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PRIVACY

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TABLE OF CONTENTS

I. WebMD's Commitment to Privacy Protection
II. What Personal Information and/or Personal Health Information does WebMD
collect from you?
   A. Registration
   B. WebMD Tools
III. "Cookies" and "Web Beacons" and How They Are Used
IV. Mobile Device Applications ("Apps")
V. How does WebMD use and disclose personal information?
   A. Disclosure to and use by CIGNA
   B. Personal Health Manager Home Page
   C. Concept Unique Identifiers
   D. Aggregate Data
   E. Data Warehouse Analysis
   F. Interactive Tools
   G. Personalized Emails/Messages
   H. Disclosure to WebMD Contractors
   I. Third Party Contractor Websites
   J. Disclosure to Linked Sites
VI. What are your privacy choices as a user of WebMD tools?
   A. Changing information
   B. Account Deletion and Removal of Your Personal Information
   C. Limitations on removing or changing Information
VII. How does WebMD protect Personal Information?
VIII. Changes to the WebMD Privacy Policy
IX. WebMD's Tools are Intended for Adults
X. Questions
XI. California Privacy Rights
XII. Glossary



THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU AND YOUR DEPENDENTS MAY
BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE
REVIEW IT CAREFULLY.

BY USING THE SERVICES PROVIDED BY THIS PORTAL, YOU ACCEPT THE TERMS OF THIS
PRIVACY POLICY. YOU MUST NOT ALLOW ANY OTHER PERSON TO ACCESS THIS PORTAL UNLESS
THAT PERSON IS YOUR DEPENDENT AND YOU OBTAIN THEIR AGREEMENT TO THE TERMS OF
THIS PRIVACY POLICY. CERTAIN CAPITALIZED TERMS USED IN THIS PRIVACY POLICY ARE
DEFINED AT THE END OF THIS POLICY.

PLEASE NOTE THAT PERSONAL HEALTH INFORMATION ("PHI") PROVIDED BY YOU WILL NOT BE
USED OR DISCLOSED BY WEBMD WITHOUT YOUR AUTHORIZATION EXCEPT AS PROVIDED BY THIS
PRIVACY POLICY OR EXCEPT AS DIRECTED BY CIGNA IN ACCORDANCE WITH THE TERMS OF
THE NOTICE OF PRIVACY PRACTICES FURNISHED BY CIGNA OR YOUR PLAN SPONSOR.

PLEASE NOTE THAT PHI ABOUT YOU OR YOUR DEPENDENTS THAT YOU FURNISH TO WEBMD MAY
BE DISCLOSED TO CIGNA AND USED BY CIGNA AS DESCRIBED IN THE NOTICE OF PRIVACY
PRACTICES FURNISHED TO YOU BY CIGNA OR YOUR PLAN SPONSOR. FOR EXAMPLE, AT THE
DIRECTION OF CIGNA, WEBMD MAY DISCLOSE YOUR PHI AND THE PHI OF YOUR DEPENDENTS
TO CIGNA'S OR YOUR PLAN SPONSOR'S DISEASE MANAGEMENT VENDOR FOR DATA ANALYSIS AS
PART OF HEALTH CARE OPERATIONS.




WebMD, LLC (the WebMD Health Manager or The WebMD Tools) is a licensee of the
TRUSTe Privacy Program and complies with the U.S.-EU Safe Harbor framework and
the U.S.-Swiss Safe Harbor framework as set forth by the U.S. Department of
Commerce regarding the collection, use, and retention of personal information
from European Union member countries and Switzerland. WebMD has certified that
it adheres to the Safe Harbor Privacy Principles of notice, choice, onward
transfer, security, data integrity, access, and enforcement. To learn more about
the Safe Harbor program, and to view WebMD's certification, please visit
http://www.export.gov/safeharbor/



TRUSTe is an independent organization whose mission is to build user's trust and
confidence in the Internet by promoting the use of fair information practices.
This privacy statement covers the Web sites ("Web site") that have a link to
this privacy statement. Because this Web site wants to demonstrate its
commitment to your privacy, it has agreed to disclose its information practices
and have its privacy practices reviewed for compliance by TRUSTe.


I. WEBMD'S COMMITMENT TO PRIVACY PROTECTION

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WebMD is committed to protecting your privacy online. In order to deliver
personalized and clinically relevant information to users of our tools, we ask
you to provide us with certain information. The purpose of this privacy policy
is to describe our information practices to you and to let you know that when
you use our tools, you accept the practices described in this privacy policy. In
particular, this privacy policy describes:

 * What Personal Information and Personal Health Information we may collect from
   you or your dependents;
 * What "cookies" and "web beacons" are and how they are used;
 * How we use personal information of you and your dependents;
 * What relationships WebMD has with third parties and how they relate to you;
 * How you can access, update, or delete information;
 * What choices are available to you regarding collection, use and distribution
   of your information and information about your dependents;
 * How WebMD protects Personal Information about you and your dependents; and
 * How WebMD may change this Privacy Policy

As a further commitment to protecting your privacy online, WebMD has been
awarded e-Health accreditation from URAC, the American Healthcare Accreditation
Association. In addition, WebMD is a licensee of the TRUSTe Privacy Program and
complies with the principles of the HON Code of Conduct established by the
Health on the Net Foundation. These organizations assist our efforts to protect
your privacy. You can receive a printed copy of this policy or any part of your
personal record by clicking on the Print option under File on your browser.


II. WHAT PERSONAL INFORMATION AND/OR PERSONAL HEALTH INFORMATION DOES WEBMD
COLLECT FROM YOU?

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A Personal Health Manager Home Page is created for you specifically by WebMD and
is accessible only by the assigned user or someone authorized by you. Only the
assigned user of a Personal Health Manager Home Page can grant access to other
authorized users. This Portal may receive Personal Information directly from you
or from a Third Party. You may gain access to a WebMD Tool through the Portal
and this mode of access has some bearing on the information that is collected
from you.

A. REGISTRATION

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No matter how you arrive at a WebMD Tool, the Tool requires certain information
as part of the user registration process, such as your name, email address and
date of birth. Each time you enter Personal Health Information into one of
WebMDs Tools, WebMD uses that information to provide you with personalized and
clinically relevant information via a Personal Health Manager Home Page and
throughout the WebMD Tools. The user controls and authorizes who can gain access
to this page.

B. WEBMD TOOLS

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In addition to the information that we collect during the registration process,
some of our tools request you to provide us with you or your dependents'
Personal Health Information. You may choose not to provide certain information
to us but that may limit the usefulness of WebMD's Tools.


III. "COOKIES" AND "WEB BEACONS" AND HOW THEY ARE USED

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The Portal uses "Cookies" and "Web Beacons." WebMD collects non-Personal
Information about your use of the Portal through the use of Cookies and Web
Beacons. Every computer is assigned a different Cookie by WebMD. The information
collected by Cookies and Web Beacons (i) helps WebMD dynamically generate
content on web pages or in newsletters, (ii) allows WebMD to statistically
monitor how many people are using the web site, (iii) allows WebMD to determine
how many people open our emails, and (iv) helps WebMD determine for what
purposes these actions are being taken. WebMD may use Cookie information to
determine the popularity of certain content. Cookies are also used to facilitate
your login and serve as navigation aides and session timers. Cookies used by the
WebMD Tools are also used to restrict use of the WebMD Tools by people who are
underage. Our Web Beacons are not used to track your activity outside of our web
sites. You may set your browser to reject Cookies and/or Web Beacons, but if you
do so, you will limit the usefulness of the WebMD Tools.


IV. MOBILE DEVICE APPLICATIONS ("APPS")

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Use of any of our Apps, as with all of our Tools, requires registration through
the registration process described above. Information that we receive through
the use of any of our Apps, including, but not limited to, the number of times
that you use the App and information that you submit, is subject to the terms of
this Privacy Policy. When you download and install one of our Apps onto your
mobile device, we assign a unique number to your App installation which we use
to identify you for certain App functionality (including identifying you for App
to App communications between you and other users of the App). We do not obtain
any information about your mobile device, other than the brand, make and model
and type of operating software your device uses.

WebMD's Apps ask for your consent (via an opt-in) before using information from
pin-pointing technology like GPS or cell tower information. You can withdraw
your consent (opt-out) for the use of "location" by WebMD at any time by
changing your location services in the "Settings" function on your mobile
device.


V. HOW DOES WEBMD USE AND DISCLOSE PERSONAL INFORMATION?

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A. DISCLOSURE TO AND USE BY CIGNA

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WebMD may provide to CIGNA Personal Information and Personal Health Information
relating to you or your dependents that you furnish to WebMD so that CIGNA may
use this information for (i) administration of the health and welfare employment
benefit plans offered by your plan sponsor, (ii) offering and providing benefit
information and health information to you or your dependents, (iii) offering and
providing health management programs and services to you or your dependents,
(iv) offering and administering rewards application programs and (v) conducting
quality assurance activities. If you are participating in an incentive program,
CIGNA may notify the program administrator (who may be your employer) of your
participation. CIGNA may provide Personal Information and Personal Health
Information relating to you or your dependents that you furnish to WebMD to
third parties who assist CIGNA or your plan sponsor in the performance of these
services or to other third parties, at the request of your plan sponsor, to
administer other aspects of your health and welfare employment benefit plans.
Those third parties selected by CIGNA have appropriate agreements in place with
CIGNA limiting their use and disclosure of this Personal Information and
Personal Health Information to a manner consistent with the uses permitted by
CIGNA.

B. PERSONAL HEALTH MANAGER HOME PAGE

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Each time you enter your Personal Health Information into one of WebMDs Tools,
WebMD uses that information to provide you with personalized and clinically
relevant information via your Personal Health Manager Home Page.

C. CONCEPT UNIQUE IDENTIFIERS

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WebMD may use Personal Health Information to create a Personal Health Manager
Home Page. In order to construct that site, WebMD will use concept unique
identifiers. WebMD tailors the information you receive on your Personal Health
Manager Home Page to reflect your individual interests, concerns and personal
health characteristics. We attach a concept unique identifier (CUI) to every
piece of information that you provide us. For example, if medical claims data
that is imported into your Personal Health Manager indicates you have diabetes,
that single piece of information is tagged with a CUI that is specific to
diabetes. Each time you view your Personal Health Manager Home pages, the CUI
tag is matched to content related to Diabetes, and if WebMDs algorithms
determine that this is likely to be an important topic to you, it will appear on
your personalized pages.

D. AGGREGATE DATA

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WebMD may combine, in a non-identifiable format, the health information you
provide with health information from other users to create aggregate data that
may be disclosed to third parties. Aggregate data does not contain any
information that could be used to contact or identify you or your dependents.
WebMD will not disclose Personal Health Information about you or your dependents
to any third party without your prior authorization.

E. DATA WAREHOUSE ANALYSIS

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Upon authorization of CIGNA or your health plan sponsor, WebMD may send your
Personal Health Information in a form that cannot be used to personally identify
you or your dependents to a data warehouse for analysis of health trends and
effectiveness of health programs. We require these data warehouses to agree that
they will not attempt to make this information personally identifiable, such as
combining it with other databases.

F. INTERACTIVE TOOLS

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WebMD Tools may gather self-reported Personal Health Information. In addition,
certain of these Tools can store Personal Health Information coming from third
party data interchange agreements between your health plan sponsor, your health
plan, pharmacy benefits manager and other third parties that provide data
interchange services. We maintain and limit use of that information to the
Opt-in you have provided at the time you use the Tool.

G. PERSONALIZED EMAILS/MESSAGES

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WebMD has the ability to use the Personal Information that you provide to send
you personalized emails or electronic messages. During registration, you have
the option of choosing whether you receive emails pertaining to your health
interests, including news, announcements, reminders and opportunities. The
service requires an "Opt-in" authorization from you. If you decide, after having
"Opted-in" for email or electronic messaging, that you would prefer not to
receive them, you may opt-out of the service by clicking on the settings tab on
your Personal Health Manager Home Page and changing your email preference.

H. DISCLOSURE TO WEBMD CONTRACTORS

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

I. THIRD PARTY CONTRACTOR WEBSITES

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Certain content and services offered to you through the Portal are served on
websites hosted and operated by a company other than WebMD ("Third Party
Contractor Websites"). WebMD Health does not disclose Personal Information about
you or your dependents to these Third Party Contractor Websites without your
consent, but you should be aware that any information you disclose once you
access these other websites is not subject to this Privacy Policy. WebMD Health
does not endorse and is not responsible for the privacy practices of these Third
Party Contractor Websites. You should review the privacy policy posted on the
other website to understand how that Third Party Contractor Website collects and
uses your Personal Information. WebMD makes an effort to make it obvious to you
when you leave our website and enter a Third Party Contractor Website, either by
requiring you to click on a link or by notifying you on the site before you
visit the third part site. In addition, if you see a phrase such as "Powered by"
or "in association with" followed by the name of a company other than WebMD,
then you are on a website hosted by a company other than WebMD.

J. DISCLOSURE TO LINKED SITES

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In addition to the Third Party Contractor Websites that you may access as
described above, for your convenience there are links to websites operated by
companies other than WebMD ("Third Party Websites") that are not contractors who
provide content or services through the Portal. These links may be found in
advertisements, referenced within content, or placed beside the names or logos
of sponsors. WebMD does not disclose Personal Information about you or your
dependents to these Third Party Websites without obtaining your consent. WebMD
does not endorse and is not responsible for the privacy practices of these
sites. Once you click on a link to a Third Party Website, and leave the Portal,
that sites privacy policy, rather than WebMD governs your activities on that
site. If you choose to link to one of these Third Party Websites, you should
review the privacy policy posted on this other website to understand how that
Third Party Website collects and uses your Personal Information.


VI. WHAT ARE YOUR PRIVACY CHOICES AS A USER OF WEBMD TOOLS?

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A. CHANGING INFORMATION

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WebMDs tools allow you to correct, update or review information you previously
submitted for use with a WebMD Tool. To do this, simply access your Personal
Health Manager Home Page and easy-to-use functions will show you how to correct,
update or review information.

B. ACCOUNT DELETION AND REMOVAL OF YOUR PERSONAL INFORMATION

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At any time, you may close your WebMD account and remove your Personal
Information. To do this, you can either:

 * Go to the "Account Deletion" tab in the "Settings" section of the Personal
   Health Manager account and follow the on screen instructions or
 * Submit a signed statement, including your name, address, email address and
   birth date, to the address below, authorizing and directing WebMD to remove
   your Personal Information.

If you decide to delete your account and Personal Information:

 * Your account access will end immediately. This applies to access gained
   through an employer or health plan sponsor account as well as through
   WebMD.com, if applicable.
 * Your Personal Information will be removed from WebMD's databases.
 * Your health information will be removed from WebMD's backup files.

If you choose to submit a written request to delete your account, send the
request to:

WebMD Health Services Group, Inc.
Attn: Record Removal
2701 NW Vaughn St.
Suite 700
Portland, OR 97210

For written requests, we will notify you by email or in writing within 30 days
after receipt of such request that your request has been processed.

Your Personal Information may continue to be maintained in backup media. We may
continue to store, use, and disclose your information in a de-identified form as
described in this Privacy Policy.

C. LIMITATIONS ON REMOVING OR CHANGING INFORMATION

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Professionally Sourced Health Information For Personal Health Information at
Personal Health Manager, your ability to correct, update or remove previously
provided Personal Information or Personal Health Information only covers
information within the reasonable control of WebMD. We place certain
restrictions on your ability to correct, update or remove professionally sourced
health information that you have authorized to be entered into the users
Personal Health Manager record. You may potentially authorize physicians, other
health care providers, health plans, hospital systems, pharmacists or
laboratories (or their respective websites) to provide data into your Personal
Health Manager record. While you can remove this professionally sourced
information from the users record for the purpose of controlling the viewing or
sharing of that information, Personal Health Manager will maintain an audit log,
a notice of that transaction and a copy of the information deleted.


VII. HOW DOES WEBMD PROTECT PERSONAL INFORMATION?

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Though an effort is made to secure Personal Information, there is always some
risk that an unauthorized third party may find a way to thwart security systems
or that transmissions of personal Information over the Internet will be
intercepted. WebMDs current practices include:

 * Using passwords to authenticate users before granting access to personal
   information.
 * Limiting access to Personal Information to authorized users. Only the person
   who creates a record can grant access to other users.
 * Using firewalls to protect information held in our servers.
 * Maintaining Audit Trails to allow you to know who has accessed your records.
 * Sensitive information, such as information related to mental health,
   substance abuse, genetics and communicable diseases, will only be delivered
   through reasonably secure means. Encrypting the information we send and
   receive from you to protect personal and health-related information. WebMD
   employs Secure Socket Layer encryption in transmitting Personal Information
   to its servers. In order to take advantage of this technology, you must have
   an internet browser which supports 128-bit encryption.
 * Protecting the physical security of WebMD servers. WebMD protects your access
   to your information by providing geographic redundancy. WebMD servers store
   identical information at two separate locations. Both sites maintain physical
   security through pass code locked door access and pass code authority.

Despite efforts to protect Personal Information and Personal Health Information,
in certain limited circumstances release of Personal Information or Personal
Health Information may be legally compelled in response to (i) a court order,
search warrant, subpoena or other legal action that the disclosing entity
reasonably deems to be valid, or (ii) in special cases, such as a physical
threat to the user or others. In the event that we are legally compelled to
disclose Personal Health Information or Personal Health Information to a third
party, we will attempt to notify you unless doing so would violate the law or
court order.


VIII. CHANGES TO THE WEBMD PRIVACY POLICY

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WebMD reserves the right to change, modify, add, or remove portions of this
Privacy Policy, or any of its supplemental policies, at any time.

Personal Information You will be informed if a material change to the Privacy
Policy is made that involves the use of Personal Information about you or your
dependents. Continued use of the Portal by you will indicate acceptance of the
changes. You may of course choose to Opt-out of continuing to use the Portal.
Please exit the Portal immediately if you do not agree to the terms of this
Privacy Policy or any revised policy.

Personal Health Information You will be informed if a material change in the
Privacy Policy is made that involves the use of Personal Health Information
about you or your dependents, and express Opt-in authorization will be requested
from you. If you choose not to accept the new privacy policy, then you will have
the opportunity to obtain a copy of your data within a specified time frame and
the current privacy will apply during this period, but you will not be able to
add new information or to use the WebMD Tools. WebMD reserves the right to
discontinue or limit functionality in all its products.

Material changes to the Privacy Policy that involve the use of Personal
Information will be communicated to you by posting those changes on this Portal
or by email notification where permitted. You also may be informed of other
changes that may affect your rights. We reserve the right to make
non-significant changes to our Privacy Policy, without user consent or notice,
and will post such changes to our Web site. You are responsible for checking the
portal from time to time for updates.


IX. WEBMD'S TOOLS ARE INTENDED FOR ADULTS

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WebMD's Tools are intended for adult use only. A parent or guardian, however,
may use WebMD Tools to establish a personal health record and a Personal Health
Manager Home Page for a minor. The parent or guardian is solely responsible for
providing supervision of the minor's use of WebMD Tools, including a personal
health record and Health Manager Home Page for the minor. The parent or guardian
assumes full responsibility for ensuring that the authentication information is
kept secure and that the information submitted is accurate. The parent or
guardian also assumes full responsibility for the interpretation and use of any
information or suggestions provided through WebMD for the minor.


X. QUESTIONS

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Questions regarding WebMD's Privacy Policy should be directed to:

WebMD Health Services Group, Inc.
Attn: Privacy Officer
2701 NW Vaughn St.
Suite 700
Portland, OR 97210

Or use our Feedback form.

If you do not receive acknowledgment of your inquiry or your inquiry has not
been satisfactorily addressed, you may then contact TRUSTe. TRUSTe will then
serve as a liaison with WebMD to resolve your concern.


XI. CALIFORNIA PRIVACY RIGHTS

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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.


XII. GLOSSARY

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Aggregate Information or Data: As a website gathers individual pieces of
non-Personal Information (see definition below) from its users, it may combine
similar data from many or all the users of the website into one big batch. For
example, the site may add up the total number of people in Peoria , Illinois ,
(but not their names) who are seeking information about weight loss and compare
that to the number of people in Petaluma , California seeking the same
information.

This sort of statistical information is called aggregate data because it
reflects the habits and characteristics of a large group of anonymous people.
Websites may use aggregate data or share it with their business partners so that
the information and services they provide best meet the needs of the users.
Aggregate data also helps advertisers and sponsors on the Web know how
effectively they are reaching and meeting the needs of their target audience.

Cookie: Means small amounts of information passed between a web site and the web
browser on the users computer that allow a users browser to remember that
specific information later during visits to that web site, and that the web
server can later retrieve.

Non-Personal Information: Information that is not traceable back to any
individual and cannot be used to identify an individual

Opt-In: Means you are actively indicating your preference to participate in a
program, email, feature, tool, or enhancement on a website. Typically, if you
Opt-in you must provide certain information, usually Personal Information, to
the website or otherwise actively indicate your choice or preference to
participate in the website program.

Opt-Out: Means that if you do not take some action you are indicating your
preference to participate in a program, email, feature, tool or enhancement on a
website. Typically, if you Opt-out you must uncheck a box next to a stated
preference or otherwise take some indicate action to indicate your preference
not to participate in a program.

Personal Information (PII): Information that can be traced back to an individual
(contrast with Non-Personal Information and Aggregate Information). Examples of
PII includes name, home address, telephone number, email address, and Social
Security number.

Personal Health Information (PHI): Means Personal Information when combined with
(or that includes) any information on a person's health or medical status.

Portal: Means that particular website located at http://mycigna.com (or its
successor, as determined by the provider of this service), which contains or
provides links to a broad aggregation of Internet-based properties that are
directed to providing health information for employees and their dependents.

Third Party: Means any entity other than WebMD.

Third Party Contractor Website: Means a Third Party that serves content and/or
services on the Portal that is served on websites hosted by a company other than
WebMD.

Third Party Site: Means a web site operated by companies other than WebMD that
is not a Third Party Contractor Website.

Web Beacons: Means an electronic file that allows a web site to access certain
cookies or to count users who have visited a particular page.

WebMD Tool: Means any WebMD web page, frame or other feature of this Portal
accessible by you.

Last Updated: February 13, 2020




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