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Our Offerings
 * Wellbeing and Health
 * Turnkey Programme
 * Turnkey Solution
 * Configurable Solution
 * Partner Ecosystem

Why Virgin Pulse
 * For Employers
 * For Intermediaries
 * For Insurers


OUR DIFFERENTIATORS

 * Homebase for Health
 * Personalisation Engine
 * Activation + Engagement

Company
 * About Us
 * Press Releases
 * Science Advisory Board
 * Careers
 * Our Team
 * Locations

Resources
 * Resource Centre
 * Case Studies
 * Blog

 * Member Login
 * Request Info
   
   
   

Last Updated: June 30, 2022

The Virgin Pulse program (the “Program”) is a voluntary wellness program that
encourages healthy lifestyle changes. The Program is paid for by your employer,
your spouse’s employer or other sponsoring organization (the “Program Sponsor”)
and operated by Virgin Pulse, Inc., a corporation organized under the laws of
the State of Delaware, headquartered at 75 Fountain Street, Providence, Rhode
Island, 02902 (“Virgin Pulse”, “Us”, “We” or “Our”).

Virgin Pulse offers a number of wellness programs under different program names
including Engage, Ignite, VP Go, and CaféWell. This Privacy Notice applies to
all Virgin Pulse Programs unless there is a specific Privacy Notice published
for that program.

We are committed to protecting your rights and your privacy. This Privacy Notice
(the “Notice”) explains what data We collect about you and how We store, analyze
and share the data We collect about you through the platform
(www.virginpulse.com) and the Virgin Pulse mobile application. This Notice
applies to all Personal Information whether collected online or offline. The
Notice also explains your rights with regards to your data, and how to contact
Us to request access, corrections, transfer, restriction, or deletion of the
data We have collected about you.

We have designed this Privacy Notice in a question-and-answer format to make it
easy to read and understand. Please read through it carefully. If you do not
agree with Our policies and practices contained in this Notice, please do not
enroll in the Virgin Pulse Program.

Does Virgin Pulse collect information about me?

Yes. We collect anonymous and Personal Information about you to provide you with
the Program and Our services. “Personal Information” means any information,
including personal and material circumstances, that allows a person to become
identifiable. The Personal Information We collect includes, but is not limited
to:

 * Your contact information, including your first name and last name, home
   address, personal and business email addresses, and your phone number;
 * The email address you use to sign-in;
 * Your profile information, including your profile photo and background photo;
 * Your gender, date of birth and age;
 * Your social security number or employee identification number;
 * Biometric information such as your blood pressure or weight;
 * Information about your health;
 * Information about your fitness and related wellness activities offered within
   the Program;
 * Information about your participation and performance in the Program and
   related challenges;
 * Information you voluntarily share about yourself during any calls you
   participate in with Our health coaches;
 * Information you voluntarily share with Our Member Services team;
 * The comments and contributions you may make on the web-based platform or
   mobile application; and
 * Additional information you may provide as you submit queries and requests to
   Us.

Please keep in mind that the extent of the Personal Information you may be able
to share with Us will depend on the Program design and the features made
available to you, as well as your level of participation in the Program. You are
under no obligation to provide any Personal Information to Us at any time.
However, if you choose to withhold some Personal Information, We may be unable
to provide you with certain services.

How does Virgin Pulse use my Personal Information?

We will use the Personal Information collected only to provide you with access
to Our services, including:

 * To administer and manage the Program and corollary features, such as the
   Virgin Pulse Online Store;
 * To administer and manage your Virgin Pulse account and Membership;
 * To identify you when you enroll or sign-in;
 * To track your progress in the Program and, if applicable, track Program
   incentives and rewards;
 * To provide you with information about the Program and Program features;
 * To respond to your questions and requests; and
 * To provide appropriate security and confidentiality controls to protect your
   Personal Information.

Additionally, We may create “Anonymous Data” records by removing any Personal
Information (including any contact information) that would allow the remaining
data to be linked back to you. We may use the Anonymous Data for internal
purposes, such as analyzing patterns and Program usage to improve Our services.
Additionally, We may use Anonymous Data to analyze and understand demographic
trends, customer behavior patterns and preferences, and information that can
help Us enrich the content and quality of the Program.

How does Virgin Pulse communicate with me?

If you have opted to receive push notifications on your mobile device, We may,
from time to time, send you push notifications to provide you with reminders and
notices. If you no longer wish to receive such communications, you may turn them
off at the device level.

From time to time, We may send you e-mails, text messages or newsletters with
information about your Program, any available features, or related services.
Depending on your country of residence, you may be given the opportunity to
opt-in to receive Our communications as you enroll in the platform. Regardless
of your initial selection, you may opt-out of Our communications, free of
charge, at any time, by updating your preferences in your account profile
information, by contacting Member Services directly, or by responding STOP to
any text message.

Can Virgin Pulse contact me directly?

You may share your phone number with Us, or We may receive it from your Program
Sponsor or third party. If you are a US resident, by accepting the relevant
Membership Agreement for your Program, you are consenting to Us contacting you
directly, including, but not limited to, via phone, the use of an automated
telephone dialing system, prerecorded and/or artificial voice, SMS, MMS, text,
fax or other similar means, at any phone number included on your profile. You
may update your profile at any time to change where and how We contact you. See
the Membership Agreement for more information about text messaging terms.

What is the Waitlist?

If you are attempting to enroll in a VP Go Program, the Program may have limited
space for participants. Your Program Sponsor may make additional spaces in the
Program available after the start of the main challenge. To support that
process, We create a temporary list of names of individuals who wish to
participate in the Program but have not been able to because of lack of
available space (the “Waitlist”). If you added your Personal Information to the
Waitlist, you are not yet a Member, but the terms of this Notice will apply to
Our use of the information you provided for the Waitlist. We will only use the
Personal Information provided for the operation of the Waitlist and to notify
you if a space in the Program becomes available. The Waitlist will be purged
three days after registration formally closes and the Waitlist is no longer
needed. If you realize you entered incorrect Personal Information when you
joined the Waitlist, or wish to be removed from the Waitlist, please contact
Member Services.

How does Virgin Pulse collect my Personal Information?

We collect Personal Information you voluntarily provide as you submit it through
the web-based platform and the mobile application, by reviewing your use of the
web-based platform and mobile application (for example through the completion of
a health assessment), your use of a synched tracking device and when you
participate in Our phone or on-site services and events. Depending on the
Program design chosen by your Program Sponsor, We may collect Personal
Information through your use of additional services such as the Virgin Pulse
Activity Tracking Devices and the Health Stations (additional information on
these is provided below). We may also collect information about you and your
participation in the Program through engagement surveys. Depending on your
Program design, your Program Sponsor may have the opportunity to create surveys
(the “Virgin Pulse Surveys”) for its Members to complete.

We may also automatically collect additional information when you visit Our
web-based platform or mobile application, including the type of browser used,
the internet service provider (ISP), referring and exit pages, the files viewed
on Our site (e.g., HTML pages, graphics, etc.), date and time stamps of activity
on the platform, the accessing IP address (the unique address that identifies
your device on the internet) and the operating system your device uses. We use
this additional information to derive a broad, non-specific understanding of the
locations from which Our Members access Our services, and to enhance the
security controls around platform access. We also use it to analyze trends,
administer the web-based platform, track Members’ movements on the platform and
around the website, and to gather demographic information about Our Member base
as a whole.

What information do Virgin Pulse Surveys collect from me?

Depending on your Program design, your Program Sponsor may be able to create and
submit customized Virgin Pulse Surveys for its Members to complete. We do not
contribute to the creation of the questions in these surveys and do not review
the questions in these surveys. If you decide to take part in a Virgin Pulse
Survey the results will be shared with your Program Sponsor in aggregated
reports. Your Program Sponsor will not be able to identify you from these
reports. However, if the survey offered gives you the ability to respond to a
question by writing in a response, the response will be shared with the Program
Sponsor. If you include identifiable Personal Information in these open-ended
responses, your Program Sponsor may be able to identify you.

What information does Virgin Pulse collect through the health assessment?

Depending on your Program design, you may have access to a health assessment
questionnaire. Health assessments can be customized by Program Sponsors and may
be used to assess your overall health, your lifestyle across multiple areas of
wellbeing or both. You do not have to complete the health assessment if you do
not want to share this type of information with Us. Your responses to the health
assessments will help guide your personalized experience in the Program. Based
on your responses, the Program will recommend features and functions designed to
specifically help people with similar wellness needs and goals.

Does Virgin Pulse collect Personal Information about children?

As is explained in the Membership Agreement, the Program is designed for adults
over the age of 18, but minors as young as 16 may participate in the Program
under the supervision of a responsible adult.  We do not knowingly collect
Personal Information about children under the age of 13.  If you have reason to
believe that We have collected Personal Information about anyone under the age
of 13, you can contact Us to remove the Personal Information.

What are the activity tracking devices and how do they track my activity?

As a Program Member, you will be able to connect goal tracking devices, such as
smart watches, smart scales and other devices, to your account. If you choose to
synchronize a tracking device with the Program, We will receive limited
information about your activity to populate your account. Tracking devices can
track a wide number of different aspects of your daily activities, including,
among others, your daily steps and fitness activity, your heartbeat and sleep
pattern. Depending on the brand and model of tracker you use, the data collected
may vary. In general, companies selling tracking devices have specific privacy
policies available, which outline what data the specific activity tracking
device collects. We strongly suggest you review the right privacy notice to know
what specific data points your activity tracking device collects about you.

The Virgin Pulse activity tracking devices are the Max™ and the Max Buzz™. These
devices track your step activity per minute. From this information, We are able
to determine your total active fitness minutes and calories consumed.
Additionally, if you wear the Max Buzz to sleep, it can recognize the length of
your sleep from how long you lie still. You may choose to connect a personal
tracking device to transfer step data into the platform instead of using the Max
or the Max Buzz.

What are Health Stations and what information can I submit by using them?

Depending on the type of Program made available to you by your Program Sponsor,
you may have access to Health Stations. Health Stations are measurement tracking
stations that allow you to measure your blood pressure and weight and input that
information in the Program. Health Stations may be located, for example, in your
office. Depending on your Program, you may receive access to Health Stations in
your area at no additional cost. Your use of Health Stations is voluntary.

Does Virgin Pulse receive information about me from other sources?

Yes. We may receive information about you from various sources to support the
Program and services included in it. The sources may include:

Your Program Sponsor

Depending on your Program design, your Program Sponsor may provide Us your
Personal Information to identify you as an individual who is able to join the
Program and become a Member. We call this an “Eligibility File”. Please contact
your Program Sponsor directly if you wish for your Program Sponsor to stop
sending Us information about you. Keep in mind that if you are removed from the
Eligibility File you will no longer have access to the Program and will not be
able to enroll in the Program.

Other Benefits Providers Hired by your Program Sponsor

In some cases, your Program Sponsor may offer benefits through other providers
that integrate with the Program.  At the direction of your Program Sponsor, We
may exchange data with these other providers to provide Our services to you.  We
may send them information, such as an employee ID, identifying who you are. They
may send Us information about you specifically related to participation in the
Program, either before or after you begin participating in the Program.

The Virgin Pulse Program Partners

Depending on your Program design, you may have access to organizations through
Our Program that partner with Us to provide you (a) biometric or lab testing
services or (b) additional health and related services (Our Program Partners).
If you use these services, the Program Partners may share activity information
and results with Us. This data sharing would be limited to information necessary
to support your wellness goals or manage incentives in the Program.

Your Healthcare Provider

With your prior approval, We may receive healthcare-related information from
your healthcare provider and any clinics or organized care facility with which
your provider is associated.

Your Insurance Provider

At the direction of your Program Sponsor, your health insurance provider may
share claims-related information with Us. We may use this claims-related
information (a) to generate aggregate reports to help the Program Sponsor
customize an effective Program based on the specific needs of its member base,
(b) to recommend specific health and wellness objectives that would be most
effective for you, and (c) to help identify effective health and wellness
objectives based on changes to your claim history.

Claims Clearinghouse Providers

In the US, we offer an insurance claims navigation feature. Healthcare
clearinghouses aggregate insurance claims information from multiple sources. If
your Program Sponsor has enabled this feature, we may collect information from
healthcare clearinghouses to provide you access to your health insurance claims
through our Program.

Public Databases

We may receive information about you from other sources including publicly
available databases or third parties from whom We have purchased data. We
combine this data with information We already have about you. We may also
combine publicly available aggregated census and demographical data with your
Personal Information. This can help Us analyze Our records to better evaluate
the effectiveness of Our services.

Examples of the types of Personal Information that We may obtain from public
databases include:

 a. Address information about you from third-party sources, such as the U.S.
    Postal Service, to verify your address before We send you mail or fulfill
    orders from the Virgin Pulse Online Store;
 b. The U.S. Federal Do Not Call registry, to verify do not call preferences
    recorded there;
 c. Census and other aggregate data sources containing statistical information
    about people who share some of your traits and demographic markers.
 d. Databases we have licensed from authorized data aggregators to improve the
    accuracy of our records and to enhance our ability to deliver relevant
    information to you on behalf of our clients.

What Tools does Virgin Pulse use to Collect my Personal Information?

Virgin Pulse, its Program Partners and vendors use tools such as Cookies, tags,
scripts and other similar technologies to enhance and support your experience on
the platform. These technologies help Us administer the web-based platform and
mobile application, measure traffic patterns and the total number of users, as
well as to personalize and customize the platform’s content, so that your
settings are “remembered” when you login.

“Cookies” are small pieces of text sent to your browser by a website you visit.
Cookies help Our web-based platform to remember information about your visit,
like your preferred settings. Cookies play an important role, they can make your
next visit easier and the web-based platform more useful to you. You can learn
more about Cookies by visiting www.allaboutcookies.org, where you will also find
information about how to block Cookies on different types of browsers. Depending
on your location, additional information about Cookies may be presented to you
when you visit the web-based platform, and you are given the opportunity to
object to the use of Cookies. However, please be aware that by blocking or
deleting Cookies you may not be able to take full advantage of the web-based
platform or mobile application.

Our web-based platform uses Cookies to collect information about Member usage of
the Program. Additionally, some Cookies on Our web-based platform are set by
third parties who are delivering services on Our behalf. Within the mobile
application, webpages are sometimes displayed. Cookies allow you to avoid having
to reenter your login credentials when accessing webpages. You can manage your
cookie preferences on our website by clicking here (ADD LINK). 

We use Cookies:

 * To remember that you have used the website before, allowing Us to identify
   you, as well as the number of unique visitors We receive and manage capacity;
 * To allow you to navigate the website more quickly and easily;
 * To remember your log-in session as you move from one page to the next within
   the platform;
 * To store your settings and preferences;
 * To customize some aspects of the platform to reflect your interests and
   preferences; and
 * To collect statistical information about how you use the website, allowing Us
   to improve Our services over time.

Does Virgin Pulse use mobile analytics?

We use mobile analytics software to allow Us to review the functionality of Our
mobile software on your phone, and how to improve its quality and Our services.
The mobile analytics software may record information such as how often you use
the mobile application, the events that occur within the mobile application,
crash reports and performance data, where the application was downloaded from
and other metrics, such as aggregated usage. The information collected by the
mobile analytics software is managed separately from other Personal Information
you submit within the mobile application.

Are there links to third party websites and mobile applications on the Virgin
Pulse platform or mobile application?

Our web-based platform and mobile application may contain links to other
websites that We do not own or control. We provide these links and connections
for your convenience. We have no control over these third parties, their privacy
policies, and the content they display on their websites or mobile applications.
If you choose to submit Personal Information while visiting these websites or
using these mobile applications, please be aware your rights will be governed by
the third parties’ privacy policies. We strongly encourage you to carefully read
the privacy notice of any website or mobile application you visit or use.

Who at Virgin Pulse has access to my Personal Information?

We rely on role-based access and only grant access to Our employees, contractors
and agents who are involved with delivering the Program services to you
according to Our policies and procedures. As a global company, We have a number
of offices and subsidiaries around the world. We have office locations or
subsidiaries in the United States, the United Kingdom, Canada, Bosnia,
Switzerland, Singapore and Australia. Our employees at these locations may be
required to access your Personal Information to provide you with quality
services, including Member Services through the Virgin Pulse Call Center. Our
employees are obligated to respect the confidentiality of your Personal
Information and are only authorized to access your Personal Information as
necessary to provide you with services or support. Examples of the employees who
have access to your Personal Information include Our member services staff, Our
wellness coaching staff, billing staff and Our data reporting staff.

Can other Members or my Program Sponsor view my Virgin Pulse profile?

You can become “Friends” with other members of the Program offered by your
Program Sponsor. You are able to send “Friend” requests to other Members taking
part in your Program, and they will be able to send you “Friend” requests. You
can choose to accept or decline these “Friend” requests. You can also choose to
remove a “Friend” any time after adding him or her. If you become “Friends” with
another Member, that person will have access to (a) certain portions of your
profile, (b) the number of steps you have taken in challenges you choose to
participate in, and (c) other activity data related to your participation in the
Program.

By joining a challenge, your name, profile picture (if you add one) and
challenge performance information (step information added to your account) will
be visible to other Members in the Program. Additionally, some performance
information such as a leaderboard may be shared with your Program Sponsor on an
individual or team basis.

Additionally, the Program may make message boards and messaging forums available
to you. Please be aware that any information disclosed in these settings may
become public information. You should exercise caution if disclosing Personal
Information while using these features.

Does Virgin Pulse disclose or share my personal information with my Program
Sponsor?

The type of information We share with your Program Sponsor depends on who your
Program Sponsor is.  In general, across all types of Program Sponsors, We share
anonymized and aggregated data with your Program Sponsor. Your Program Sponsor
will not be able to use such anonymized or aggregated data to directly identify
you. Your Program Sponsor may use the anonymized information in its discretion,
including to evaluate the overall program, as well as to provide additional
benefits, programs and services.

In specific circumstances and for limited purposes, such as to ensure proper
Program administration or to support tax compliance, We may share reports
containing identifiable information with your Program Sponsor. In these
circumstances, We limit the Personal Information to the least amount necessary
to support the specific, necessary purpose.

If your activity information indicates there may be an abnormality or Program
abuse, We may share your activity information with your Program Sponsor and make
adjustments, or suspend or terminate your account, in accordance with your
Program Sponsor’s instructions.

Medical care providers

When your Program Sponsor is also your medical care provider, We may share your
Personal Information, including detailed health and wellness related
information, to facilitate treatment activities.

Health Insurance Providers

If your Program Sponsor is your Health Plan, We may share additional information
about you and your participation in the Program, to ensure you are provided
access to any additional services or engagement opportunities and benefits that
may be offered through your Health Plan.

Coaching Providers

Some Program Sponsors hire their own wellness coaches who use Our systems to
deliver their coaching services. These coaches are employees of the Program
Sponsor and are subject to their own privacy notice. We may share Personal
Information with these coaches as necessary for them to provide wellness
coaching services directly to you. If you are unclear about whether your
wellness coach is a Virgin Pulse employee or employed by your Program Sponsor,
you can ask your coach.

Does Virgin Pulse disclose or share my Personal Information to third parties?

We may, from time to time, share your Personal Information with third parties to
allow Us to provide you with Our services. If We need to share your Personal
Information with third parties, We will limit the information disclosed to the
minimum amount necessary to ensure the provision and quality of the services We
offer you. We never use, disclose, or share your Personal Information collected
through the Program for third-party marketing purposes, and We never sell, rent
or lease your Personal Information to third parties. At the request of your
Program Sponsor, we may combine Personal Information from third-party databases
with Personal Information from the Program to deliver you targeted messages
related to the Program. This may be deemed to constitute a sale of Personal
Information under certain laws. Subject to any limitations imposed by applicable
laws, We reserve the right to disclose Anonymous Data at Our discretion.

With respect to personal data received or transferred pursuant to the Privacy
Shield Framework, Virgin Pulse is subject to the regulatory enforcement powers
of the U.S. Federal Trade Commission.  In certain situations, Virgin Pulse may
be required to disclose personal data in response to lawful requests by public
authorities, including to meet national security or law enforcement
requirements.

In the event that We (a) undergo reorganization or liquidation under bankruptcy,
or (b) are sold to a third party, any Personal Information We hold about you may
be transferred to the reorganized entity or third party, in accordance with
applicable laws. In any such event, the new entity will continue to use your
Personal Information in accordance with and within the limits of this Notice to
ensure continuation of service.

Who else does Virgin Pulse disclose my Personal Information to?

Benefits Distributors and Aggregators

Your Program Sponsor may have engaged Our services through a distributor or
aggregator service. If directed to do so by your Program Sponsor, We may share
limited amounts of Personal Information with these services related to your
participation in the Program to facilitate coordination of services across
multiple health and wellness providers.

Third Party Providers

We may use or disclose your Personal Information to allow your participation in
additional third-party provided wellness services or to support the
administration of the Program. These third parties may be Our partners (“Program
Partners”), your Program Sponsor, or other entities your Program Sponsor
contracts with directly (“Third Party Providers”).

We may provide information in an anonymous and aggregated format or provide your
Personal Information in a group format to third parties that process that
Personal Information (“Analytics Processors”) to generate Anonymous Information
and derive analytical information. The Analytics Processors do not have any
independent right to use your Personal Information, except to provide the
aggregation and analysis services.

Our Program Partners are industry leading health, wellness and wellbeing
providers We select to enhance your experience. In certain instances, the use of
such Program Partners may require you to provide additional Personal Information
and data to these Program Partners. If you choose to use Program Partner
services or you provide additional Personal Information and data to these
Program Partners, you will be subject to the Program Partner’s privacy notice
and terms of use. You can see a list of these partners for your Program by
selecting Devices & Apps from under your profile picture in Our application.

Government entities

We may be required to disclose your Personal Information if:

 a. Legally required to do so by governments, tribunals, law enforcement and
    regulatory agencies (for example as part of an ongoing investigation,
    subpoena, similar legal process or proceeding);
 b. As otherwise required under any applicable law, regulation, or rule; and
 c. If We believe, in good faith, that such disclosure is necessary to protect
    or defend Our rights or the rights of others, to assist in an investigation
    or to prevent illegal activity.

Why may Virgin Pulse disclose my Personal Information?

From time to time We may need to disclose limited amounts of your Personal
Information. We limit Our disclosures to the least amount of information
required to meet the permissible purpose. We disclose your Personal Information
for the following limited purposes:

 * At your request to whomever you direct Us to disclose the information;
 * To administer the Program, services and the Virgin Pulse Online Store;
 * To coordinate enrollment in additional services made available to you;
 * To enhance your Program experience;
 * To provide you with information about the services available to you through
   the Program and platform or provided to you by a Program Partner or a
   Third-Party Provider;
 * To ensure that you receive appropriate rewards for participation in Our
   services and other similar services provided by your Program Sponsor or
   Third-Party Providers;
 * To evaluate the overall quality and effectiveness of the program(s) you may
   participate in;
 * To conduct in depth analytics about the Program;
 * To assess your eligibility for other programs that your Program Sponsor or
   Third-Party Providers may offer; or
 * To comply with applicable laws.

Where and how is my Personal Information and other data stored?

All your data, including any Personal Information We collect about you, is
stored at Amazon Web Services data centers located in the United States of
America (USA). Because your data is stored on USA soil, it may be subject to USA
laws, including the “Uniting and Strengthening America by Providing Appropriate
Tools Required to Intercept and Obstruct Terrorism Act of 2001” (USA PATRIOT
Act), as well as the jurisdiction of the USA government, tribunals, law
enforcement and regulatory agencies, which may require Us to grant them access
to your data. In some limited circumstances, We may store Eligibility Files for
some of Our EU based clients at Amazon Web Services data centers located in the
EU.

How does Virgin Pulse secure my Personal Information?

We are committed to protecting your data and your privacy. To ensure data
security, We follow reasonable physical, electronic and managerial procedures
designed to safeguard and secure your data and Personal Information. However, no
company can fully eliminate security risks associated with the provision of
online services.

Among the security features We use to protect your Personal Information and
other data, We require that you create and use a username and unique password to
access the web-based platform and mobile application. We use multiple layers of
security to protect your Personal Information and data, including firewalls,
intrusion detection tools and antivirus software.

How does Virgin Pulse protect my Personal Information during transfers with
authorized parties?

When We receive Personal Information from a third party, or share Personal
Information with a third party, We execute appropriate written agreements based
on the applicable jurisdiction.  For example, We execute EU approved standard
contractual clauses with EU-based Program Sponsors that send Us Eligibility
Files as the data importer, as that term is defined in the GDPR.  We also
execute EU approved standard contractual clauses with Our subcontractors that
assist us in processing EU based data, as the data exporter.

Virgin Pulse is responsible for the processing of personal data it receives and
subsequently transfers to a third party acting as an agent on its behalf, under
the Privacy Shield Framework. Virgin Pulse complies with the Privacy Shield
Principles for all onward transfers of personal data from the EEA, the United
Kingdom and Switzerland, including the onward transfer liability provisions.

What data protection rights do I have?

Various laws from around the world establish varying levels of data subject
rights. At Virgin Pulse We strive to provide a similar level of data rights to
all Our members, regardless of where they live, but some of those rights are
governed by local laws.  In addition to the basic rights of confidentiality,
those rights include:

 * ·       The right of access, explained in more detail below.
 * The right to amend or change your data, explained in more detail below.
 * The right to transfer your data to another provider, explained in more detail
   below.
 * The right to delete your data, also called the right to be forgotten,
   explained in more detail below.
 * The right to object to processing activities, explained in more detail below.
 * The right to restrict processing activities, explained in more detail below.
 * The right to submit data protection related complaints to Us and to relevant
   government agencies, as referenced above.
 * The right to opt out of selling your data, explained in more detail below.

You can use Our online data management tool, available on your profile page, to
submit data subject rights requests.

Can I access or change the Personal Information Virgin Pulse has collected about
me?

Yes, you can review and change your Personal Information by logging into the
platform or mobile application. All Our Members, regardless of residency, except
in specific circumstances identified by local laws, have a legal right to access
and correct or update the information We have collected about you. You can also
request a copy of all the Personal Information and data We hold about you. We
will provide you with a copy of all the data We have collected about you in a
standard format (such as Excel) through a secure channel. You can contact Us to
request a copy of all your Personal Information or to request a change in your
Personal Information through the “Data Requests” option in the platform or
mobile application. We will respond to your request within a reasonable
timeframe.

Please keep in mind that We may not be able to accommodate your request if We
reasonably believe the change would violate any laws or cause the information to
be inaccurate or incorrect. Additionally, We may not be able to fulfill a
request where it would impose a burden on Us that is disproportionate to the
risk to your privacy, or where your request may affect another individual’s
rights to privacy. If We are unable to fulfill a request, We will provide you
with the reasons why We are unable to comply.

Can I request that my Personal Information and other data be transferred to a
different company?

Yes, you can request that all your Personal Information and other data be
transferred to a different wellness services provider. To complete the transfer,
We will require additional information about the new vendor to ensure a secure
channel is used, so that your Personal Information and other data remain
protected. Depending on the circumstances, We may be unable to support a
transfer. However, We will be able to provide you with your Personal Information
which you will be able to disclose to anyone you choose. To request such
transfer, you may contact Us through the “Data Requests” option in the platform
or mobile application. We will respond to your request within a reasonable
timeframe.

Can I request that my Personal Information and data be deleted from Virgin Pulse
databases?

Yes, you can request that We delete your identifying information from Our
system. You may terminate your Program Membership at any time by submitting a
deletion request to Our Member Services team, or through the “Data Requests”
option in the platform or mobile application. Your Membership will terminate
[$pending_cancellation_duration$] days after We receive your request. We will
delete your identifying information We collected from your participation in the
Program permanently and irreversibly at the end of an additional
[$deidentification_duration$] day grace period.

Following your deletion request, We may still receive some information about you
on your Program Sponsor provided Eligibility Files or in the claims-related
information discussed earlier in this Notice. To remove your information from
these sources you will need to submit that request directly to your Program
Sponsor.

Your Personal Information will also be permanently and irreversibly
deidentified, in accordance with the timelines above, once the Program ends and
your account is cancelled in accordance with the terms of the Membership
Agreement. You will not be able to claim any incentive rewards after We
terminate your Membership.

Can I request that Virgin Pulse restrict processing for some of my data?

Beyond the information necessary for enrollment, you are not required to share
any additional information with Us, however, choosing not to share information
may limit your ability to earn Rewards if they are made available to you by your
Program Sponsor. You can choose to limit the data you share with Us by not
inputting or not using certain features. However, once you have shared
information, We are unable to accommodate requests to restrict the processing of
certain sets of data. If you wish for Us to stop processing parts of your data,
you can request that all data be deleted by cancelling your account.

Can I object to Virgin Pulse’s processing of my data?

Yes, you can object to Our processing of your data by contacting the Privacy
Officer and notifying Us that you wish for your account to be suspended while
your concerns about the processing of your data are resolved. Once you feel
comfortable resuming use of the Program, you can contact Us to unlock your
account. If you realize during the time your account is suspended that you do
not feel comfortable resuming use of the Program, you can cancel your account.
Your data will be deleted in accordance with Our standard process, except that
you will not be able to access your account while the cancellation process takes
place unless you first request for the suspension to be lifted.

Can I opt-out of Virgin Pulse selling my Personal Information?

Virgin Pulse recognizes that you may have a right to opt-out of any “sale” of
your Personal Information.  In the US we may combine Personal Data from
third-party databases with our communications services in a way that could be
deemed a sale of personal data under applicable laws. If you would like to opt
out of any activity that could be deemed a sale under applicable laws, please
use our Individual Data Rights Request form to submit the request.

How does Virgin Pulse make changes to this Privacy Notice?

We may update this Notice from time to time to reflect changes in Our
information practice and services offered. If We make any material changes to
this Notice, you will be notified via an update notification, and you will be
given the opportunity to review and accept the new Notice prior to being able to
access the platform or continue to use the Program. The date indicating the last
update can be found at the top of the Notice. If there are typographical
mistakes, like grammar or spelling errors, in the Notice We may correct them
without notifying you.

What should I do if I have a concern or complaint against Virgin Pulse and its
data privacy practices?

If you have an unresolved privacy or data use concern that We have not addressed
satisfactorily, please contact Our U.S.-based third party dispute resolution
provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website,
you may be entitled to invoke binding arbitration when other dispute resolution
procedures have been exhausted.

What laws, regulations or frameworks does Virgin Pulse comply with?

We comply with any applicable laws and regulations based on the geographical
location you select. You are asked to input your country and, if applicable
state, of residence during enrollment. Any discrepancy between your true
residence and the information disclosed to Us, and how that may affect the
functionality of the platform, remains your responsibility.

The level of data protection established in the USA is generally lower than the
one established in the European Union (EU) and other countries with data
protection laws similar to the EU; therefore, We take measures to ensure that
your Personal Information is stored safely with Us, meeting regulatory privacy
and security requirements imposed on EU businesses. Nothing in this Notice
limits or attempts to limit your rights under applicable laws, including your
ability, depending on your country of residence, to file a complaint with your
local Data Protection Authority.

Virgin Pulse participates in and has certified its compliance with the EU-U.S.
Privacy Shield and Swiss-U.S. Privacy Shield Framework, as set forth by the U.S.
Department of Commerce regarding the collection, use and retention of Personal
Information from the European Economic Area, the United Kingdom, and Switzerland
to the United States. Virgin Pulse is committed to subjecting all personal data
received from European Economic Area (EEA) member countries, the United Kingdom
and Switzerland to the Framework’s applicable Principles.  To learn more about
the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy
Shield website. Click to view and learn more about Our certification. With
respect to personal information received or transferred pursuant to the Privacy
Shield Framework, Virgin Pulse is subject to the regulatory enforcement powers
of the U.S. Federal Trade Commission.  In certain situations, Virgin Pulse may
be required to disclose personal information in response to lawful requests by
public authorities, including to meet national security or law enforcement
requirements.

As a result of the decision of the Court of Justice of the European Union in
Case C-311/18 (“Schrems II”) on July 16, 2020, the EU-U.S. Privacy Shield
Framework is no longer suitable as a mechanism to ensure the lawfulness of
transfers of Personal Data from the EEA, UK and Switzerland to the US.  We
maintain adherence to this Framework as required to maintain Our Privacy Shield
certification, and particularly with regard to personal data already transferred
from the EEA, UK or Switzerland to the US. We continue to ensure the lawful
transfer of personal data from the EEA, UK and Switzerland to the US through
alternative mechanisms such as the Standard Contractual Clauses, as approved by
the European Commission. These were not invalidated by the decision of the Court
of Justice of the European Union as a lawful transfer mechanism. We are
monitoring the situation as it develops and will update this information with
any amendments needed to remain compliant.

Virgin Pulse’s privacy practices, described in this Privacy Notice, comply with
the APEC Cross Border Privacy Rules System. The APEC CBPR system provides a
framework for organizations to ensure protection of personal information
transferred among participating APEC economies. For more information about the
APEC framework, please download and review this document.

Virgin Pulse also complies with the California Consumer Privacy Act (CCPA) and
similar state laws. If you are California Resident, please see our Supplemental
Privacy Notice for California Residents.

Which Translation of the Virgin Pulse Privacy Notice is the Official Version?

Please note that any translation of this Notice is intended solely to facilitate
your access to this information. The English version is the only official
version of this Notice, and any translation inaccuracies or discrepancies are
not binding and have no legal effect for compliance or enforcement purposes.

How can I contact Virgin Pulse or its Data Protection Officer (DPO)?

If you have general questions about your Program, you can contact Member
Services by calling 1-888-671-9395 (in the US) or by sending an email
to support@VirginPulse.com.

If you have any questions, comments or concerns, about this Notice, or your
rights and obligations under this Notice, you may contact Us via email
at PrivacyOfficer@VirginPulse.com or via the “Contact Us” section of the Virgin
Pulse web-based platform and mobile application.

Alternatively, you can contact Us by writing to:

Virgin Pulse, Inc.

Attn:  Privacy Officer

75 Fountain Street

Providence, Rhode Island 02902

United States

Representation for data subjects in the EU

We value your privacy and your rights as a data subject and have therefore
appointed Prighter as Our privacy representative and your point of contact.

Prighter gives you an easy way to exercise your privacy-related rights (e.g.,
requests to access or erase personal data). If you want to contact us via Our
representative Prighter or make use of your data subject rights, please
visit: https://prighter.com/q/12992072071


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