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POLICIES

AdvertisingCopyrightEditorialMedical ReviewPrivacyTerms


WEBMD HEALTH SERVICES PRIVACY POLICY

Your health plan Sponsor (which could be your employer in the case of a
self-funded plan, a group health plan, an insurer, or a third-party) contracts
with WebMD Health Services Group, Inc. for tools and services to help you manage
your health. We refer to this wellness website and the tools and services
provided by WebMD Health Services Group, Inc. collectively as the "WebMD
Services."

In this Privacy Policy, "we," "our," and "WebMD" refer to WebMD Health Services
Group, Inc. and any company that WebMD Health Services Group, Inc. owns or
controls. We do not operate, own, or control the website www.webmd.com. That
website is run by WebMD LLC, which is an affiliate of WebMD Health Services
Group, but is not owned or controlled by it. WebMD Health Services Group may
share information with companies that it owns or controls, and your information
will remain protected under the terms of this Privacy Policy.

This Privacy Policy explains how WebMD collects, receives, uses, stores, shares,
transfers, and processes your personal information as well as your rights in
determining what we do with the information that we collect or hold about you.
We know that keeping your personal information secure is very important to you.
Please read this Privacy Policy before you use the WebMD Services. Use of the
WebMD Services, as well as indicating your consent on this website's initial
registration page, signifies your acceptance of the terms of this Privacy
Policy. If you do not accept the terms of this Privacy Policy, do not use the
WebMD Services.

This Privacy Policy is not the same as your health plan's Health Insurance
Portability and Accountability Act of 1996 ("HIPAA") Notice of Privacy
Practices, which describes in detail how your health plan uses and discloses
your individually identifiable health information. To learn more, see "Your
Health Plan's Notice of Privacy Practices" below.

How to Contact Us

WebMD Health Services Group, Inc.
Attn: Privacy Office
9229 Delegates Row, Suite 400
Indianapolis, IN 46240

privacy@webmd.com


YOUR CHOICES

 * You decide whether to use the WebMD Services.

 * When you establish an account, you will be asked to consent to the
   information practices described in this Privacy Policy.

 * Before making any material changes to this Privacy Policy, we will ask for
   your consent.

 * You may access, correct, and delete your personal information directly
   through the WebMD Services.

 * We retain personal information in your WebMD account for as long as your
   WebMD account is open. Once we have been notified by your Sponsor that you
   are no longer eligible to use the WebMD Services, or if you otherwise write
   to us to have your account deleted, your account will be closed and the
   personal information in your WebMD account will be removed from WebMD's
   database and backup files in accordance with our data destruction policy and
   the terms of our agreement with your Sponsor.

 * You may close your account and delete your personal information at any time.


OUR COMMITMENT TO YOUR PRIVACY

WebMD respects and safeguards the privacy of everyone who uses the WebMD
Services. Here is a brief summary of our privacy practices:

 * We collect information directly from you when you register an account or use
   our tools or services.

 * We collect information about how you use our tools and services. We may use
   cookies or other tracking methods to do this. You can stop the collection of
   some information by turning off your browser's cookies, but this may keep
   some of our tools and services from working as they were designed to work.

 * We may collect location information when you use our apps, but only with your
   consent. You can stop this by not giving consent or by turning off location
   services on your device.

 * We collect information that your Sponsor gives us.

 * Our website does not contain advertisements and we do not share your personal
   information with any advertisers.

 * We use the information that we collect to manage your account, give you
   relevant health information, give your Sponsor statistics and aggregate
   reports, and improve our tools and services.

 * We will not use or share your personal information unless you allow us to,
   except as stated in this Privacy Policy or as directed by your Sponsor in
   accordance with your health plan's Notice of Privacy Practices.

 * We may share your information with service providers, third parties as
   directed by you or your Sponsor, in response to legal requests that we deem
   valid, in special circumstances, or in the event of a corporate restructure.

 * We use reasonable security measures to protect your personal information.


INFORMATION COVERED BY THIS PRIVACY POLICY

This Privacy Policy applies to information about you that WebMD collects and
stores in relation to your use of the WebMD Services. This information may
include:

 * personal information, which is any information relating to you that
   identifies you or, combined with other information, allows you to be
   identified; and

 * aggregate information, which is information about a group of individuals that
   does not identify any particular individual or allow any particular
   individual to be identified.

This Privacy Policy does not govern how other entities use your information.
This includes third-party websites that you may get to by clicking on links on
the WebMD Services. We recommend that you review the privacy policy of each
third-party website you visit.


PERSONAL INFORMATION WE COLLECT

We collect personal information about you from your Sponsor, from third-party
vendors working for your Sponsor, or directly from you when you use the WebMD
Services.

Personal information collected from, or provided to us by, your Sponsor includes
basic demographic information such as your name, email address, and your work
location.

Personal information collected directly from you includes:

 * information that you give us when you set up an account on the WebMD Services
   (this includes your name, email address, and date of birth) and your account
   information, including passwords and answers to security questions;

 * information about your health and behavior that you give us when you use
   WebMD Services, such as health trackers or a health assessment; and

 * other information that your Sponsor has requested, such as social security
   numbers and trade union membership.

You may choose not to give such information, but you would be limiting the
usefulness of the WebMD Services. Further, if you choose not to give certain
information, your Sponsor may make you ineligible for certain incentives. Ask
your Sponsor if you have questions about its incentive programs.

Your Sponsor may direct third-party vendors that provide services (such as
pharmacy benefits and biometric screening) on its behalf to send your personal
information to us.


OTHER INFORMATION COLLECTED WHEN YOU USE OUR SERVICES

Information collected indirectly from you includes information about your usage
of the WebMD Services, including information about how you navigate this
website, which health topics you inquire about, and which tools you use. To
collect this type of information we use cookies, web beacons, and other web
trackers. Cookies are small text files that are stored on your browser when you
visit a website that can be recognized during future visits to the website.
Similarly, a web beacon, pixel tag, or clear GIF is a small bit of code embedded
on a web page or in an email.

WebMD and its service providers use cookies and similar technologies to:

 * dynamically generate content on web pages or in newsletters;

 * statistically monitor how many people are using this website;

 * determine how many people open our emails;

 * determine the popularity of certain content; and

 * facilitate your login and serve as navigation aides and session timers.

We never use cookies or similar trackers for advertising. You can turn off
cookies in your browser settings, but doing so may negatively impact the
functionality of the WebMD Services. This website does not respond to web
browser do not track signals.

We do not track your use of the WebMD services for advertising.


MOBILE DEVICE APPLICATIONS

We offer some services through mobile apps. As with all of our other tools and
services, you must set up an account to use apps. We collect information when
you use an app. This can include the number of times that you use the app and
the information you submit via the app. We may also collect information about
the device on which you use the app. This includes the device's maker, type, and
software. To install one of our apps on your device, we'll give you a unique
code to access the app and to enable certain features. Our apps may ask you to
allow location functions (i.e., GPS). You don't have to give your location. If
you don't consent, some apps may not work as they were designed to work. You can
stop our apps from providing location information about you by changing the
location settings on your mobile device.

The information we collect when you use our apps is governed by this Privacy
Policy.


WHY WE COLLECT AND HOW WE USE YOUR INFORMATION

Personal information provided by your Sponsor is needed to:

 * authenticate you as a legitimate user of the WebMD Services;

 * establish log-in credentials to provide you with secure access to your
   information;

 * provide demographic data required by some WebMD Services; and

 * provide your Sponsors with reports of aggregate information (see the
   Disclosures to Your Sponsor section below).

Personal information collected directly from you is needed to:

 * establish and control access to your WebMD account;

 * allow you to track your health information and health-related behavior;

 * provide personalized content, advice, and recommendations that are relevant
   to you and your health needs; for example, we:
   
   * allow you to track your health and behaviors,
   
   * give you personalized health assessments,
   
   * send you health alerts or other health-related messages, and
   
   * send you messages about your account;

 * produce the report of statistics and aggregate information mentioned above;

 * respond to questions or comments that you send to us;

 * allow you to communicate with others in online health topic communities;

 * communicate with you as required by law, in connection with our services and
   as otherwise permitted by you or your Sponsor; and

 * find out how our services are being used to help us improve and know which
   tools users find most helpful.

Personal information collected indirectly from you is needed to assess and
improve how users of the WebMD Services navigate and utilize the website.


DISCLOSURES TO YOUR SPONSOR

We may disclose information about you to your Sponsor or to any third party: (a)
as instructed by your Sponsor, (b) as described in the Notice of Privacy
Practices that your Sponsor gave you, and (c) in accordance with applicable laws
and regulations.

We do provide your Sponsor with a number of reports on an aggregate and
anonymous basis. Your Sponsor uses these aggregate reports to better understand
and assess the health needs and concerns of its employee population, and to
consider development of programs to address these needs and concerns. For
example, your Sponsor might learn that there is significant interest in stopping
smoking amongst employees in a particular geographic region and then introduce
smoking cessation programs in those countries.

WebMD may tell your Sponsor if you have registered with WebMD, if you have taken
a health assessment, or if you've signed up for WebMD programs offered by your
Sponsor. We will do so to help your Sponsor manage incentives and analyze
registration rates. WebMD will not share your personal information (such as the
answers you give to the health assessment) in a manner that can be used to
identify you with your Sponsor.


DISCLOSURES TO OTHER THIRD PARTIES

WebMD may give your personal information to third-party vendors that provide us
services, including analytics, security, and marketing. Additionally, at the
direction of your Sponsor, WebMD may give your personal information to
third-party vendors that provide services for your Sponsor. For example, if your
Sponsor provides an incentive program that is managed by a vendor (e.g., for
completing a health assessment), then we may share your name, contact
information, and eligibility with the vendor so that you can get your incentive.
In any case, these third-party vendors are authorized only to process that
information as necessary and as directed by us or your Sponsor, respectively.

We may also give your personal information to other third parties under special
circumstances such as:

 * a court order, search warrant, subpoena, or other legal purpose that we deem
   to be valid;

 * to protect our rights, your rights, or the rights of others; and

 * a corporate transaction that results in a transfer of the assets or line of
   business that holds your information.

Should any of these events occur, WebMD will attempt to notify you through the
email address you provided us, unless doing so would violate a law or court
order.


HOW WE SAFEGUARD YOUR INFORMATION

We use reasonable technical, administrative, and physical safeguards to protect
your information from loss, misuse, and unauthorized access and changes. All
personal information you provide through the use of the WebMD Services is
secured in transmission using encryption and passwords. We also use
industry-standard encryption and hash algorithms in storing your personal
information within our databases and in back-up files. We use firewalls and
monitoring software to provide real-time protection for our servers, which are
locked down using standard physical measures. We store identical information on
servers at two separate locations to provide continuity of service.

We limit access to your information to help ensure that only you, our authorized
personnel, and other authorized third parties can access your information as
described in this Privacy Policy. All WebMD personnel are required to complete
privacy and security training on a regular and refresher basis and are subject
to disciplinary action for violating WebMD's information security policies.

No information system is 100% secure, and we can't guarantee that your
information will be protected against all security threats.


STORAGE OF YOUR INFORMATION

The personal information you provide when using the WebMD Services is stored and
maintained on servers owned by WebMD in data centers located in the United
States.


YOUR ACCESS AND CORRECTION RIGHTS

When you log in to this website, you can view, change, and delete personal
information that you have entered on this website.

Your Sponsor may choose to include information about your health (such as your
lab results, medications, or conditions) in your account. You can view this
information on the WebMD Services. You can stop this information from being
shown on your screen when you log on; but, you can't delete information that
your Sponsor gives us.

Also, your rights to view, correct, or change your personal information that are
set forth in your health plan's Notice of Privacy Practices may apply to some or
all of the information that we collect. Please read that notice so you know your
rights and how to act on them.


YOUR ACCOUNT DELETION RIGHTS

You may close your WebMD account and remove personal information from your
account. To do this, you can either:

 * go to the "Account Deletion" tab under "Settings" on this website's home page
   and follow the on-screen instructions to delete your account; or

 * send a signed statement with your name, address, email address, and birth
   date that directs WebMD to close your account and remove your personal
   information, to the address below.

If you want to write to us to have your account deleted, or to make changes to
your information, send it to:

WebMD Health Services Group, Inc.
Attn: Privacy Office
9229 Delegates Row, Suite 400
Indianapolis, IN 46240

privacy@webmd.com

or by submitting a request through the "Feedback" option at the bottom of the
log-in page.

If you delete your account and personal information, your Sponsor may decide
that you are not eligible for incentives and your account access, gained through
your Sponsor, will end immediately.


IF YOU SEPARATE FROM YOUR SPONSOR OR YOUR ACCOUNT IS CANCELLED

Certain events may cause you to lose access to your WebMD account. For example,
you may change jobs or health plans, or the contract between WebMD and your
Sponsor may end. When we know that you no longer have access, WebMD will shut
down your account and your personal information will be stored and subsequently
removed in keeping with our data destruction schedule. You may be able to access
your information after your account is shut down if your Sponsor has allowed
portable personal health records. If you think that your account has been
disabled in error, please contact WebMD at:

WebMD Health Services Group, Inc.
Attn: Privacy Office
9229 Delegates Row, Suite 400
Indianapolis, IN 46240

privacy@webmd.com

or by submitting a request through the "Feedback" option at the bottom of the
log-in page.


THE WEBMD SERVICES ARE INTENDED FOR ADULTS

All WebMD services are for adults who are at least 18 years of age. We do not
knowingly collect personal information from anyone under 18. But, in limited
instances, WebMD may permit parents and guardians to set up accounts for minors
in their care. Parents and guardians are solely responsible for accessing and
maintaining data on behalf of their minors. Parents and guardians are fully
responsible for securing usernames, passwords, and other login information and
for the accuracy of information. Parents and guardians are also fully
responsible for interpreting any advice their minors receive.


QUESTIONS OR COMPLAINTS

We will respond to your questions or complaints about how WebMD handles your
personal information. Questions or complaints regarding this Privacy Policy or
WebMD's handling of your personal information should be directed to:

WebMD Health Services Group, Inc.
Attn: Privacy Office
9229 Delegates Row, Suite 400
Indianapolis, IN 46240

privacy@webmd.com


CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional
rights regarding our use of your personal information. For more information
relevant to our users who are California residents, please read our Supplemental
Privacy Notice for California Residents.


NOTE TO USERS OUTSIDE OF THE UNITED STATES

WebMD stores all information on servers owned and maintained by WebMD in data
centers in the United States. In order to provide the WebMD Services 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.


CANADIAN PRIVACY RIGHTS

Cross-Border Transfer. The collection, use and disclosure of your personal
information through the WebMD Services is governed by applicable Canadian laws
and is also subject to US privacy laws. WebMD may transfer your personal
information outside Canada to its affiliates or third-party service providers
with operations in other countries, which are subject to laws of a foreign
jurisdiction. WebMD transfers and stores personal information on WebMD servers
in the US. By accepting this Privacy Policy, using the WebMD Services or
providing us with your personal information you acknowledge and consent to your
personal information being processed by third parties on WebMD’s behalf and
transferred, accessed and/or stored in countries outside Canada.

Canada Anti-Spam Law. In accordance with Canadian Anti-Spam laws, we obtain your
consent in order to send you commercial electronic messages. You may subscribe
or unsubscribe to receive marketing communications from us, such as
announcements of new features. We do not share email addresses or other contact
information with third parties without your permission.

Consent for WebMD Services. WebMD will seek your specific consent for the
collection, use or disclosure of personal information in connection with WebMD
Services that involve the provision of health care or wellness services. The
purposes for which this information is collected, used or disclosed are set out
at the time of collection..

Withdrawal of Consent, Access and Correction. You may withdraw your consent for
the collection, use or disclosure of Personal Information at any time by
notifying privacy@webmd.com, however such withdrawal shall not have retroactive
effect. You may also make a request to access or correct your Personal
Information by making a request in writing.


PERSONAL DATA PRIVACY NOTICE UNDER MEXICAN LAW

Privacy Notice. This privacy policy constitutes the personal data privacy notice
(the “Privacy Notice") required under the Federal Protection Law of Personal
Data in Possession of Private Parties and its Regulations of the United Mexican
States (collectively, the "Mexican Privacy Law"). In compliance with Mexican
Privacy Law, this Privacy Notice sets forth above (i) what Personal Information
we collect from you, (ii) how we collect your Personal Information, (iii) how we
use your Personal Information and (iv) how we share your Personal Information
with third parties.

Consent. Pursuant to Mexican Privacy Law, you hereby agree and grant your
express consent for WebMD to use your Personal Information in accordance with
the terms and conditions of this Privacy Notice, unless you oppose such use. At
any time you may revoke your consent in writing as hereinafter set forth below
in the paragraph "ARCO Rights".

Security of your Personal Information. This Privacy Notice sets forth above the
administrative, technical and physical security measures that we have
implemented to protect your Personal Information from unauthorized access or
disclosure and improper use. Compliance of such measures shall be likewise
requested from any third parties with whom we share your Personal Information.

ARCO Rights. As holder of the Personal Information, you may exercise your rights
of access, rectification, cancellation and opposition to the use of your
Personal Information ("ARCO Rights") provided by Mexican Privacy Law, or your
right to revoke your consent granted to WebMD for the use of your Personal
Information by contacting us as set forth below.

For such purposes, you shall provide the following: (a) name and address or
other means to give you a response to your request; (b) your identification
documents or, if applicable, legal representation documents; (c) a clear and
precise description of the Personal Information with respect of which you wish
to exercise any of the ARCO Rights; (d) your express revocation of your consent,
if applicable, to the use of your Personal Information and, therefore, to stop
using the same; and (e) any other element which may facilitate the
identification of the Personal Information.


AUSTRALIAN PRIVACY RIGHTS

Australian Privacy Act. The Australian Privacy Act 1968 (for the purposes of
this section, the "Privacy Act") provides Australian citizens with certain
rights regarding their personal information. This section contains additional
information about WebMD's collection, use and disclosure of Australian users'
information through the WebMD Services.

Definition of Personal Information: For Australian users of the WebMD Services,
personal information has the meaning set out in the Privacy Act, which at a high
level includes any information or opinion about an individual who is reasonably
identifiable.

Accuracy of Personal Information: We try to maintain your personal information
as accurately as reasonably possible. We rely on the accuracy of personal
information as provided to us both directly (from you) and indirectly. We
encourage you to contact us if you become aware of any personal information we
hold about you is incorrect and to notify us of a change in your personal
information. Our contact details are set out in the section of this Privacy
Policy titled "How to Contact Us".

Complaints: If you have any questions, comments or complaints about our
collection, use or disclosure of personal information, or if you believe that we
have not complied with this Privacy Policy or the Privacy Act, please contact us
(WebMD's contact details are set out in the section of this Privacy Policy
titled "How to Contact Us"). We will take any privacy complaint seriously and
any complaint will be assessed with the aim of resolving any issue in a timely
and efficient manner. We request that you cooperate with us during this process
and provide us with any relevant information that we may need.

If you are not satisfied with the outcome of our assessment of your complaint,
you may wish to contact the Office of the Australian Information Commissioner.

Overseas disclosure of Personal Information: WebMD may disclose Personal
Information outside of Australia to our related bodies corporate, service
providers and other third parties including those located in the United States.


NOTE TO USERS IN THE EUROPEAN ECONOMIC AREA (EEA) AND UK

General Data Protection Regulation

The EU General Data Protection Regulation and UK General Data Protection
Regulation (together the "GDPR") require certain information to be provided to
data subjects located in the EEA and the UK, and grant them certain rights
regarding their personal data. This section applies solely to the processing
activities that are governed by the GDPR.

Data Controller and EEA Representative

When you access the WebMD Services, your Sponsor and WebMD are separate
controllers of certain processing activities related to your personal data.
WebMD has appointed Dentons Europe Consulting B.V. as its representative in the
EEA. WebMD's Data Protection Officer can be contacted at privacy@webmd.com. This
Privacy Policy describes how WebMD processes your personal data.

Legal Bases for Processing

We may process your personal data in order to perform a contract with you (e.g.,
to deliver the WebMD Services you have requested) or in order to take certain
steps prior to entering into such contract. For example, we may process your
personal data in the following instances:

 * In order to provide you with the WebMD Services, you will need to create an
   account with WebMD and we will need to verify you as the account owner.

 * As part of the WebMD Services, we may need to contact you in order to provide
   you with information about your account or other health management and
   wellbeing program services.

 * As part of the WebMD Services, we may provide personalized services and more
   relevant content to you, based on the information you provide to us and on
   the information that we collect as part of your use of the WebMD Services.

 * As part of the WebMD Services, we may provide you with information for
   general service and transactional purposes, such as answering your questions,
   administering your account, responding to your complaints, and processing
   your data subject rights requests.

 * We may offer health management and wellbeing programs as part of the WebMD
   Services, and in order for you to participate in these programs, we may
   receive certain types of data from third-party service providers engaged by
   us or your Sponsor. These service providers may include entities that offer
   biometric screenings or flu shot services.

We may also process your personal data based on our legitimate interests or on
the legitimate interests of third parties, such as your Sponsor, provided that
such processing shall not outweigh your rights and freedoms. For example, we may
process your personal data in order to:

 * Keep the WebMD Services safe and secure;

 * Comply with laws and regulations that apply to us;

 * Manage corporate transactions, such as mergers or acquisitions; and

 * Understand and improve the WebMD Services.

Finally, we may process your personal data when you have given us your explicit
consent to such processing, particularly:

 * The sensitive personal data you provide to us; and

 * When you consent to receiving newsletters, marketing materials, and other
   promotional offers from us.

Where we rely on your consent to process your personal data, you have the right
to decline consent or withdraw your consent at any time. Where we rely on our
legitimate interests to process your personal data, you have the right to
object.

Transfers of Personal Data Outside of the EEA and the UK

WebMD, the controller of your personal data, is located in the United States.
Accordingly, your personal data is processed by WebMD in the United States.

WebMD may also transfer your personal data to third-party service providers to
help us provide the WebMD Services to you. Personal data may be stored and
processed in any country where WebMD has engaged service providers. If you are
located in the EEA in the UK, please note that your personal data may be
transferred to the United States or another country that may not be considered
to have the same level of data protection as the countries in the EEA or the UK.
However, please note that we have implemented appropriate safeguards by entering
into standard contractual clauses with any service provider located outside the
EEA and the UK.

Retention of Personal Data

WebMD will retain your personal data up to ninety (90) days after your account
deactivation. Thereafter, the data will be archived in order to comply with
applicable law or regulation that you, WebMD, or your Sponsor may be subject to,
such as HIPAA, or the data will be fully anonymized.

Your Rights to Your Personal Data

Under the GDPR, and in certain circumstances, you may ask to access, rectify,
erase, restrict, or port your personal data, as well as, object to the use of
your personal data. To exercise these rights, or if you have any questions or
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CHANGES TO THIS PRIVACY POLICY

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The date of any change, along with a brief description of the change, will be
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Issue date: November 21, 2023

November 21, 2023: Reviewed and approved without changes by JG (legal).

December 29th 2022: Updated EU DPO to include Dentons; updated Supplemental
Privacy Statement for CA; and other minor edits.

December 23rd, 2021: Added Privacy Rights for Canada, Mexico, and Australia.
Edited language for disclosures to sponsors.

April 28, 2021: Amendment the policy to remove provisions relating to the EU-US
Privacy Shield and Swiss-US Privacy Shield frameworks. Further updated the
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January 9, 2020: Amendment the policy to include a reference to the Supplemental
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March 6, 2019: Minor adjustments made to the policy to clarify processing in
accordance with the EU-US Privacy Shield and Swiss-US Privacy Shield frameworks.

February 25, 2019: Amended the policy to clarify the entity processing personal
information and added legal bases for processing in accordance with the EU
General Data Protection Regulation.

May 25, 2018: Minor adjustments made to the policy to reflect changes in the
access technology made available to users and to clarify both
information-handling practices and compliance with the EU General Data
Protection Regulation.

January 18, 2018: Removed references to Safe Harbor.

July 1, 2017: Amended the policy to incorporate the additional privacy
protections of the Swiss-U.S. Privacy Shield framework.

October 2016: Amended the policy to incorporate the additional privacy
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March 2013: Added Section XV. Safe Harbor Supplement for European Users.


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Last updated: September 1, 2022


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Editorial Integrity

Our mission is to bring you the most objective, trustworthy, and accurate health
information. Our daily goal is to ensure that WebMD is your practical and
relevant content source for health and medicine.

We are committed to providing information on a wide variety of health topics,
and rather than filtering certain types of information that may or may not be
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to choose the information that is most appropriate for you. However, the
original editorial information we provide is not intended to be a substitute for
professional medical advice, diagnosis, or treatment. Always seek the advice of
your physician or other qualified health provider with any questions you may
have regarding a medical condition. Never disregard professional medical advice
or delay in seeking it because of something you have read on the WebMD Site!

The following sections detail our content policies and procedures.


Editorial Selection of Original Content Created by WebMD

WebMD creates original content with reference generally to the following
criteria:

Relevance -- Issues that could affect how you manage your own health and that of
your family. Topics include coverage of breaking health news; drug and product
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managing diseases and conditions and staying healthy.

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New England Journal of Medicine, The Lancet, Pediatrics, Diabetes Care,
Circulation, and many others.

Trends -- Seasonal interests, such as "Summer Safety", "Allergy Seasons", and
"Cold and Flu"; public health awareness, such as "Breast Cancer Awareness Month"
and "Healthy Heart Month"; and emerging health trends, such as the latest in
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Our Content Is Different

It's more reliable. In a medium often accused of providing outdated and
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Our news and feature stories are based on our editors' selections of the most
important and relevant health events occurring on a given day. Our news articles
are more than a short summary of a study or an event. They often contain
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it means in today's world.

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WebMD maintains sole control of its editorial content.

Journalistic Excellence -- WebMD upholds traditional journalistic principles of
excellence in reporting original news for the Internet and in reviewing and
corroborating information from other sources. Our content continues to win
awards and recognitions in journalistic excellence and you can see our most
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Health Equity -- WebMD is dedicated to creating content by and for all people
and to helping close health equity gaps.


Editorial Policy for WebMD Editorial Staff

WebMD is the leading provider of health information services, serving consumers,
physicians and other healthcare professionals. Editorial content created by
WebMD is free from influence by advertisers and other sources.

Anyone who serves on the WebMD Editorial staff must fully disclose any potential
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The WebMD Editorial staff is charged with the responsibility of providing
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WebMD journalists strive to provide thorough and honest coverage and share a
dedication to the highest professional standards.


Original Content Process

The content that we produce and the news that we feature is determined by our
staff of physicians and medical journalists. It contains the latest information
from reliable sources including the most important peer-reviewed medical
journals, announcements from federal health agencies, and analyses on the latest
health trends. Our experienced health reporters talk daily with prominent
medical leaders, providing in-depth analyses, updates, and profiles that give
our health news and content a perspective found nowhere else. Every original
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Third parties may provide funding to WebMD for the creation by WebMD of original
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Each completed story to be published is reviewed by a physician editor for
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Licensed and Third Party Content

When WebMD licenses health and wellness content from third-parties for
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© 2024. WebMD Health Services Group, Inc. All rights reserved.

Last updated: February 15, 2023


CLINICAL REVIEW AND OVERSIGHT

WebMD Health Services maintains the highest clinical standards for the content
on our site. That’s why we maintain an active Clinical Advisory Board which is
composed of expert physicians and scientists who provide clinical guidance for
our products and solutions. The members provide expertise on topics including
behavioral science, lifestyle medicine, condition management, tobacco cessation,
health analytics, obesity, and more. They regularly review and approve the set
of evidence-based clinical guidelines from which most of our content is sourced.

In addition to the Clinical Advisory Board members who support our content, we
maintain expert physicians who regularly review and update our digital and print
content to ensure that it is accurate, up-to-date, and aligns with the
guidelines and scientific evidence. WebMD verifies the qualifications of all
healthcare professionals who contribute to the site.


CLINICAL ADVISORY BOARD


JAMES BECKERMAN, MD, FACC

James Beckerman is WebMD Health Service’s Medical Director providing clinical
oversight for WebMD’s condition management program, services and clinical
content. Dr. Beckerman also participates in the Quality Oversight Committee and
provides guidance on areas that impact the safety and clinical integrity of our
site.

Dr. Beckerman is the WebMD Heart Expert and a cardiologist with the Providence
Heart Institute in Portland, Oregon. He served as Chair of the Oregon Governor’s
Council for Physical Fitness and Sports and is the team cardiologist for the
Portland Timbers Major League Soccer team. Dr. Beckerman is the medical director
of Play Smart, a prevention-based cardiac screening program and is the
coach-in-chief of Heart to Start, a multi-state 5K training program. He is the
author of two books, The Flex Diet (2011) and Heart to Start (2015), which
inspire lifestyle change through medical evidence and motivational coaching. Dr.
Beckerman graduated from Harvard College and Harvard Medical School and
completed his internal medicine and cardiology training at Massachusetts General
Hospital and Stanford University.


BREANNE BROWN, DO, CAQSM, FAAFP

Breanne Brown is a Sports Medicine and Family Medicine physician in Portland,
Oregon. She graduated from The Chicago College of Osteopathic Medicine,
Midwestern in 2009 and did her Family Medicine residency in Portland, Oregon
with Providence Health and Services. She graduated in 2009 and went on to her
Sports Medicine Fellowship at Oregon Health and Science University. After
graduating from fellowship, Dr. Brown has worked for Providence in the Portland
service area practicing a blend of Family Medicine and Sports Medicine.

She is the head physician for the Portland Thorns, the women’s professional
soccer team, in addition to working with the United States Women’s National team
for soccer.

She serves as an executive Medical Task force member for the National Women’s
Soccer League in addition to Medical Director for Sports Medicine for Providence
in the greater Oregon and Southwest Washington region.


MICHAEL DANSINGER, MD

Michael Dansinger is a nationally recognized authority on dietary and lifestyle
counseling for weight loss and disease prevention. Dr. Dansinger is the Founding
Director of the Diabetes Reversal Program at Tufts Medical Center in Boston, and
an Assistant Professor at Tufts University School of Medicine. He is the
Wellness Director at Boston Heart Diagnostics, is a nutrition and diabetes
expert for WebMD Health Services, DietID, Heali, RxDiet, True Health Initiative
Media Response Team, and the CDC’s Worksite Health ScoreCard. He is a
contributing author to the Culinary Medicine Textbook by Deborah Kennedy, PhD.

His research on dietary counseling is well known. He published the highly
publicized research study “Comparison of the Atkins, Ornish, Weight Watchers and
Zone Diets for Weight Loss and Cardiac Risk Reduction” in the Journal of the
American Medical Association (JAMA). He is a panelist judge for US News and
World Reports’ “Best Diets” awards, and was the nutrition doctor for NBC’s “The
Biggest Loser” for 11 years. He has been interviewed about his weight loss
experience on the Today show, CNN, National Public Radio, CBS Radio, BBC Radio,
Oprah magazine, Time magazine, Consumer Reports, USA Today, The Wall Street
Journal, NY Times, Washington Post, Boston Globe, and hundreds of other media
outlets. He lectures throughout the U.S. to medical and non-medical audiences,
and is represented by the Harry Walker Agency.


ARIA DIBIASE, MD

Aria DiBiase attended Stanford University School of Medicine and completed
training in Internal Medicine and Cardiovascular Medicine at Stanford. She is
Board Certified in Internal Medicine, Cardiovascular Medicine and Advanced Heart
Failure and Transplantation. She has practiced clinical cardiology and heart
failure at Palo Alto Medical Foundation for over 25 years. She has extensive
experience in Disease Management and Heart Failure tele-management. She has
served on the WebMD Clinical Advisory Board for 8 years.


JENNIFER DRESSLER, BSN, RN, CPHQ

Jennifer Dressler joined WebMD Health Services in 2016. In her role as Director,
Clinical Services, Jennifer sets and guides the development of clinical
standards and protocol ensuring WebMD meets the highest clinical standards for
their programs and tools. This includes leading the Quality Oversight Committee,
being a liaison with the Clinical Advisory Board, overseeing the review and
accuracy of clinical content. Jennifer is heavily involved in the Condition
Management Program overall, its outcomes and Client support. She is also
accountable for successful submission of our four NCQA (National Committee for
Quality Assurance) and URAC (Utilization Review Accreditation Commission)
Accreditations.

Jennifer has more than 30 years’ experience in the health care industry. She
earned her bachelor’s degree in nursing from Niagara University with extensive
experience in various clinical settings including Neurological and Medical
Intensive Care, interventional cardiology, as well as utilization and case
management for health insurance companies. Jennifer holds the Certified
Professional in Healthcare Quality (CPHQ) certification further demonstrating
her commitment to quality and improving health outcomes.

Prior to working with WebMD, she held various leadership roles and positions
supporting international insurance stop loss, global product safety for a
pharmaceutical company, Medicaid Delivery System and Payment Transformation
Services, and state accountability for influencing Medicare star ratings. She
has been a member of the New York State and Indiana Nurses Association’s and
supports the Colorado Center for Nursing Excellence.


JOHN FOREYT, PHD

John P. Foreyt received his PhD in clinical psychology in 1969 from Florida
State University. He served on the faculty there until 1974 when he moved to
Baylor College of Medicine, Houston, Texas. He currently is Professor Emeritus
at the Baylor College of Medicine’s Department of Medicine and Department of
Psychiatry.

Dr. Foreyt has served as a member of the National Task Force on the Prevention
and Treatment of Obesity, National Institutes of Health; The Committee to
Develop Criteria for Evaluating the Outcomes of Approaches to Prevent and Treat
Obesity, Food and Nutrition Board, Institute of Medicine, National Academy of
Sciences; and The Expert Panel on the Identification, Evaluation, and Treatment
of Overweight and Obesity in Adults, National Institutes of Health, NHLBI.

He has published extensively in the areas of diet modification, cardiovascular
risk reduction, eating disorders, and obesity. He has published 17 books and
more than 380 articles. He is currently a member of the editorial boards of:
Eating Disorders; Obesity Research and Clinical Practice; American Journal of
Lifestyle Medicine; American Journal of Health Behavior; Obesity and Weight
Management; American Journal of Health Promotion; Childhood Obesity; and
Nutrition Today.

Dr. Foreyt is an Overseas Fellow of the Royal Society of Medicine; a Fellow of
the Society of Behavioral Medicine, a Fellow of the Obesity Society, a Fellow of
the Academy of Behavioral Medicine Research and a member of other professional
associations. He is a Life Member of the American Psychological Association and
an honorary member of the Academy of Nutrition and Dietetics.


SABRINA FELSON, MD

Sabrina Felson is a physician educator board-certified in internal medicine, Her
medical practice is at the Veterans Affairs New York Harbor, where she provides
primary care to our nation’s veterans. Like any true generalist, Dr. Felson is
interested in many facets of medicine and healthcare. She is passionate about
diagnosis, the more complicated the better. Dr. Felson also loves to work on
clinically-informed systems redesign and clinically-driven efficiency projects
to improve the patient interface with the healthcare system. She developed a
navigational tool called the Follow-up Plan for patients to use between
face-to-face visits, and spear-headed a project writing life bios to accompany
terminally-ill veterans throughout their hospitalizations. Dr. Felson is
currently preoccupied with reinvigorating the role of the general internist in
outpatient medicine. To further this goal, Dr. Felson recently stepped down as
Assistant Chief of Primary Care to become the Director of Clinical Innovations
in Primary Care at the Manhattan VA.

Dr. Felson is also Clinical Associate Professor of Medicine in the NYU
Department of General Medicine. As an educator, Dr. Felson serves as an NYU Firm
Chief, a senior faculty mentor for medical students during the medicine
clerkship. She continues to professionally guide students choosing to pursue
residency in Internal Medicine through the match process. Dr. Felson also
supervises a cohort of NYU residents assigned to the VA for their 3-year
continuity clinic experience.

Before entering medical school, Dr. Felson lived in Bolivia, where she helped to
develop training materials and run workshops for indigenous Aymaran women
interested in becoming midwives. She then earned a Master’s Degree in History of
Medicine at the University of Wisconsin-Madison before starting medical school
at Case Western Reserve University Medical School. Completed her residency
training at NYU Grossman School of Medicine, and had the honor of serving as
senior chief resident before joining the faculty.


RON Z. GOETZEL, PHD, MA

Ron Goetzel is a Senior Scientist and Director of the Institute for Health and
Productivity Studies (IHPS) at the Johns Hopkins Bloomberg School of Public
Health. The mission of the IHPS is to bridge the gap between academia, the
business community, and the healthcare policy world – bringing academic
resources into policy debates and day-to-day business decisions, and bringing
worker health and productivity management concerns into academia. Before moving
to Johns Hopkins University, Dr. Goetzel was on the faculty at Emory and Cornell
Universities. Dr. Goetzel is responsible for leading innovative projects for
healthcare purchaser, managed care, government, and pharmaceutical clients
interested in conducting cutting-edge research focused on the relationship
between health and well-being, medical costs, and work-related productivity. He
is an internationally recognized and widely published expert in health and
productivity management (HPM), return-on-investment (ROI), program evaluation,
and outcomes research. Dr. Goetzel has published well over 200 peer-reviewed
articles and book chapters and frequently presents at international business and
scientific forums.

Dr. Goetzel was the principal investigator (PI) for a Robert Wood Johnson
Foundation study examining the relationship between an organization’s culture of
health, employees’ health risks, medical costs, and company stock price. Dr.
Goetzel served as PI on a five-year project sponsored by the National Heart,
Lung, and Blood Institute (NHLBI) focused on obesity prevention at the
workplace. He was PI for the Centers for Medicare and Medicaid Services (CMS)
Senior Risk Reduction Demonstration, New Opportunities for Healthy Aging in
Medicare, and demonstrations focused on Cancer Prevention and Treatment for
Ethnic and Racial Minorities, Chiropractic Care, Vision Rehabilitation, and
Health Improvement Incentive Structures for Medicaid Beneficiaries. He also
served as PI for the Federal Employee Worksite Health and Wellness Initiative
administered by the Office of Personnel Management. For the Centers for Disease
Control and Prevention (CDC), Dr. Goetzel was PI for a New York City-based
project supporting collaboration between the private and public sectors directed
at employer health promotion programs. He was PI on two CDC initiatives focused
on updating the CDC Worksite Health ScoreCard and building a comprehensive CDC
Workplace Health Resource Center. Dr. Goetzel has worked with the Department of
Defense (DoD) on two health promotion and resilience training demonstrations for
the U.S. Army and Air Force. He supported the Office of the Secretary of Defense
as the evaluation contractor for the Healthy Base Initiative focused on managing
obesity and tobacco use in the military. Dr. Goetzel is working with the
Bipartisan Policy Center (BPC) in Washington DC supporting the CEO Council on
Health and Innovation and an initiative to build partnerships between businesses
and public health departments to improve community health.

In the private sector, Dr. Goetzel has led multiple evaluations of health
promotion and disease prevention programs at Boeing, Chevron, General Electric,
Dow Chemical, Citibank, Johnson & Johnson, IBM, Procter & Gamble, Duke
University, University of Michigan, Vanderbilt University, Motorola, Novartis,
PepsiCo, Prudential, PPG Industries, Mass Mutual, Whirlpool, and Bristol Myers
Squibb. Public sector partners have included King County Washington, Cayuga
County New York, and the State of Delaware. Health plan and insurance company
collaborators include Blue Cross Blue Shield Federal Employee Program, Health
Care Services Corporation, Blue Cross Blue Shield of Michigan, Blue Shield of
California, Highmark, American Specialty Health, Blue Cross Blue Shield
Association, Mayo Clinic, and Kaiser Permanente. Dr. Goetzel has also done work
with non-profits including the Robert Wood Johnson Foundation, Population Health
Alliance, Health Enhancement Research Organization (HERO),Transamerica Center
for Health Studies, American Heart Association, and The Health Project. Finally,
Dr. Goetzel has established strong working relationships with vendors in the
health promotion industry including StayWell, Johnson & Johnson, WebMD, Health
Fitness Corporation, Virgin Pulse, HealthStat, and Pfizer. Dr. Goetzel’s
international work includes projects with Discovery Health in South Africa, the
Ministry of Health in Israel, Social Service of Industry (SESI) in Brazil, and
The Health Promotion Board of Singapore.

Dr. Goetzel was a Task Force Member for the Guide to Community Preventive
Services (Community Guide) housed at the CDC and is currently the President and
CEO of The Health Project, which annually awards the prestigious C. Everett Koop
Prize to organizations with credible data demonstrating population health
improvement along with business results. He is the former Chairperson for HERO
and Jury Chair for The Fries Foundation housed at the CDC Foundation. He has
also served on several committees organized by the National Academies of
Science, Engineering and Medicine (NASEM). Dr. Goetzel was formerly Vice
President for Consulting and Applied Research at IBM Watson Health and Vice
President of Assessment, Data Analysis, and Evaluation Services at Johnson &
Johnson. Dr. Goetzel was one of the original members of the core development and
marketing group at Corporate Health Strategies. Earlier in his career, Dr.
Goetzel was the Medical School Education Program Evaluator at the Albert
Einstein College of Medicine, where he was appointed to the Psychiatry faculty.
Dr. Goetzel earned his doctorate in Organizational and Administrative Studies
and his M.A. in Applied Social Psychology from New York University (NYU), and
his B.S. degree in Psychology from the City College of New York (CCNY). He is
located in Bethesda, MD.


JEANETTE MENAPACE, MPH, RDN, LDN, CHES®

Jeanette Menapace is a Senior Health Education Specialist with WebMD Health
Services. She brings a wealth of expertise with the various roles and education
background within the healthcare sector. Jeanette earned her bachelor’s degree
in dietetics at The University of Akron. She then went on to earn her master’s
in public health from the Consortium of Eastern Ohio Master of Public Health
Program through Northeast Ohio Medical University. Finally, she obtained the
Certification for Health Education Specialist. Jeanette also worked as an
adjunct professor teaching online courses and serving as a tutor for students in
the Dietetics/Food Technology Associates Degree Program at Stark State College.
She maintains the Wellcoach Certification, Adult First Aid/CPR/AED certificate
and newly certified in the Mental Health First Aid USA. She is currently a
member of her local dietetic association and maintains her membership with the
Academy of Nutrition and Dietetics which includes a member of the Dietetics
Practice Based Research Group. She also continues her involvement with the Ohio
Academy of Nutrition and Dietetics and Ohio Society for Public Health Education.

During her 12-year tenure with WebMD, she has held various positions that first
included a WebMD Health Coach. She worked with hundreds of participants to
improve health using behavioral health techniques in the Whole Person Lifestyle,
Positively Me, Quit By WebMD, and Condition Management Coaching programs.
Currently, she manages the content creation and review of the Group Coaching
product materials and virtual webinars for clients. She works with a team of 5
health coaches who create and review content for these programs.

She is also responsible for helping manage accreditation materials. She has been
working on accreditation since 2019 and has helped to submit materials for NCQA
Health Information Product (HIP), Wellness & Health Promotion (WHP) and
Population Health Program (PHP). She also works on the preparing the Utilization
Review Accreditation Commission (URAC) submission.

Before joining WebMD Health Services, she worked with another wellness company
as a Senior Trainer/Development Specialist and briefly worked for the Women,
Infants and Children (WIC) program through MetroHealth Center for Community
Health in Cleveland, Ohio.


NIRMAL PATEL, MD, MPH

Dr Nirmal (Nim) Patel is a primary care physician, trained at the University of
Manchester in the UK where she received her MD, then at Yale, where she received
her MPH. Nim is passionate about high quality, patient centric care delivery,
using evidence, data and information technology to improve efficiency at the
point of care. She has more than two decades of experience working with senior
executives, in developing high performing primary care delivery systems and
digital health solutions, that are outcomes focused.

Nim has deep knowledge of the U.S. healthcare system, clinical care, health
benefits and her insights inform her approach to strategy, business and markets
she has been responsible for. Having worked within the large employer, hospital,
managed care and growth company environments, Nim understands the business
imperatives of stakeholders and her work focuses on business solutions and
timely delivery.

Her differentiated knowledge of clinical operations, evidence-based medicine,
care variation and gaps, have enabled her to innovate in the design of optimal
primary care delivery systems, which when combined with her strong quantitative
skills have allowed Nim and her teams to consistently measure outcomes and
success.

Nim is a subject matter expert in telehealth having created first of the kind
care-at-a-distance solutions focused on primary care, dermatology, as well as
behavioral health, while simultaneously using vast data sets collected, to
perform analytics to improve quality and cost of care.

She understands high performing ACOs models, development and deployment of
innovative population health software with clinical decision support and
telehealth applications for the point of care, to drive affordability and
quality.

Nim is a respected thought leader and spokesperson for the businesses she
represents. Areas of research, public speaking engagements are notable, she has
participated in numerous nationally renowned boards, leadership councils and is
often in the media sharing her expertise.


DEBORAH SHURE, MD, MASTER FCCP

Deborah Shure is a pulmonologist and consultant in clinical trial design for
medical devices, specializing in the areas of Pulmonary, Critical Care, and
Sleep Medicine. She has been on the WebMD Health Services Clinical Advisory
Board since 2012, having begun her association with WebMD Health Services with
major input into revisions and expansions of the COPD and Asthma Condition
Management Solutions products at that time. She values her continued input into
these and similar programs during her tenure at WebMD, enjoying working with
both her colleagues on the Clinical Advisory Board and the excellent staff at
WebMD Health Services. She was honored to be able to participate in the COVID-19
vaccine information effort in 2020 by participating in the WebMD Health Services
blog on the subject.

Dr. Shure graduated from Harvard University (BA), Dartmouth Medical School
(BMS), and Albert Einstein College of Medicine (MD). She trained in Internal
Medicine at Bellevue-NYU where she served as the first woman Chief Resident in
Medicine. She trained in Pulmonary Medicine at the University of California at
San Diego School of Medicine and remained on the faculty of UCSD for 12 years,
followed by faculty appointments at Washington University, University of
Mississippi (Professor of Medicine and Director of Pulmonary, Critical Care, and
Sleep Medicine), and University of Texas at Houston (Professor of Medicine and
Director, Program for Pulmonary Vascular Diseases).

During her more than 25-year career in academic medicine, Dr Shure became an
internationally recognized expert in several areas including pulmonary vascular
disease, COPD, bronchoscopy, teaching and mentoring, particularly of women and
minorities. Her work in these areas was recognized by many awards and honors
including national funding, the Elizabeth A Rich Award of the American Thoracic
Society, the American Thoracic Society Presidential Citation, and President of
the American College of Chest Physicians as well as Master Fellow of the
American College of Chest Physicians. Dr Shure was the first woman to be honored
by the College as President and as Master Fellow.

Following her career in academics, Dr Shure spent 7 years as a clinical reviewer
for the FDA Center for Devices and Radiological Health (CDRH) as the sole
pulmonologist for the Center where she gained valuable regulatory experience in
medical devices and received the CDRH Director’s Special Citation. Drawing on
her expertise in clinical practice, clinical research, device development, and
regulatory experience, Dr Shure became an independent consultant in the
development of medical devices (Cardiopulmonary, Critical Care, and Sleep
Medicine) in 2012. She also has an international reputation in this field and
continues to use her clinical and research skills to aid in this work. She
values the perspective that medical careers in three areas (academic,
regulatory, and business) allowed her to apply to her work with WebMD through
the Clinical Advisory Board.


LOREN SOEIRO, PHD, ABPP

Dr. Loren Soeiro joined the WebMD Health Services Clinical Advisory Board in
2016. He is a psychologist and psychotherapist with over two decades of clinical
experience. Prior to opening his Manhattan private practice, Dr. Soeiro worked
in an outpatient psychiatry clinic in the Bronx, NY, for patients with HIV and
AIDS. Along with a multimodal team of psychiatrists, physicians, social workers,
and other specialists, he evaluated and planned treatments in both English and
Spanish.

Dr. Soeiro was previously employed as an Assistant Clinical Professor of
Psychiatry and Behavioral Sciences at the Albert Einstein College of Medicine,
where he supervised and trained psychology interns, unlicensed psychologists and
medical residents. He specialized in teaching psychodynamic theory and
treatment, as well as psychotherapy for diverse populations. Dr. Soeiro also
provided training for psychology interns at several other New York-area
hospitals, such as North Central Bronx Hospital and the Beth Israel Medical
Center.

Dr. Soeiro received his Doctor of Philosophy and Master of Arts degrees in
clinical psychology from Long Island University, in Brooklyn, NY. He completed
his pre-doctoral internship at New York’s Beth Israel Medical Center; prior to
that, he studied psychology at Harvard College.

Dr. Soeiro is board certified as an expert in clinical psychology by the
American Board of Professional Psychologists and is a Fellow of the American
Academy of Clinical Psychology, as well as a member of the National Register of
Health Service Psychologists.


CLINICAL REVIEW TEAM


SABRINA FELSON, MD

Sabrina Felson is a physician educator board-certified in Internal Medicine. Her
medical practice is at the VA New York Harbor, where she provides primary care
to our nation’s veterans. Like any true generalist, Dr. Felson is interested in
many facets of medicine and healthcare. She is passionate about diagnosis, the
more complicated the better. Dr. Felson also loves to work on
clinically-informed systems redesign and clinically-driven efficiency projects
to improve the patient interface with the healthcare system. She developed a
navigational tool called the Follow-up Plan for patients to use between
face-to-face visits, and spear-headed a project writing life bios to accompany
terminally-ill veterans throughout their hospitalizations. Dr. Felson is
currently preoccupied with reinvigorating the role of the general internist in
outpatient medicine. To further this goal, Dr. Felson recently stepped down as
Assistant Chief of Primary Care to become the Director of Clinical Innovations
in Primary Care at the Manhattan VA.


STEFANIE LAI DO

Dr. Stefanie Lai is an osteopathic neuromusculoskeletal medicine specialist. She
graduated from the University of New England College of Osteopathic Medicine in
Biddeford, Maine in 2019. She then went on to complete her residency training at
Larkin Community Hospital in Hialeah, Florida. She is passionate about
osteopathic medicine and alternative pain management strategies.

© 2024. WebMD Health Services Group, Inc. All rights reserved.

Last updated: June 15, 2024


WEBMD HEALTH SERVICES PRIVACY POLICY

Your health plan Sponsor (which could be your employer in the case of a
self-funded plan, a group health plan, an insurer, or a third-party) contracts
with WebMD Health Services Group, Inc. for tools and services to help you manage
your health. We refer to this wellness website and the tools and services
provided by WebMD Health Services Group, Inc. collectively as the "WebMD
Services."

In this Privacy Policy, "we," "our," and "WebMD" refer to WebMD Health Services
Group, Inc. and any company that WebMD Health Services Group, Inc. owns or
controls. We do not operate, own, or control the website www.webmd.com. That
website is run by WebMD LLC, which is an affiliate of WebMD Health Services
Group, but is not owned or controlled by it. WebMD Health Services Group may
share information with companies that it owns or controls, and your information
will remain protected under the terms of this Privacy Policy.

This Privacy Policy explains how WebMD collects, receives, uses, stores, shares,
transfers, and processes your personal information as well as your rights in
determining what we do with the information that we collect or hold about you.
We know that keeping your personal information secure is very important to you.
Please read this Privacy Policy before you use the WebMD Services. Use of the
WebMD Services, as well as indicating your consent on this website's initial
registration page, signifies your acceptance of the terms of this Privacy
Policy. If you do not accept the terms of this Privacy Policy, do not use the
WebMD Services.

This Privacy Policy is not the same as your health plan's Health Insurance
Portability and Accountability Act of 1996 ("HIPAA") Notice of Privacy
Practices, which describes in detail how your health plan uses and discloses
your individually identifiable health information. To learn more, see "Your
Health Plan's Notice of Privacy Practices" below.

How to Contact Us

WebMD Health Services Group, Inc.
Attn: Privacy Office
9229 Delegates Row, Suite 400
Indianapolis, IN 46240

privacy@webmd.com


YOUR CHOICES

 * You decide whether to use the WebMD Services.

 * When you establish an account, you will be asked to consent to the
   information practices described in this Privacy Policy.

 * Before making any material changes to this Privacy Policy, we will ask for
   your consent.

 * You may access, correct, and delete your personal information directly
   through the WebMD Services.

 * We retain personal information in your WebMD account for as long as your
   WebMD account is open. Once we have been notified by your Sponsor that you
   are no longer eligible to use the WebMD Services, or if you otherwise write
   to us to have your account deleted, your account will be closed and the
   personal information in your WebMD account will be removed from WebMD's
   database and backup files in accordance with our data destruction policy and
   the terms of our agreement with your Sponsor.

 * You may close your account and delete your personal information at any time.


OUR COMMITMENT TO YOUR PRIVACY

WebMD respects and safeguards the privacy of everyone who uses the WebMD
Services. Here is a brief summary of our privacy practices:

 * We collect information directly from you when you register an account or use
   our tools or services.

 * We collect information about how you use our tools and services. We may use
   cookies or other tracking methods to do this. You can stop the collection of
   some information by turning off your browser's cookies, but this may keep
   some of our tools and services from working as they were designed to work.

 * We may collect location information when you use our apps, but only with your
   consent. You can stop this by not giving consent or by turning off location
   services on your device.

 * We collect information that your Sponsor gives us.

 * Our website does not contain advertisements and we do not share your personal
   information with any advertisers.

 * We use the information that we collect to manage your account, give you
   relevant health information, give your Sponsor statistics and aggregate
   reports, and improve our tools and services.

 * We will not use or share your personal information unless you allow us to,
   except as stated in this Privacy Policy or as directed by your Sponsor in
   accordance with your health plan's Notice of Privacy Practices.

 * We may share your information with service providers, third parties as
   directed by you or your Sponsor, in response to legal requests that we deem
   valid, in special circumstances, or in the event of a corporate restructure.

 * We use reasonable security measures to protect your personal information.


INFORMATION COVERED BY THIS PRIVACY POLICY

This Privacy Policy applies to information about you that WebMD collects and
stores in relation to your use of the WebMD Services. This information may
include:

 * personal information, which is any information relating to you that
   identifies you or, combined with other information, allows you to be
   identified; and

 * aggregate information, which is information about a group of individuals that
   does not identify any particular individual or allow any particular
   individual to be identified.

This Privacy Policy does not govern how other entities use your information.
This includes third-party websites that you may get to by clicking on links on
the WebMD Services. We recommend that you review the privacy policy of each
third-party website you visit.


PERSONAL INFORMATION WE COLLECT

We collect personal information about you from your Sponsor, from third-party
vendors working for your Sponsor, or directly from you when you use the WebMD
Services.

Personal information collected from, or provided to us by, your Sponsor includes
basic demographic information such as your name, email address, and your work
location.

Personal information collected directly from you includes:

 * information that you give us when you set up an account on the WebMD Services
   (this includes your name, email address, and date of birth) and your account
   information, including passwords and answers to security questions;

 * information about your health and behavior that you give us when you use
   WebMD Services, such as health trackers or a health assessment; and

 * other information that your Sponsor has requested, such as social security
   numbers and trade union membership.

You may choose not to give such information, but you would be limiting the
usefulness of the WebMD Services. Further, if you choose not to give certain
information, your Sponsor may make you ineligible for certain incentives. Ask
your Sponsor if you have questions about its incentive programs.

Your Sponsor may direct third-party vendors that provide services (such as
pharmacy benefits and biometric screening) on its behalf to send your personal
information to us.


OTHER INFORMATION COLLECTED WHEN YOU USE OUR SERVICES

Information collected indirectly from you includes information about your usage
of the WebMD Services, including information about how you navigate this
website, which health topics you inquire about, and which tools you use. To
collect this type of information we use cookies, web beacons, and other web
trackers. Cookies are small text files that are stored on your browser when you
visit a website that can be recognized during future visits to the website.
Similarly, a web beacon, pixel tag, or clear GIF is a small bit of code embedded
on a web page or in an email.

WebMD and its service providers use cookies and similar technologies to:

 * dynamically generate content on web pages or in newsletters;

 * statistically monitor how many people are using this website;

 * determine how many people open our emails;

 * determine the popularity of certain content; and

 * facilitate your login and serve as navigation aides and session timers.

We never use cookies or similar trackers for advertising. You can turn off
cookies in your browser settings, but doing so may negatively impact the
functionality of the WebMD Services. This website does not respond to web
browser do not track signals.

We do not track your use of the WebMD services for advertising.


MOBILE DEVICE APPLICATIONS

We offer some services through mobile apps. As with all of our other tools and
services, you must set up an account to use apps. We collect information when
you use an app. This can include the number of times that you use the app and
the information you submit via the app. We may also collect information about
the device on which you use the app. This includes the device's maker, type, and
software. To install one of our apps on your device, we'll give you a unique
code to access the app and to enable certain features. Our apps may ask you to
allow location functions (i.e., GPS). You don't have to give your location. If
you don't consent, some apps may not work as they were designed to work. You can
stop our apps from providing location information about you by changing the
location settings on your mobile device.

The information we collect when you use our apps is governed by this Privacy
Policy.


WHY WE COLLECT AND HOW WE USE YOUR INFORMATION

Personal information provided by your Sponsor is needed to:

 * authenticate you as a legitimate user of the WebMD Services;

 * establish log-in credentials to provide you with secure access to your
   information;

 * provide demographic data required by some WebMD Services; and

 * provide your Sponsors with reports of aggregate information (see the
   Disclosures to Your Sponsor section below).

Personal information collected directly from you is needed to:

 * establish and control access to your WebMD account;

 * allow you to track your health information and health-related behavior;

 * provide personalized content, advice, and recommendations that are relevant
   to you and your health needs; for example, we:
   
   * allow you to track your health and behaviors,
   
   * give you personalized health assessments,
   
   * send you health alerts or other health-related messages, and
   
   * send you messages about your account;

 * produce the report of statistics and aggregate information mentioned above;

 * respond to questions or comments that you send to us;

 * allow you to communicate with others in online health topic communities;

 * communicate with you as required by law, in connection with our services and
   as otherwise permitted by you or your Sponsor; and

 * find out how our services are being used to help us improve and know which
   tools users find most helpful.

Personal information collected indirectly from you is needed to assess and
improve how users of the WebMD Services navigate and utilize the website.


DISCLOSURES TO YOUR SPONSOR

We may disclose information about you to your Sponsor or to any third party: (a)
as instructed by your Sponsor, (b) as described in the Notice of Privacy
Practices that your Sponsor gave you, and (c) in accordance with applicable laws
and regulations.

We do provide your Sponsor with a number of reports on an aggregate and
anonymous basis. Your Sponsor uses these aggregate reports to better understand
and assess the health needs and concerns of its employee population, and to
consider development of programs to address these needs and concerns. For
example, your Sponsor might learn that there is significant interest in stopping
smoking amongst employees in a particular geographic region and then introduce
smoking cessation programs in those countries.

WebMD may tell your Sponsor if you have registered with WebMD, if you have taken
a health assessment, or if you've signed up for WebMD programs offered by your
Sponsor. We will do so to help your Sponsor manage incentives and analyze
registration rates. WebMD will not share your personal information (such as the
answers you give to the health assessment) in a manner that can be used to
identify you with your Sponsor.


DISCLOSURES TO OTHER THIRD PARTIES

WebMD may give your personal information to third-party vendors that provide us
services, including analytics, security, and marketing. Additionally, at the
direction of your Sponsor, WebMD may give your personal information to
third-party vendors that provide services for your Sponsor. For example, if your
Sponsor provides an incentive program that is managed by a vendor (e.g., for
completing a health assessment), then we may share your name, contact
information, and eligibility with the vendor so that you can get your incentive.
In any case, these third-party vendors are authorized only to process that
information as necessary and as directed by us or your Sponsor, respectively.

We may also give your personal information to other third parties under special
circumstances such as:

 * a court order, search warrant, subpoena, or other legal purpose that we deem
   to be valid;

 * to protect our rights, your rights, or the rights of others; and

 * a corporate transaction that results in a transfer of the assets or line of
   business that holds your information.

Should any of these events occur, WebMD will attempt to notify you through the
email address you provided us, unless doing so would violate a law or court
order.


HOW WE SAFEGUARD YOUR INFORMATION

We use reasonable technical, administrative, and physical safeguards to protect
your information from loss, misuse, and unauthorized access and changes. All
personal information you provide through the use of the WebMD Services is
secured in transmission using encryption and passwords. We also use
industry-standard encryption and hash algorithms in storing your personal
information within our databases and in back-up files. We use firewalls and
monitoring software to provide real-time protection for our servers, which are
locked down using standard physical measures. We store identical information on
servers at two separate locations to provide continuity of service.

We limit access to your information to help ensure that only you, our authorized
personnel, and other authorized third parties can access your information as
described in this Privacy Policy. All WebMD personnel are required to complete
privacy and security training on a regular and refresher basis and are subject
to disciplinary action for violating WebMD's information security policies.

No information system is 100% secure, and we can't guarantee that your
information will be protected against all security threats.


STORAGE OF YOUR INFORMATION

The personal information you provide when using the WebMD Services is stored and
maintained on servers owned by WebMD in data centers located in the United
States.


YOUR ACCESS AND CORRECTION RIGHTS

When you log in to this website, you can view, change, and delete personal
information that you have entered on this website.

Your Sponsor may choose to include information about your health (such as your
lab results, medications, or conditions) in your account. You can view this
information on the WebMD Services. You can stop this information from being
shown on your screen when you log on; but, you can't delete information that
your Sponsor gives us.

Also, your rights to view, correct, or change your personal information that are
set forth in your health plan's Notice of Privacy Practices may apply to some or
all of the information that we collect. Please read that notice so you know your
rights and how to act on them.


YOUR ACCOUNT DELETION RIGHTS

You may close your WebMD account and remove personal information from your
account. To do this, you can either:

 * go to the "Account Deletion" tab under "Settings" on this website's home page
   and follow the on-screen instructions to delete your account; or

 * send a signed statement with your name, address, email address, and birth
   date that directs WebMD to close your account and remove your personal
   information, to the address below.

If you want to write to us to have your account deleted, or to make changes to
your information, send it to:

WebMD Health Services Group, Inc.
Attn: Privacy Office
9229 Delegates Row, Suite 400
Indianapolis, IN 46240

privacy@webmd.com

or by submitting a request through the "Feedback" option at the bottom of the
log-in page.

If you delete your account and personal information, your Sponsor may decide
that you are not eligible for incentives and your account access, gained through
your Sponsor, will end immediately.


IF YOU SEPARATE FROM YOUR SPONSOR OR YOUR ACCOUNT IS CANCELLED

Certain events may cause you to lose access to your WebMD account. For example,
you may change jobs or health plans, or the contract between WebMD and your
Sponsor may end. When we know that you no longer have access, WebMD will shut
down your account and your personal information will be stored and subsequently
removed in keeping with our data destruction schedule. You may be able to access
your information after your account is shut down if your Sponsor has allowed
portable personal health records. If you think that your account has been
disabled in error, please contact WebMD at:

WebMD Health Services Group, Inc.
Attn: Privacy Office
9229 Delegates Row, Suite 400
Indianapolis, IN 46240

privacy@webmd.com

or by submitting a request through the "Feedback" option at the bottom of the
log-in page.


THE WEBMD SERVICES ARE INTENDED FOR ADULTS

All WebMD services are for adults who are at least 18 years of age. We do not
knowingly collect personal information from anyone under 18. But, in limited
instances, WebMD may permit parents and guardians to set up accounts for minors
in their care. Parents and guardians are solely responsible for accessing and
maintaining data on behalf of their minors. Parents and guardians are fully
responsible for securing usernames, passwords, and other login information and
for the accuracy of information. Parents and guardians are also fully
responsible for interpreting any advice their minors receive.


QUESTIONS OR COMPLAINTS

We will respond to your questions or complaints about how WebMD handles your
personal information. Questions or complaints regarding this Privacy Policy or
WebMD's handling of your personal information should be directed to:

WebMD Health Services Group, Inc.
Attn: Privacy Office
9229 Delegates Row, Suite 400
Indianapolis, IN 46240

privacy@webmd.com


CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional
rights regarding our use of your personal information. For more information
relevant to our users who are California residents, please read our Supplemental
Privacy Notice for California Residents.


NOTE TO USERS OUTSIDE OF THE UNITED STATES

WebMD stores all information on servers owned and maintained by WebMD in data
centers in the United States. In order to provide the WebMD Services 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.


CANADIAN PRIVACY RIGHTS

Cross-Border Transfer. The collection, use and disclosure of your personal
information through the WebMD Services is governed by applicable Canadian laws
and is also subject to US privacy laws. WebMD may transfer your personal
information outside Canada to its affiliates or third-party service providers
with operations in other countries, which are subject to laws of a foreign
jurisdiction. WebMD transfers and stores personal information on WebMD servers
in the US. By accepting this Privacy Policy, using the WebMD Services or
providing us with your personal information you acknowledge and consent to your
personal information being processed by third parties on WebMD’s behalf and
transferred, accessed and/or stored in countries outside Canada.

Canada Anti-Spam Law. In accordance with Canadian Anti-Spam laws, we obtain your
consent in order to send you commercial electronic messages. You may subscribe
or unsubscribe to receive marketing communications from us, such as
announcements of new features. We do not share email addresses or other contact
information with third parties without your permission.

Consent for WebMD Services. WebMD will seek your specific consent for the
collection, use or disclosure of personal information in connection with WebMD
Services that involve the provision of health care or wellness services. The
purposes for which this information is collected, used or disclosed are set out
at the time of collection..

Withdrawal of Consent, Access and Correction. You may withdraw your consent for
the collection, use or disclosure of Personal Information at any time by
notifying privacy@webmd.com, however such withdrawal shall not have retroactive
effect. You may also make a request to access or correct your Personal
Information by making a request in writing.


PERSONAL DATA PRIVACY NOTICE UNDER MEXICAN LAW

Privacy Notice. This privacy policy constitutes the personal data privacy notice
(the “Privacy Notice") required under the Federal Protection Law of Personal
Data in Possession of Private Parties and its Regulations of the United Mexican
States (collectively, the "Mexican Privacy Law"). In compliance with Mexican
Privacy Law, this Privacy Notice sets forth above (i) what Personal Information
we collect from you, (ii) how we collect your Personal Information, (iii) how we
use your Personal Information and (iv) how we share your Personal Information
with third parties.

Consent. Pursuant to Mexican Privacy Law, you hereby agree and grant your
express consent for WebMD to use your Personal Information in accordance with
the terms and conditions of this Privacy Notice, unless you oppose such use. At
any time you may revoke your consent in writing as hereinafter set forth below
in the paragraph "ARCO Rights".

Security of your Personal Information. This Privacy Notice sets forth above the
administrative, technical and physical security measures that we have
implemented to protect your Personal Information from unauthorized access or
disclosure and improper use. Compliance of such measures shall be likewise
requested from any third parties with whom we share your Personal Information.

ARCO Rights. As holder of the Personal Information, you may exercise your rights
of access, rectification, cancellation and opposition to the use of your
Personal Information ("ARCO Rights") provided by Mexican Privacy Law, or your
right to revoke your consent granted to WebMD for the use of your Personal
Information by contacting us as set forth below.

For such purposes, you shall provide the following: (a) name and address or
other means to give you a response to your request; (b) your identification
documents or, if applicable, legal representation documents; (c) a clear and
precise description of the Personal Information with respect of which you wish
to exercise any of the ARCO Rights; (d) your express revocation of your consent,
if applicable, to the use of your Personal Information and, therefore, to stop
using the same; and (e) any other element which may facilitate the
identification of the Personal Information.


AUSTRALIAN PRIVACY RIGHTS

Australian Privacy Act. The Australian Privacy Act 1968 (for the purposes of
this section, the "Privacy Act") provides Australian citizens with certain
rights regarding their personal information. This section contains additional
information about WebMD's collection, use and disclosure of Australian users'
information through the WebMD Services.

Definition of Personal Information: For Australian users of the WebMD Services,
personal information has the meaning set out in the Privacy Act, which at a high
level includes any information or opinion about an individual who is reasonably
identifiable.

Accuracy of Personal Information: We try to maintain your personal information
as accurately as reasonably possible. We rely on the accuracy of personal
information as provided to us both directly (from you) and indirectly. We
encourage you to contact us if you become aware of any personal information we
hold about you is incorrect and to notify us of a change in your personal
information. Our contact details are set out in the section of this Privacy
Policy titled "How to Contact Us".

Complaints: If you have any questions, comments or complaints about our
collection, use or disclosure of personal information, or if you believe that we
have not complied with this Privacy Policy or the Privacy Act, please contact us
(WebMD's contact details are set out in the section of this Privacy Policy
titled "How to Contact Us"). We will take any privacy complaint seriously and
any complaint will be assessed with the aim of resolving any issue in a timely
and efficient manner. We request that you cooperate with us during this process
and provide us with any relevant information that we may need.

If you are not satisfied with the outcome of our assessment of your complaint,
you may wish to contact the Office of the Australian Information Commissioner.

Overseas disclosure of Personal Information: WebMD may disclose Personal
Information outside of Australia to our related bodies corporate, service
providers and other third parties including those located in the United States.


NOTE TO USERS IN THE EUROPEAN ECONOMIC AREA (EEA) AND UK

General Data Protection Regulation

The EU General Data Protection Regulation and UK General Data Protection
Regulation (together the "GDPR") require certain information to be provided to
data subjects located in the EEA and the UK, and grant them certain rights
regarding their personal data. This section applies solely to the processing
activities that are governed by the GDPR.

Data Controller and EEA Representative

When you access the WebMD Services, your Sponsor and WebMD are separate
controllers of certain processing activities related to your personal data.
WebMD has appointed Dentons Europe Consulting B.V. as its representative in the
EEA. WebMD's Data Protection Officer can be contacted at privacy@webmd.com. This
Privacy Policy describes how WebMD processes your personal data.

Legal Bases for Processing

We may process your personal data in order to perform a contract with you (e.g.,
to deliver the WebMD Services you have requested) or in order to take certain
steps prior to entering into such contract. For example, we may process your
personal data in the following instances:

 * In order to provide you with the WebMD Services, you will need to create an
   account with WebMD and we will need to verify you as the account owner.

 * As part of the WebMD Services, we may need to contact you in order to provide
   you with information about your account or other health management and
   wellbeing program services.

 * As part of the WebMD Services, we may provide personalized services and more
   relevant content to you, based on the information you provide to us and on
   the information that we collect as part of your use of the WebMD Services.

 * As part of the WebMD Services, we may provide you with information for
   general service and transactional purposes, such as answering your questions,
   administering your account, responding to your complaints, and processing
   your data subject rights requests.

 * We may offer health management and wellbeing programs as part of the WebMD
   Services, and in order for you to participate in these programs, we may
   receive certain types of data from third-party service providers engaged by
   us or your Sponsor. These service providers may include entities that offer
   biometric screenings or flu shot services.

We may also process your personal data based on our legitimate interests or on
the legitimate interests of third parties, such as your Sponsor, provided that
such processing shall not outweigh your rights and freedoms. For example, we may
process your personal data in order to:

 * Keep the WebMD Services safe and secure;

 * Comply with laws and regulations that apply to us;

 * Manage corporate transactions, such as mergers or acquisitions; and

 * Understand and improve the WebMD Services.

Finally, we may process your personal data when you have given us your explicit
consent to such processing, particularly:

 * The sensitive personal data you provide to us; and

 * When you consent to receiving newsletters, marketing materials, and other
   promotional offers from us.

Where we rely on your consent to process your personal data, you have the right
to decline consent or withdraw your consent at any time. Where we rely on our
legitimate interests to process your personal data, you have the right to
object.

Transfers of Personal Data Outside of the EEA and the UK

WebMD, the controller of your personal data, is located in the United States.
Accordingly, your personal data is processed by WebMD in the United States.

WebMD may also transfer your personal data to third-party service providers to
help us provide the WebMD Services to you. Personal data may be stored and
processed in any country where WebMD has engaged service providers. If you are
located in the EEA in the UK, please note that your personal data may be
transferred to the United States or another country that may not be considered
to have the same level of data protection as the countries in the EEA or the UK.
However, please note that we have implemented appropriate safeguards by entering
into standard contractual clauses with any service provider located outside the
EEA and the UK.

Retention of Personal Data

WebMD will retain your personal data up to ninety (90) days after your account
deactivation. Thereafter, the data will be archived in order to comply with
applicable law or regulation that you, WebMD, or your Sponsor may be subject to,
such as HIPAA, or the data will be fully anonymized.

Your Rights to Your Personal Data

Under the GDPR, and in certain circumstances, you may ask to access, rectify,
erase, restrict, or port your personal data, as well as, object to the use of
your personal data. To exercise these rights, or if you have any questions or
comments regarding your personal data, please contact us at privacy@webmd.com.

When we process your personal data based on your consent, you have the right to
withdraw your consent, at any time, without affecting the lawfulness of such
processing before your withdrawal. To withdraw your consent, please submit a
written request to privacy@webmd.com.

For processing necessary to perform the contract, or based on our legitimate
interests, we may be unable to accommodate any requests to cease such
processing; or if we do accommodate such requests, you may lose access to the
WebMD Services.

If you believe that we have not complied with our obligations under this Privacy
Policy or the GDPR, you have the right to complain to your local data protection
authority.

Do You Need to Provide Personal Data?

We need to process your personal data in order to provide you with the WebMD
Services. If you do not want to provide any personal data, you may not enjoy all
or part of the WebMD Services.

Automated Decision-Making

WebMD does not make automated decisions that create legal effects or otherwise
significantly affect you.

Our Safeguards and Security Measures

We have implemented technology and security measures to protect your personal
data from unauthorized access, disclosure, improper use, alteration, unlawful or
accidental destruction, and accidental loss. For more information, please refer
to the How We Safeguard Your Information section above.

By using the WebMD Services or providing personal information to us, you
acknowledge that we may communicate with you electronically about any security,
privacy, or administrative issues relating to your use of the WebMD Services. If
You have any reason to believe that your interaction with us is no longer
secure, please contact us immediately at privacy@webmd.com.


YOUR HEALTH PLAN'S NOTICE OF PRIVACY PRACTICES

You should know that your health plan has a Notice of Privacy Practices, which
includes policies for use and disclosure of your information, including
information that you provide to WebMD. This is managed by your health plan, not
by WebMD, so we aren't able to let you know of changes or updates. If you would
like to read a copy of your health plan's Notice of Privacy Practices, please
ask your Sponsor or your plan for a copy.


CHANGES TO THIS PRIVACY POLICY

We may change parts of this Privacy Policy from time to time. Changes take
effect at the time they are posted unless otherwise noted. You will be required
to opt-in to the new policy when they log back in after any material changes. We
will update the date at the end of this Privacy Policy if we make any changes.

You should regularly review this Privacy Policy at
https://www.webmdhealth.com/Policies/Privacy?spid=1.

The date of any change, along with a brief description of the change, will be
posted at the bottom of the Privacy Policy.

Issue date: November 21, 2023

November 21, 2023: Reviewed and approved without changes by JG (legal).

December 29th 2022: Updated EU DPO to include Dentons; updated Supplemental
Privacy Statement for CA; and other minor edits.

December 23rd, 2021: Added Privacy Rights for Canada, Mexico, and Australia.
Edited language for disclosures to sponsors.

April 28, 2021: Amendment the policy to remove provisions relating to the EU-US
Privacy Shield and Swiss-US Privacy Shield frameworks. Further updated the
policy to clarify processing that is subject to the GDPR.

January 9, 2020: Amendment the policy to include a reference to the Supplemental
Privacy Notice for California residents.

March 6, 2019: Minor adjustments made to the policy to clarify processing in
accordance with the EU-US Privacy Shield and Swiss-US Privacy Shield frameworks.

February 25, 2019: Amended the policy to clarify the entity processing personal
information and added legal bases for processing in accordance with the EU
General Data Protection Regulation.

May 25, 2018: Minor adjustments made to the policy to reflect changes in the
access technology made available to users and to clarify both
information-handling practices and compliance with the EU General Data
Protection Regulation.

January 18, 2018: Removed references to Safe Harbor.

July 1, 2017: Amended the policy to incorporate the additional privacy
protections of the Swiss-U.S. Privacy Shield framework.

October 2016: Amended the policy to incorporate the additional privacy
protections of the EU-U.S. Privacy Shield framework.

March 2013: Added Section XV. Safe Harbor Supplement for European Users.

WebMD® TERMS OF USE

PLEASE READ THESE TERMS OF USE CAREFULLY BEFORE USING OUR SERVICES OR OUR SITE.

By using this WebMD website or any related tools, products or services,
including without limitation, WebMD ONE℠, WebMD Health Manager, or WebMD Health
Coaching (collectively, the "Site"), you signify your acceptance to these Terms
of Use. If you do not agree to all of these Terms of Use, do not use our Site.

WebMD Health Services Group, Inc. ("WebMD") may revise, modify or amend these
Terms of Use at any time. Any such revision, modification or amendment shall be
effective immediately upon either posting it to the Site or notifying you. You
agree to review these Terms of Use periodically to ensure that you are aware of
any changes. Your continued use of this Site will mean you accept those changes.

WebMD reserves the right at any time and from time to time to modify or
discontinue, temporarily or permanently, all or any part thereof, or our Content
(as defined below), with or without notice.

We have organized the Terms of Use under the following topics:

 1.  THE SITE DOES NOT PROVIDE MEDICAL ADVICE
 2.  CHILDREN'S PRIVACY
 3.  USE OF CONTENT
 4.  LIABILITY OF WEBMD AND ITS LICENSORS
 5.  SPONSORING ORGANIZATIONS
 6.  USER SUBMISSIONS
 7.  PASSWORDS
 8.  WEBMD LIVE AND MEMBER-TO-MEMBER AREAS
 9.  SEARCHES AND LINKS TO OTHER SITES
 10. TRADEMARKS
 11. TERMINATION OF SERVICE
 12. INDEMNITY
 13. NOTICE
 14. GENERAL
 15. JURISDICTION
 16. COMPLETE AGREEMENT
 17. QUESTIONS, COMMENTS, OR REQUESTING ADDITIONAL INFORMATION FROM US


1. THE SITE DOES NOT PROVIDE MEDICAL ADVICE

The contents of this Site, such as text, graphics, images, tools, products,
services and other material contained on the Site ("Content") is provided by
WebMD and its licensors for informational purposes only. Nothing contained in
the Content is intended to be medical advice or instructional for medical
diagnosis or treatment. The health information furnished on this Site is not
intended to be complete, to suggest or recommend a course of treatment, or to
replace personal consultation with a qualified health care professional.

Always seek the advice of your physician or other qualified health provider with
any questions you may have regarding a health or medical condition. Never
disregard, avoid or delay obtaining professional medical advice from your doctor
or other qualified health provider because of something you have read on this
Site!

If you are in the United States and think you may have a medical emergency, call
your doctor or 911 immediately.

WebMD does not recommend or endorse any specific tests, physicians, products,
procedures, opinions or other information that is mentioned on the Site.
Reliance on any information provided by WebMD, WebMD employees, others appearing
on the Site at the invitation of WebMD, or other visitors to the Site is solely
at your own risk. The Site may contain health or medical related materials that
are sexually explicit. If you find these materials offensive, you may not want
to use our Site.

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2. CHILDREN'S PRIVACY

We are committed to protecting the privacy of children. Neither WebMD nor any of
its services are intended or designed to attract children under the age of 18.
Some of our services may allow a parent or guardian to use such services on
behalf of their minor children. In these instances, the parent or guardian is
solely responsible for providing supervision of the minor's use of the Site.

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3. USE OF CONTENT

WebMD authorizes you to view or download the material on the Site solely for
your personal, noncommercial use if you include the following copyright notice:
"Copyright © 1996 - 2022, WebMD Health Services Group, Inc. All rights reserved"
and other copyright and proprietary rights notices that are contained in the
Content. Any special rules for the use of certain software and other items
accessible on the Site may be included elsewhere within the Site and are
incorporated into these Terms of Use by reference.

The Content is protected by copyright under both United States and foreign laws.
Title to the Content remains with WebMD or its licensors. Any use of the Content
not expressly permitted by these Terms of Use is a breach of these Terms of Use
and may violate copyright, trademark, and other laws. Content and features of
the Site are subject to change or termination without notice at the editorial
discretion of WebMD. All rights not expressly granted herein are reserved to
WebMD and its licensors.

If you violate any of these Terms of Use, your permission to use the Content
automatically terminates and you must immediately destroy any copies you have
made of any portion of the Content.

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4. LIABILITY OF WEBMD AND ITS LICENSORS

The use of the Site and the Content is at your own risk.

When using the Site, information will be transmitted over a medium that may be
beyond the control and jurisdiction of WebMD and its suppliers. Accordingly,
WebMD assumes no liability for or relating to the delay, failure, interruption,
or corruption of any data or other information transmitted in connection with
your use of the Site.

The Site and the content are provided on an "AS IS" basis. WEBMD, ITS LICENSORS,
AND ITS SUPPLIERS, TO THE FULLEST EXTENT PERMITTED BY LAW, DISCLAIM ALL
WARRANTIES, EITHER EXPRESS OR IMPLIED, STATUTORY OR OTHERWISE, INCLUDING BUT NOT
LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY, NON-INFRINGEMENT OF THIRD
PARTIES' RIGHTS, AND FITNESS FOR PARTICULAR PURPOSE. Without limiting the
foregoing, WebMD, its licensors, and its Content suppliers make no
representations or warranties about the following:

 A. The accuracy, reliability, completeness, usefulness, adequacy, suitability,
    currentness, or timeliness of the Content, software, text, graphics, links,
    or communications provided on or through the use of the Site or in
    newsletters and other products and services from WebMD or its licensors;
 B. The satisfaction of any government regulations requiring disclosure of
    information on prescription drug products or the approval or compliance of
    any software tools with regard to the Content contained on the Site;
 C. That the Content is free from errors and omissions; and
 D. That data flowing to and from the Site or WebMD (regardless of the means)
    will not be delayed, interrupted or experience losses of data, or that files
    available for downloading from this Site will be free of infection by
    viruses, worms, Trojan horses or other code with destructive properties.

In no event shall WebMD, its licensors, its suppliers, or any third parties
mentioned on the Site be liable for any damages (including, without limitation,
incidental and consequential damages, personal injury/wrongful death, lost
profits, or damages resulting from lost data or business interruption) resulting
from the use of or inability to use the Site or the Content, whether based on
warranty, contract, tort, or any other legal theory, and whether or not WebMD is
advised of the possibility of such damages. WebMD shall be liable only to the
extent of actual damages incurred by you, not to exceed U.S. $1000. WebMD is not
liable for any personal injury, including death, caused by your use or misuse of
the Site, Content, or Public Areas (as defined below). Any claims arising in
connection with your use of the Site, any Content, or the Public Areas must be
brought within one (1) year of the date such action occurred. Remedies under
these Terms of Use are exclusive and are limited to those expressly provided for
in these Terms of Use.

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5. SPONSORING ORGANIZATIONS

If you are accessing WebMD ONE℠ or WebMD Health Manager through a sponsoring
organization's site, the sponsoring organization may have a separate
registration process in addition to the WebMD ONE℠ or WebMD Health Manager
registration. WebMD encourages you to read your sponsoring organization's
disclosure statement, which may include, among other things, a description of
their business practices relating to collection and use of your personal data.

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6. USER SUBMISSIONS

You agree that you will not upload or transmit any communications or content of
any type to any member-to-member areas, such as message boards and member
communities (collectively, the “Public Areas”) that infringe or violate any
rights of any party. By submitting communications or content to the Public
Areas, you agree that such submission is non-confidential for all purposes.

If you make any such submission, you agree that you will not send or transmit to
WebMD by email, (including through the email addresses listed on the "Contact
Us" link) any communication or content that infringes or violates any rights of
any party. If you submit any business information, idea, concept or invention to
WebMD by email, you agree such submission is non-confidential for all purposes.

If you make any submission to a Public Area or if you submit any business
information, idea, concept or invention to WebMD by email, you automatically
grant-or warrant that the owner of such content or intellectual property has
expressly granted-WebMD a royalty-free, perpetual, irrevocable, world-wide
nonexclusive license to use, reproduce, create derivative works from, modify,
publish, edit, translate, distribute, perform, and display the communication or
content in any media or medium, or any form, format, or forum now known or
hereafter developed. WebMD may sublicense its rights through multiple tiers of
sublicenses. If you wish to keep any business information, ideas, concepts or
inventions private or proprietary, do not submit them to the Public Areas or to
WebMD by email.

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7. PASSWORDS

Several tools on the Site, including WebMD ONE℠ and WebMD Health Manager, allow
you to record and store information. For example, WebMD ONE℠ and WebMD Health
Manager are tools that allow you to record Personal Health Information on a
voluntary basis on servers maintained by WebMD or on its behalf. The WebMD ONE℠
and WebMD Health Manager tools are structured to allow access only to registered
visitors who have a valid user ID and password.

When registering for tools on the Site, including WebMD ONE℠ and WebMD Health
Manager, you will establish a personal WebMD account with your own unique
password. You agree to maintain the security of your user identification,
password and other confidential information relating to the use of your WebMD
account and to be responsible for any and all charges resulting from use of your
WebMD account. You are responsible for taking all reasonable steps to ensure
that no unauthorized person shall have access to your WebMD passwords or
accounts. It is your sole responsibility to (1) control the dissemination and
use of activation codes and passwords; (2) authorize, monitor, and control
access to and use of your WebMD account and password; (3) promptly inform WebMD
of any need to deactivate a password. You grant WebMD and all other persons or
entities involved in the operation of the Site the right to transmit, monitor,
retrieve, store, and use your information in connection with the operation of
the Site. WebMD cannot and does not assume any responsibility or liability for
any information you submit, including to the WebMD ONE℠ and WebMD Health Manager
tools, or your or third parties' use or misuse of information transmitted or
received using WebMD tools and services, including WebMD ONE℠ and WebMD Health
Manager.

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8. WEBMD LIVE AND MEMBER-TO-MEMBER AREAS

If you use a Public Area, you are solely responsible for your own
communications, the consequences of posting those communications, and your
reliance on any communications found in the Public Areas. WebMD is not
responsible for the consequences of any communications in the Public Areas. In
cases where you feel threatened or believe someone else is in danger, you should
contact your local law enforcement agency immediately. If you think you may have
a medical emergency, call your doctor or 911 immediately.

In consideration of being allowed to use the Public Areas, you agree that the
following actions shall constitute a material breach of these Terms of Use:

 A. Using a Public Area for any purpose in violation of local, state, national,
    or international laws;
 B. Posting material that infringes on the intellectual property rights of
    others or on the privacy or publicity rights of others;
 C. Posting material that is unlawful, obscene, defamatory, threatening,
    harassing, abusive, slanderous, hateful, or embarrassing to any other person
    or entity as determined by WebMD in its sole discretion;
 D. Posting advertisements or solicitations of business;
 E. After receiving a warning, continuing to disrupt the normal flow of
    dialogue, or posting comments that are not related to the topic being
    discussed (unless it is clear the discussion is free-form);
 F. Posting chain letters or pyramid schemes;
 G. Impersonating another person;
 H. Distributing viruses or other harmful computer code;
 I. Harvesting or otherwise collecting information about others, including email
    addresses, without their consent;
 J. Allowing any other person or entity to use your identification for posting
    or viewing comments;
 K. Posting the same note more than once or "spamming"; or
 L. Engaging in any other conduct that restricts or inhibits any other person
    from using or enjoying the Public Area or the Site, or which, in the
    judgment of WebMD, exposes WebMD or any of its customers or suppliers to any
    liability or detriment of any type.

WebMD reserves the right (but is not obligated) to do any or all of the
following:

 A. Record the dialogue in public chat rooms;
 B. Investigate an allegation that a communication(s) do(es) not conform to the
    terms of this section and determine in its sole discretion to remove or
    request the removal of the communication(s);
 C. Remove communications that are abusive, illegal, or disruptive, or that
    otherwise fail to conform with these Terms of Use;
 D. Terminate a user's access to any or all Public Areas and/or the Site upon
    any breach of these Terms of Use;
 E. Monitor, edit, or disclose any communication in the Public Areas; or
 F. Edit or delete any communication(s) posted on the Site, regardless of
    whether such communication(s) violate these standards.

WebMD reserves the right to take any action it deems necessary to protect the
personal safety of our guests or the public. WebMD has no liability or
responsibility to users of the Site or any other person or entity for
performance or nonperformance of the aforementioned activities.

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9. SEARCHES AND LINKS TO OTHER SITES

WebMD may provide links to third-party web sites. WebMD also may select certain
sites as priority responses to search terms you enter. WebMD does not recommend
and does not endorse the content on any third-party websites. WebMD is not
responsible for the content of linked third-party sites, sites framed within the
Site, third-party sites provided as search results, and does not make any
representations regarding their content or accuracy. Your use of third-party
websites is at your own risk and subject to the terms and conditions of use for
such sites. WebMD does not endorse any product advertised on the third-party
sites. WebMD is not responsible or liable for any loss or damage of any sort
incurred as a result of your dealings on a third-party site.

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10. TRADEMARKS

We own the names we use for our products and services on the Site, and these
names are protected by trademark laws in the U.S. and internationally. An ®
following a name on our site indicates that the trademark has been registered in
the United States. All trademarks are the property of their respective owners.
If your activities are noncommercial, you may make use of our trademarks by
linking to us or discussing us with others, as long as you make it clear that we
are the owner of the trademark. Any other uses of our trademarks require our
prior written approval.

You may not use WebMD's trademarks in any of the following ways:

 A. In a non-WebMD product name or publication title;
 B. Within or as part of your own trademarks;
 C. To identify non-WebMD products or services;
 D. In a manner which will likely cause confusion;
 E. In a manner that implies that WebMD sponsors, endorses or is otherwise
    connected with your own activities, products, or services; or
 F. In a manner that disparages WebMD.

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11. TERMINATION OF SERVICE

You agree that if you violate these Terms of Use, your permission to use this
Site automatically terminates. You also agree that WebMD may, at its sole
discretion, terminate your access to this Site, or any portion thereof, or
discontinue providing the Site, or any portion thereof. Further, you agree that
WebMD is not liable to you or any third party for any such termination or
discontinuance.

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12. INDEMNITY

You agree to defend, indemnify and hold harmless WebMD, its parent, subsidiaries
and affiliates, licensors and suppliers, and their directors, officers,
employees, agents and contractors from and against any claims, actions or
demands, liabilities and settlements including without limitation, reasonable
legal and accounting fees, resulting from, or alleged to result from, your
violation of these Terms of Use.

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13. NOTICE

If you register for services or tools on the Site, including WebMD ONE℠ or WebMD
Health Manager, you agree to keep your contact information, such as email
address, accurate and up-to-date so that we can contact you regarding our
policies. Failure to have accurate contact information may affect our ability to
provide you notice.

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14. GENERAL

WebMD makes no claims that the Content is appropriate or may be downloaded
outside of the United States. Access to the Content may not be legal by certain
persons or in certain countries. If you access the Site from outside the United
States, you do so at your own risk and are responsible for compliance with the
laws of your jurisdiction. For purposes of these Terms of Use, the term WebMD
shall include WebMD Health Services Group, Inc., its parent, subsidiaries and
affiliates and their directors, officers, employees, agents and contractors. The
following provisions survive the expiration or termination of these Terms of Use
for any reason whatsoever: Liability, User Submissions, Indemnity, General,
Jurisdiction, and Complete Agreement.

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15. JURISDICTION

You expressly agree that exclusive jurisdiction for any dispute with WebMD, or
in any way relating to your use of the Site, resides in the courts of the State
of New York and you further agree and expressly consent to the exercise of
personal jurisdiction in the courts of the State of New York in connection with
any such dispute including any claim involving WebMD, its parent, subsidiaries
and affiliates, licensors and suppliers, and their directors, officers,
employees, agents and contractors.

These Terms of Use are governed by the internal substantive laws of the State of
New York, without respect to its conflict of laws principles. If any provision
of these Terms of Use is found to be invalid by any court having competent
jurisdiction, the invalidity of such provision shall not affect the validity of
the remaining provisions of these Terms of Use, which shall remain in full force
and effect. No waiver of any of these Terms of Use shall be deemed a further or
continuing waiver of such term or condition or any other term or condition.

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16. COMPLETE AGREEMENT

Except as expressly provided in a particular "legal notice" on the Site, these
Terms of Use and the WebMD Privacy Policy constitute the entire agreement
between you and WebMD with respect to the use of the Site and Content.

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17. QUESTIONS, COMMENTS, OR REQUESTING ADDITIONAL INFORMATION FROM US

We allow you to communicate concerns or issues you may have about WebMD, the
Site, or our staff and we will provide you with understandable information. You
can receive more information about us upon request, including information
regarding:

 A. Our products, services, and programs;
 B. The qualifications of the staff that provides services to you; and
 C. The nature of any contractual relationships we have with third parties that
    provide services to you on our behalf.

We will also honor your right to decide not take part in, or to stop taking part
in any product, program, or service; however, your sponsoring organization may
impose material consequences as a result of your election not to take part in,
or to stop taking part in, products, programs, or services. Please check with
your sponsoring organization to determine if any consequences would apply before
making any such decision.

We will always treat you courteously and respectfully. We honor your rights, and
we want you to express your concerns or questions to us. Please call our
Customer Service Department toll-free at 1–800–488–3140 from 8:30 AM – 8:00 PM
Eastern Time, Monday through Friday.

Please note that with some types of issues, we are not allowed, by contract or
law, to tell you how the issue or concern was resolved, but, if permitted, we
will let you know at least that action is being taken. WebMD will attempt to
respond to your concerns or issues within two (2) business days and to provide a
plan for resolution within thirty (30) calendar days.

Questions or comments regarding the Site, including any reports of
non-functioning links, should be submitted using the 'Feedback' link or via
email to WebMD Office of Privacy at privacy@webmd.com.

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Thank you for your cooperation. We hope you find the Site helpful and convenient
to use!

© 2022. WebMD Health Services Group, Inc. All rights reserved.

Last updated: November 21, 2023



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