and location of employment, gender, contact information (phone number, physical address, e-mail address), PHI, Employer specific dates (hire, re-hire, termination) and occupation.

5. Use of Your Personal information

(a) General Use. In general, personal information you submit to us or provided by your Employer is used either to respond to requests that you make, or to aid us in serving you better. We will never sell your information. We may use your personal information to:
· facilitate the creation of and secure your Account on our network;
· identify you as a User in our system;
· provide improved administration of our Services;
· provide the Services you request;
· keep an internal record for our reporting and analysis purposes;
· run utilization and actuarial data analytics;
· protect the Employer, Plan, Dental Provider, Sub-Merchant and ourselves and other security purposes;
· contact you for market research purposes;
· target ads to you based on your online activity;
· improve the quality of experience when you interact with our Applications and Services, and other marketing purposes;
· send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
· send you e-mail notifications regarding Account activities, including approval of a treatment summary, payment status, and specialist referrals;
· send you SMS text notifications or phone calls regarding treatment or other Account activity;
· send you administrative e-mail notifications, such as security or support and maintenance advisories;
· send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of the Company; and
· respond to your inquiries related to employment opportunities or other requests.

(b) Creation of Anonymous Data. We may create anonymous data records from personal information by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze request, usage and treatment utilization patterns so that we may enhance the content of our Services and improve Application navigation. We reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties in our sole discretion.

6. Disclosure of Your Personal information. We disclose your personal information as described below and as described elsewhere in this Privacy Policy.

(a) Profile Information. If you are a Member, the information in your Profile will be accessible by your Employer or Plan as well as any Dental Provider with whom your Employer has approved to take part in your dental plan. In addition, the treatment code (the numerical number) associated with any dental treatment you inquire about or obtain from any Dental Provider will be accessible to such Dental Provider, your Employer and/or your Plan.

(b) Pricing Information. As an essential element of the Services, Pricing Information is by design available to the applicable Employer, Plan and Member associated with any Dental Provider’s Account.

(c) Third Party Service Providers. We may share certain aspects of your personal information with third party service providers to: provide you with the Services that we offer you; fulfill your order or subscription for any products, services or other goods; conduct quality assurance testing; facilitate creation of accounts; provide technical support; and/or to provide other services to the Company.

(d) Affiliates. We may share some or all of your personal information with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. Data obtained through the short code program will not be shared with any third-party for their marketing reasons/purposes.

(e) Corporate Restructuring. We may share some or all of your personal information in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or any portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business, or any of our assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Privacy Policy.

(f) Other Disclosures. Regardless of any choices you make regarding your personal information (as described below), the Company may disclose personal information if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on the Company; (c) to protect or defend the rights or property of the Company or Users of the Applications or Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

7. Your Choices Regarding Your Information. You have several choices regarding use of information on our Services:

(a) Email Communications. We may periodically send you free newsletters and e-mails that directly promote the use of our Services. If and when you receive promotional communications from us, you may indicate a preference to stop receiving further promotional communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our General Terms or Privacy Policy.

(b) SMS or Phone Call Communications. We may use the phone number in your Account to send you SMS text communications or phone calls. Such communications may involve treatment authorization, dispute or case grievances and resolution processes, or other administrative or transactional uses. You may indicate a preference to stop receiving such communications through your User settings in your Account. You acknowledge that refusal to communicate via SMS or phone may impact your use of the Services, but is not a requirement for the use of the Services. Despite any opt-out, we may call you in the event of any disputes or any compliance or chargeback issues with any Payment Parties, or as needed for administrative purposes.

(c) Changing or Deleting Your Personal Information. You may change any of your personal information in your Account by editing your settings within your Account or by sending an email to us at the address listed above. You may request deletion of your personal information by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives or backups. We may also retain your information for fraud prevention or similar purposes.

(d) Applications. You can stop all collection of information by an Application that is a mobile application by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

(e) Do Not Track Signals. Some web browsers may transmit “do not track” signals to the websites and other online services with which your web browser communicates. There is no standard that governs what, if anything, websites should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard is established, we may revise our policy on responding to these signals.

8. Security. We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place physical, electronic and managerial procedures to safeguard and secure the information we collect online.

9. Changes to This Privacy Policy. This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your personal information, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes within our Applications. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes within the Applications. These changes will be effective immediately for new Users of our Services. Please note that at all times you are responsible for updating your personal information to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you have an Account and you do not wish to permit changes in our use of your personal information, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us. Continued use of our Applications or Services, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

433 E. Las Colinas Blvd., Suite 900, Irving TX 75039

855-4-WELLFIT (855-493-5534) | support@wellfit.com

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