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INCLUDED HEALTH PRIVACY POLICY

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INCLUDED HEALTH PRIVACY POLICY

Effective Date: May 10, 2023

We are pleased to announce that Grand Rounds, Inc., Doctor On Demand, Inc., and
Included Health Communities are now part of Included Health, Inc. 

We encourage you to read this document to understand the terms, policies, and
more that apply to you when you use our websites, products, or services,
including how we process your personal information and how you can update and
manage that information.


INCLUDED HEALTH PRIVACY POLICY

Included Health, Inc. (“Included Health”, “Company”, “we”, “us”, or “our”)
operates the websites located at includedhealth.com and doctorondemand.com, and
other websites, products, services, and mobile applications with links to this
Privacy Policy, including without limitation the Doctor On Demand webpages and
secure applications (collectively, the “Sites” or “Websites”, unless otherwise
specified). Users of the Sites or Services are referred below as “Users”,
“Members”, “you”, “your”, or “yours”.

We offer online telehealth services enabling our Members to report their health
history and engage independent healthcare professionals (“Healthcare
Professionals”) to obtain medical and healthcare services, as well as provide
behavioral health coaching from Coaches (“Coaches”) who do not provide
professional or clinical services.

The Healthcare Professionals who deliver Services through Included Health are
independent professionals practicing within several groups of independently
owned professional practices (collectively, “Doctor On Demand Professionals”).
Please refer to the Doctor On Demand Professionals Notice of Privacy Practices
to learn more about these groups and how they’re organized. 

Please note that Users in different regions may be subject to different data
protection laws, regulations, and standards. As such, this document has a
section dedicated to California consumers, as well as a section dedicated to
consumers subject to European Union jurisdiction.

Please read this Privacy Policy carefully before using the Sites or Services. By
visiting or using any of the Sites or Services, you are accepting the practices
described in this Privacy Policy, as well as the Included Health Terms of
Service and other terms, agreements, statements of rights, consent forms, and
policies referenced above, as applicable. If you do not agree to this Privacy
Policy, or any of the documents referenced above, please do not use the Sites or
Services.

When visiting or using any of the Sites or Services, including Doctor On Demand
by Included Health (“Doctor On Demand”), or any other website or mobile
application that reference or link to this Privacy Policy, your information will
be processed by Included Health for the purposes stated below, and in accordance
with the Doctor On Demand Notice of Privacy Practices, where applicable and
legally permissible. 


WHAT IS THE PURPOSE OF THIS PRIVACY POLICY?

This Privacy Policy discloses Included Health’s personal information gathering
and dissemination practices with respect to the Sites, as well as any other
websites, mobile applications, or other products and services provided by us
that link to this Privacy Policy. When we use the term “personal information” in
this Privacy Policy, we mean information that on its own, or in combination with
other information, could reasonably identify you. 

We have also created this Privacy Policy to demonstrate our commitment to
privacy. We recognize that when you provide us with information about yourself
that you trust us to act in a responsible manner with that information. We are
committed to making sure we earn that trust.

The personal information we receive or obtain through your use of the Services
may be subject to different state and federal privacy laws, including the Health
Insurance Portability and Accountability Act of 1996 and its implementing
regulations (“HIPAA”). Descriptions in this Privacy Policy regarding our
collection, use and disclosure of personal information may be subject to or
further restricted by the requirements of these laws. In addition, where
Included Health collects, creates, maintains, uses and discloses Protected
Health Information (“PHI”), which is personally identifiable health information
protected by HIPAA, we may be and likely are subject to certain agreements,
including with health plans and health care providers. In those cases, our
collection, creation, maintenance, use and disclosure of PHI will be in
accordance with such agreements and your health plan’s (“Plan”) Notice of
Privacy Practices, where applicable. As such, references below to HIPAA, PHI,
and related are provided for informational purposes. For official notices
concerning, or for more information or questions about, the use and disclosure
of your PHI, please refer to your Plan’s Notice of Privacy Practices, as
applicable.


WHAT INFORMATION DO WE COLLECT FROM USERS AND HOW IS IT USED?

The following describes the types of personal and other information Included
Health may collect about you, and how we may use and maintain that information,
including, but not limited to:

 * Eligibility, claims, medical history, and other Employer data. If you are
   eligible for our Services through your employer, Plan, or labor union
   (collectively, your “Employer”), your Employer may provide to us directly or
   via a third-party data required to verify your eligibility, to allow us to
   communicate with you, and to understand your health. This information may
   include your name, email address, phone number, Service eligibility data,
   carrier membership data, biometric data, medical history and claims data, and
   information used to verify your identity (such as birthday, partial social
   security number, and/or employee ID number).
 * Registration. Before you can utilize certain services that we offer on the
   Sites or otherwise, we may ask that you register with the Sites and provide
   us with your email address, a password, your first and last name and other
   contact information and personal details. We request this information for
   identification purposes, to communicate with you regarding your account, and
   to facilitate the functioning of certain services. 
 * Forms. To fully utilize the services we offer, you may be required to fill
   out forms that will contain personal information such as your name, address,
   telephone number, social security number, account information, employment,
   health status and other personal information relevant to your health
   insurance coverage, diagnosis and treatment. 
 * Surveys. At various points in your Member experience with us, you may be
   presented with optional surveys intended to measure your Service experience
   in some way. 
 * Medical Records. To support the medical professionals giving second opinions
   regarding your health, you may be required to provide us with past and
   current medical records, description of symptoms, a medical history and
   life-style descriptions.
 * Correspondence. If you correspond with us, including postal, email, in-app
   chat or messaging, phone, or video, we may retain those records.
 * Technical information and usage information. Like many other websites, we 
   collect information about users’ devices (such as browser and device types,
   device identification numbers, or other online identifiers) and users’
   utilization and navigation of our Sites. This information helps us to design
   our Sites to better suit our users’ needs. For example, our Sites will track
   the URL that you visited before you came to our Sites, the URL to which you
   next go and your Internet Protocol (IP) address. We use your IP address to
   help diagnose problems with our server and to administer our Sites. Your IP
   address also is used to help identify you and to gather broad demographic
   information.
 * Information Collected With Cookies. Like most major websites, we use cookies
   on certain pages of our Sites. Cookies make using the Internet easier by,
   among other things, saving your preferences for you. For example, a cookie
   lets the Sites remember that you’ve registered, which allows us to speed up
   your future activities at our Sites, and which allows you to enter your
   registration information less frequently while visiting our Sites. We may
   also use cookies to deliver content tailored to your interests. Our cookies
   may enable us to relate your use of our Sites to personally identifying
   information that you previously submitted, such as calling you by name when
   you return to our Sites. If your browser is set to reject cookies, or if your
   browser notifies you that you are about to receive a cookie and you reject
   it, then your use of the Sites may not be as efficient or as enjoyable as it
   would be if the cookie were enabled. The information that we collect with
   cookies allows us to improve our marketing and promotional efforts, to
   statistically analyze Sites’ usage, to improve our content and product
   offerings and to customize our Sites’ content, layout and services. You may
   learn more about specific cookies later in this document.
 * Included Health Communities. For users of Included Health Communities
   (“Communities”), in addition to other types of information described above
   (such as contact information), we also collect: information users provide
   directly to us, including by registering for events through the Sites, when
   requesting support, by contacting us with inquiries or comments, or accessing
   the Communities Site pages; usage information, such as website traffic
   patterns; location information, meaning information used to locate the device
   the user uses to access Communities services (e.g., the location of the
   device derived from GPS or WiFi use, the location derived from the IP address
   of the device or internet services used to access Communities services, and
   other information made available by a user or others that indicates the
   current or prior location of the user); and any other information that users
   may provide to us that can be used to identify them. We may also collect
   personal information about Communities users from other sources, including
   from employers, which we may combine with the information we collect directly
   from users to help us tailor communications and improve the Communities
   services. In connection with the Communities services, we also use
   information collected from users to connect users with healthcare service
   providers or organizations and enhance user experiences, such as by tailoring
   content and remembering user preferences.


TO WHOM DOES INCLUDED HEALTH DISCLOSE INFORMATION ABOUT YOU THAT WE COLLECT?

Included Health will not share, rent, sell or otherwise disclose any of the
personally identifiable information that we collect about you, except when we
have your permission or in any of the following situations:

 * If you have requested a Service, we may use information about you to fulfill
   such requests (including providing that information to third parties). We may
   also at any time review your case, your medical records from prior to and
   after your interaction with the Sites, and any records created as a result of
   Services received. We may share information about you, your care, and your
   use of Services to your healthcare payor, or as necessary to implement plan
   designs described to you in your applicable Plan documentation, or on your
   request. If your Plan provides incentives for utilization of services, we
   will share information required to implement such incentives. We may request
   courtesy notices from your treating physician(s) and/or request additional
   medical records from them, including records pertaining to care you received
   after receiving the services. We may review these records for, among other
   purposes, reviewing the quality of service you received, reviewing the
   quality of service provided by the physicians and medical professionals
   treating you (including the physicians and medical professionals to whom you
   may have received a referral), to better understand the course of treatment
   for your condition(s) including information regarding outcomes and costs, and
   to improve treatments and recommendations for people with similar or
   different conditions. We will take care to minimize personally identifying
   information in this process. We may also use anonymous information gathered,
   including information from your medical records, to generate conclusions
   about the healthcare process, particular conditions, and other matters. We
   and our affiliated physicians and researchers may publish this anonymous
   information in journals, websites and other locations. However, we will not
   publish your name or any identifying information about you without your
   permission; we will use only anonymous data for any public purpose.
 * We may disclose information that we collect about you to our third-party
   contractors who perform services for us in order to provide certain services
   or to complete or confirm a transaction that you conduct with us.
 * We may use information we know about you to contact you to inform you about
   relevant services, including by telephone, text message, email, or direct
   mail.
 * We may disclose the results of anonymized aggregated data about you for
   marketing or promotional purposes (for instance, that a certain percentage of
   our Sites’ users are living in a particular state of the United States). In
   these situations, we do not disclose to these entities any information that
   could be used to personally identify you. Certain information, such as your
   password, is not disclosed to marketing advertisers at all, even in aggregate
   form.
 * We may disclose information about you as part of a merger, acquisition or
   other sale or transfer of its assets or business. We do not guarantee that
   any entity receiving such information in connection with one of these
   transactions will comply with all terms of this Privacy Policy.
 * We may disclose information about you for purposes such as to provide
   services available on the Sites; to coordinate with insurance, reinsurance
   and excess or stop loss insurers; to enforce our Members’ rights; to protect
   against actual or potential fraud; to resolve Member inquiries or disputes;
   to receive payments; to carry out our business; to protect the
   confidentiality or security of our records; to administer preventive health
   and case management programs; to perform auditing and ratemaking functions;
   to enable our service providers to perform marketing services on our behalf
   and inform Users about our own products or services; to comply with federal
   or state laws and other applicable legal requirements.
 * We may disclose your information, to the extent permitted by law, in court or
   in the stages leading to possible legal action arising from improper use of
   this website, application or services, or due to a dispute you initiate in
   connection with the related services.
 * Moreover, we may be legally obligated to disclose information about you to
   the government or to third parties under certain circumstances, such as in
   connection with illegal activity on our Sites or to respond to a subpoena,
   court order or other legal process. We reserve the right to release
   information that we collect to law enforcement or other government officials,
   as we, in our sole and absolute discretion, deem necessary, appropriate or as
   required under law, such as your statement to hurt yourself or others.
 * For users of Communities, we also disclose personal information to providers
   with whom the users have a relationship or with whom users request that we
   facilitate a consultation or appointment as part of Communities’ services.

If you use our Sites or Services outside of the United States, information that
we collect about you will be transferred to servers inside the United States,
which may involve the transfer of information out of countries located in the
European Economic Area. By allowing us to collect information about you, you
consent to such transfer and processing of your data.


YOUR RIGHTS UNDER HIPAA REGARDING PROTECTED HEALTH INFORMATION

This section excludes Services performed by or associated with the Doctor On
Demand Professionals. For more information, please see the Doctor On Demand
Notice of Privacy Practices. 

You have certain rights regarding your protected health information under HIPAA
that may be available to you. For official notice concerning these rights, you
should refer to your Plan’s Notice of Privacy Practices. 

To exercise these rights, you may contact your Plan at the contact information
listed in your Plan’s Notice of Privacy Practices or follow the instructions
below under “How to exercise your privacy rights”. Where applicable, we will
respond to your request in accordance with the business associate agreement we
have with your Plan. In the event of any inconsistency between the below
summary, and your Plan’s Notice of Privacy Practices, we will follow your Plan’s
Notice of Privacy Practices as applicable, unless we are otherwise instructed by
your Plan, subject to a relevant business associate agreement. 


WHAT SECURITY MEASURES DO THE SITES EMPLOY?

To help protect the privacy of data you transmit through the Sites, where
personally identifiable information is requested, Included Health also uses
technology designed to encrypt the information that you input before it is sent
to us using Secure Sockets Layer (SSL) technology or similar encryption
technology. In addition, we take steps to protect the user data we collect
against unauthorized access. However, you should keep in mind that the Sites and
our services are run on software, hardware and networks, any component of which
may, from time to time, require maintenance or experience problems or breaches
of security beyond our control.

Please also be aware that despite our best intentions and the guidelines
outlined in this Privacy Policy, no data transmission over the Internet or
encryption method can be guaranteed to be 100% secure.


HOW CAN YOU CORRECT OR UPDATE INFORMATION THAT WE COLLECT ABOUT YOU?

You may correct or update information collected about you by managing your
account profile, contacting us via the contact information below, or submitting
a privacy request as laid out below under “How to exercise your privacy rights”.
We will respond in accordance with our agreements and legal requirements. If
necessary, we may retain original and updated information for reasons such as
technical constraints, dispute resolution, troubleshooting and agreement
enforcement.


WHAT ARE THE POLICIES OF LINKED SITES AND OTHER THIRD PARTIES?

This Privacy Policy only addresses the use and disclosure of certain information
Included Health collects from or about you. You should be aware that when you
are on the Sites, you can be directed to other websites that are beyond our
control, and we are not responsible for the privacy practices of third parties
or the content of linked websites. We encourage you to read the posted privacy
policy whenever interacting with any website.


HOW WILL I KNOW ABOUT CHANGES IN THE PRIVACY POLICY?

Included Health’s Sites are owned and operated by Included Health. Our Sites are
continually under development and changes to the Sites or Services may be made
at any time. We reserve the right to revise or remove any part of this Policy in
our sole discretion at any time and without prior notice to you, unless where
legally required. Thus, you should visit this page periodically for changes. Any
changes to this Policy are effective upon posting to the Sites, unless otherwise
specified. If you disagree with this Policy, your sole remedy is to discontinue
your use of the Sites and Services. Your continued use after a change has been
posted constitutes your acceptance of the changes.


WHAT IS OUR POLICY ON CHILDREN USERS OF OUR SITES?

Included Health does not knowingly collect or maintain personally identifiable
information from persons under 13 years old, and no part of our Sites is
directed to persons under 13. IF YOU ARE UNDER 13 YEARS OF AGE, PLEASE DO NOT
USE OR ACCESS OUR SITES AT ANY TIME OR IN ANY MANNER, except where allowed in
accordance with our Terms of Service. Where permitted, any personal information
relating to those children will be health information governed by this Privacy
Policy or the applicable Notice of Privacy Practices.

If you are a parent or guardian and discover that your child under the age of
13, or equivalent minimum age depending on jurisdiction, has obtained an
Included Health account, then you may alert us using the contact information
below under “Contact Us” and request that we delete that child’s personal
information from our systems. If we learn that we have collected the personal
information of a child under 13, or equivalent minimum age depending on
jurisdiction, outside the above circumstances we will take steps to delete the
information as soon as possible, except where prohibited by applicable law.

We do collect from employers information regarding Members of all ages, so that
we may know who is eligible to receive Services. A parent/guardian may request
that we stop processing that information if eligible under CCPA or GDPR, as
further described below, however you should contact your Employer if you would
like that information no longer provided to health carriers.


WHAT LAW GOVERNS MY USE OF THE SITES AND INCLUDED HEALTH’S SERVICES?

By choosing to visit Included Health’s Sites, use our Services, or otherwise
provide information to us, you agree that any dispute over privacy or the terms
contained in this Privacy Policy will be governed by the law of the State of
California. You also agree to abide by any limitation on damages contained in
our Terms of Service or other agreement that we have with you.


ADDITIONAL INFORMATION ABOUT THIS PRIVACY STATEMENT

Our Sites are owned and operated by Included Health. The terms indicated in this
Privacy Policy will remain effective, even if the Member’s coverage is
terminated, to the extent we retain information about a Member. 


INFORMATION ABOUT PARTICULAR SERVICES

Please note that the descriptions below concerning particular services may not
apply to all services, sites, or mobile applications provided by Included
Health.

Analytics

The services contained in this section enable us to monitor and analyze web
traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”).
Google utilizes the Data collected to track and examine the use of this
Application, to prepare reports on its activities and share them with other
Google services.

Google may use the Data collected to contextualize and personalize the ads of
its own advertising network.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Google Privacy Policy – Google Opt Out

Display Advertising extension for Google Analytics (Google Inc.)

Google Analytics on this Application might use Google’s Interest-based
advertising, 3rd-party audience data and information from the DoubleClick Cookie
to extend analytics with demographics, interests and ads interaction data.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Google Advertising Privacy Policy – Google Advertising
Opt Out

Analytics collected directly (This Website)

This Website uses an internal analytics system that does not involve third
parties.

Personal Data collected: Cookies and Usage Data.

Google Tag Manager (Google Inc.)

Google Tag Manager is an analytics service provided by Google Inc.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Google Tag Manager Privacy Policy

LinkedIn conversion tracking (LinkedIn Corporation)

LinkedIn conversion tracking is an analytics service provided by LinkedIn
Corporation that connects data from the LinkedIn advertising network with
actions performed on this Website.

Personal Data collected: Cookies and Usage Data, Tracking Pixel.

Place of processing: US – LinkedIn Privacy Policy

Content Commenting

Content commenting services allow Users to make and publish their comments on
the contents of this Website.

Depending on the settings chosen by Included Health, Users may also leave
anonymous comments. If there is an email address among the Personal Data
provided by the User, it may be used to send notifications of comments on the
same content. Users are responsible for the content of their own comments.

If a content commenting service provided by third parties is installed, it may
still collect web traffic data for the pages where the comment service is
installed, even when Users do not use the content commenting service.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms
directly from the pages of this Website and interact with them.

This type of service might still collect web traffic data for the pages where
the service is installed, even when Users do not use it.

Infrastructure monitoring

This type of service allows this Website to monitor the use and behavior of its
components so its performance, operation, maintenance and troubleshooting can be
improved.

Which Personal Data are processed depends on the characteristics and mode of
implementation of these services, whose function is to filter the activities of
this Website.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts,
phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the
message was viewed by the User, as well as when the User interacted with it,
such as by clicking on links included in the message.

Marketo Email Marketing (Marketo, Inc.)

Marketo Email Marketing is an email address management and message sending
service provided by Marketo, Inc.

Personal Data collected: email address and Usage data.

Place of processing: US – Marketo Privacy Policy

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external
platforms directly from the pages of this Application.

The interaction and information obtained through this Application are always
subject to the User’s privacy settings for each social network.

This type of service might still collect traffic data for the pages where the
service is installed, even when Users do not use it.

Remarketing and Behavioral Targeting

This type of service allows this Application and its partners to inform,
optimize and serve advertising based on past use of this Application by the
User.

This activity is performed by tracking Usage Data and by using Cookies,
information that is transferred to the partners that manage the remarketing and
behavioral targeting activity.

Remarketing through Google Analytics for Display Advertising (Google Inc.)

Google Analytics for Display Advertising is a Remarketing and Behavioral
Targeting service provided by Google Inc. that connects the tracking activity
performed by Google Analytics and its Cookies with the Adwords advertising
network and the Doubleclick Cookie.

Personal Data collected: Cookies and Usage data.

Place of processing: US – Privacy Policy – Opt Out

LinkedIn Website Retargeting (LinkedIn Corporation)

LinkedIn Website Retargeting is a remarketing and behavioral targeting service
provided by LinkedIn Corporation that connects the activity of this Website with
the LinkedIn advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: US – LinkedIn Website Retargeting Privacy Policy – LinkedIn
Website Retargeting Opt Out

User database management

This type of services allows Included Health to build user profiles by starting
from an email address, a personal name, or other information that the User
provides to this Application, as well as to track User activities through
analytics features. This Personal Data may also be matched with publicly
available information about the User (such as social networks’ profiles) and
used to build private profiles that Included Health can display and use for
improving this Application.

Some of these services may also enable the sending of timed messages to the
User, such as emails based on specific actions performed on this Application.

Marketo Lead Generation (Marketo, Inc.)

Marketo Lead Generation is a User database management service provided by
Marketo, Inc.

Personal Data collected: email address and various types of Data as specified in
the privacy policy of the service.

Place of processing: US – Marketo Lead Generation Privacy Policy

Heat mapping and session recording

Heat Mapping services are used to display the areas of a page where Users most
frequently move the mouse or click. This shows where the points of interest are.
These services make it possible to monitor and analyze web traffic and keep
track of User behavior.

Some of these services may record sessions and make them available for later
visual playback.

Contacting the User

Contact form (this Website)

By filling in any contact form with their Data, the User authorizes this Website
to use these details to reply to requests for information, quotes or any other
kind of request as indicated by the form’s header.

Personal Data collected: various types of Data.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party
services may collect files that record interaction with this Website (System
logs) use other Personal Data (such as the IP Address) for this purpose. Logging
data may be collected in order to assist with troubleshooting crashes and other
issues.

Web Beacons

A web beacon (also referred to as clear gif, pixel tag or single-pixel gif) is a
transparent graphic image used in tandem with cookies that enables us to record
a user’s actions.

Included Health uses web beacons to count users who have visited certain pages,
verify system and server integrity and for similar statistical measures.
Included Health may also use pixel tags in HTML-based emails sent to its users
to track which emails are opened by recipients.


DATA RETENTION

Included Health retains personal information, subject to this Policy, only for
as long as necessary for the purposes for which the data was collected and
processed. 

Data collected for the provision of Services is retained for the longer of as
needed to provide Services; as specified in a relevant agreement (e.g., with
your Plan); or as otherwise required, including by applicable law or regulation.


ADDITIONAL INFORMATION FOR EU / EEC USERS

The disclosures in this section are only applicable to individuals in the
European Economic Area, Switzerland, and the United Kingdom. This part of the
document integrates with and supplements the information contained in the rest
of the Privacy Policy.

Data Is required to provide services

Unless otherwise specified, all Personal Data (as defined under the GDPR)
requested is mandatory and your choice to not provide such Personal Data may
make it impossible to provide services to you. In cases where we have made clear
that some Personal Data is not mandatory, you are free not to communicate this
Personal Data without any consequences on the availability or the functioning of
the service. If you are uncertain about which Personal Data is mandatory then
you are welcome to contact Included Health at the contact details below under
“Contact Us”.

Additional information about your Personal Data

In addition to the information contained in this privacy policy, upon your
request we may provide you with additional and contextual information concerning
particular services or the collection and processing of Personal Data.

Your GDPR rights

Solely to the extent applicable to us, if you are subject to the GDPR, you may
have certain rights and protections about the collection, sharing, and use of
your Personal Data including as follows:

 * Right to Access Your Personal Data: You can ask us for a copy of the Personal
   Data we have about you.
 * Right to Rectification/Correction: You can also ask us to change, correct, or
   update your Personal Data in certain cases, especially if it is inaccurate.
 * Right to Erasure/Right to be Forgotten: You can ask us to stop using or erase
   all or some of your Personal Data (if we have no legal right to keep using
   it).
 * Right to Data Portability: You can ask us for a copy of the Personal Data you
   provided to us in a commonly used and machine-readable format.
 * Right to Object or Restrict Processing: You can object to or ask us to
   restrict processing under certain circumstances.

Requests should be sent to the Data Controller via the contact details below
under “Contact Us”

Additional information regarding methods of processing

We take security measures to prevent unauthorized access, disclosure,
modification, or unauthorized destruction of the Personal Data. The Personal
Data processing is carried out using computers and/or IT enabled tools,
following organizational procedures and modes strictly related to the purposes
indicated. In addition to us, in some cases, the Personal Data may be accessible
to certain types of persons in charge, involved with the operation of this
Website (administration, sales, marketing, legal, system administration) or
external parties (such as third-party technical service providers, mail
carriers, hosting providers, IT companies, communications agencies) appointed,
if necessary, as Data Processors by us. If applicable, this list may be
requested and by a GDPR-covered Person from us at any time.

Legal basis for processing

We may process Personal Data relating to Users if one of the following applies:

 * Users or their agents (including group sponsors and employers) have given
   their consent for one or more specific purposes. Note: Under some
   legislations we may be allowed to process Personal Data until the User
   objects to such processing (“opt-out”), without having to rely on consent or
   any other of the following legal bases;
 * provision of Personal Data is necessary for the performance of an agreement
   with the User or an authorized agent of the User (such as a group sponsor or
   employer) and/or for any pre contractual obligations thereof;
 * processing is necessary for compliance with a legal obligation to which we
   are subject;
 * processing is related to a task that is carried out in the public interest or
   in the exercise of official authority vested in us;
 * processing is necessary for the purposes of the legitimate interests pursued
   by us or by a third party.

In any case, we will gladly help to clarify the specific legal basis that
applies to the processing, and in particular whether the provision of Personal
Data is a statutory or contractual requirement, or a requirement necessary to
enter into a contract.

Place of processing

Personal Data is processed at our operating offices, in data centers located in
the United States and in any other places where the parties involved in the
processing are located. The United States has different (and sometimes lesser)
privacy protections than other jurisdictions. By providing Personal Data, using
this website, using mobile applications provided by us, or requesting services,
you consent to the transfer of your Personal Data to the United States and the
processing of such Personal Data in the United States.

Retention time

Personal Data shall be processed and stored as noted above under Data Retention.

Where Personal Data is processed subject to the General Data Protection
Regulation, such Personal Data collected for the purposes of our legitimate
interests shall be retained as long as needed to fulfill such purposes,
including but not limited to retention of records of completed services as
required by law, regulation and healthcare practice and for the other reasons
described in this policy. 

Users may find specific information regarding the legitimate interests pursued
by us within the relevant sections of this document or by contacting us at the
contact details below under “Contact Us”. 

Furthermore, we may be obliged to retain Personal Data for a longer period
whenever required to do so for the performance of a legal obligation (including
but not limited to retention of records of healthcare services performed or
recommended) or upon order of an authority.

Purposes of processing

Personal Data about you is collected to allow us to provide services to you, as
well as for the following purposes: Analytics, Remarketing and behavioral
targeting, Interaction with external social networks and platforms, Managing
contacts and sending messages, User database management, Heat mapping session
recording, Content commenting, Displaying content from external platforms,
Content performance and features testing (A/B testing), Generation models of
medical and clinical conditions, Generation models of physician and clinical
performance, Infrastructure monitoring and Contacting the User.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be
requested from the Data Controller at any time. Please see the contact
information below under “Contact Us”.

Data Protection Officer

The Data Protection Officer shall be the HIPAA Privacy Officer.

Legal Basis

This privacy statement has been prepared based on provisions of multiple
legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data
Protection Regulation or “GDPR”).


ADDITIONAL INFORMATION FOR CALIFORNIA CONSUMERS

This part of the document integrates with and supplements the information
contained in the rest of the Privacy Policy, and applies to any personal
information processed by Included Health of Users who are consumers, residing in
the state of California, United States of America, and subject to The California
Consumer Privacy Act of 2018. For such consumers, these provisions supersede any
other possibly divergent or conflicting provisions contained in the Privacy
Policy.

This section of the Policy uses the term “personal information“ as it is defined
in CCPA.


CATEGORIES OF PERSONAL INFORMATION COLLECTED, DISCLOSED OR SOLD

Please refer to the list above under “What information do we collect from users
and how is it used?”


HOW WE USE THE INFORMATION WE COLLECT: SHARING AND DISCLOSING OF YOUR PERSONAL
INFORMATION WITH THIRD PARTIES FOR A BUSINESS PURPOSE

We may disclose the personal information we collect about you to a third party
for business purposes. In this case, we enter a written agreement with such
third party that requires the recipient to both keep the personal information
confidential and not use it for any purpose(s) other than those necessary for
the performance of the agreement.

We may also disclose your personal information to third parties when you
explicitly ask or authorize us to do so, in order to provide you with our
Service.

To find out more about the purposes of processing, please refer to the relevant
section of this document.


YOUR RIGHT TO OPT OUT OF THE SALE OF PERSONAL INFORMATION

We do not sell Member information, including lists of Members or any personal
information of Members otherwise.

To the extent our website uses third party cookies and these cookies collect
personal information, such collection may in some cases be considered a “sale”
of personal information for purposes of the CCPA. 

You have the right to opt out of the sale of your personal information. This
means that whenever you request us to stop selling your data, we will abide by
your request. 

You can opt out of such sales. Such requests can be made freely, at any time,
without submitting any verifiable request by following the below instructions.


INSTRUCTIONS TO OPT OUT OF THE SALE OF PERSONAL INFORMATION

On our Sites are cookie banners with a button labeled “Do not sell my data.”
This button was added in order to comply with the CCPA, and it offers
information about our use of these third-party cookies, and provides consumers
an opportunity to opt-out of certain of these cookies. 

Should you wish to opt-out of these cookies, please click on the “Do not sell my
data” button on the banner that pops up. This will result in the placement of an
opt-out cookie on your device browser. 

If you’d like to know more, you can contact us at the contact details below
under “Contact Us”.


WHAT ARE THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION?

We may use your personal information to allow us to render services to you and
your Employer (if applicable), the operational functioning of the Sites and
features thereof (all together, “business purposes”). 

We may also use your personal information for other reasons such as for
commercial purposes as well as for complying with the law and defending our
rights before the competent authorities where our rights and interests are
threatened or we suffer an actual damage.


YOUR CALIFORNIA PRIVACY RIGHTS

The right to know and to portability

You have the right to request that we disclose to you:

 * the categories and sources of the personal information that we collect about
   you, the purposes for which we use your information and with whom such
   information is shared;
 * in case of sale of personal information or disclosure for a business purpose,
   two separate lists where we disclose:
   * for sales, the personal information categories purchased by each category
     of recipient; and
   * for disclosures for a business purpose, the personal information categories
     obtained by each category of recipient.
 * The disclosure described above will be limited to the personal information
   collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be
“portable”, i.e. delivered in an easily usable format to enable you to transmit
the information to another entity without hindrance – provided that this is
technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information,
subject to exceptions set forth by the law (such as, including but not limited
to, where the information is used to identify and repair errors on this Website,
to detect security incidents and protect against fraudulent or illegal
activities, to exercise certain rights etc.). For example, we cannot delete
information that explains medical treatment decisions, as we are legally
obligated to keep such information.

If no legal exception applies, as a result of exercising your right, we will
delete your personal information and direct any of our service providers to do
so.


HOW TO EXERCISE YOUR PRIVACY RIGHTS


HOW TO MAKE A REQUEST

At Included Health, member and consumer privacy are very important to us. As a
result, before we process any requests we first must verify your identity and
ensure we have enough information. To exercise rights described throughout the
Privacy Policy, you must submit to us a “verifiable request by:

 * providing sufficient information that allows us to reasonably verify you are
   the person about whom we collected personal information or an authorized
   representative; and
 * describing your request with sufficient detail that allows us to properly
   understand, evaluate, and respond to it.

With that in mind, at this time:

 * Requests from Members are considered verified if submitted using our
   Services. If you are an existing Member, please submit your request either by
   calling us and confirming your identity, or by submitting via the application
   (e.g., using the chat service, or via an open case). If, however, there is
   indication or suspicion of fraud or other malicious activity on the Member’s
   account, we may suspend reliance on these verification methods and defer to
   other methods to confirm authenticity. 
 * You may alternatively contact us via the information provided below under
   “Contact Us”. However, please note that emailed requests are not considered
   verified, and we may request additional information from you (that we would
   already have in our records) in order to confirm your identity. 

 * We may also recognize verified requests submitted on an individual’s behalf
   by “Authorized Agents”. To be valid, we must receive from the Agent a signed
   authorization from the individual on whose behalf the Agent is acting. We
   will also need to verify the authorization with the consumer.
 * For “household” requests subject to the CCPA, we will need to verify each
   household Member’s individual identity and current status as household
   members.
 * And we will not process any requests of children under 13 years of age
   without verifiable consents from their parents or legal guardians. 

We will not respond to or process any unverified request.  This is all done to
protect your confidentiality and ensure, to the best of our ability, that we
only process such requests for the right persons. 

You can submit a maximum number of 2 requests over a period of 12 months.

If you choose to exercise your privacy rights, you will not receive
discriminatory treatment or a lesser degree of service from us.


HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST

Unless otherwise specified in this Policy, the following applies for timing and
expectations around how and when we will respond to your requests. If our
response to a privacy request is restricted by an agreement between us and your
Employer, we will process your requests in accordance with that agreement and
related authorization. Otherwise, the following applies. 

To the best of our ability, we will confirm receipt of your verifiable request
within 10 days and provide information about how we will process your request.

For CCPA-related requests, we will respond to your request within 45 days of its
receipt, and for all other requests within 30 days of receipt. Should we need
more time, we will explain to you the reasons why, and how much more time we
need. In this regard, please note that we may take up to 90 days to fulfill your
request.

Our CCPA disclosures will cover the preceding 12 month period.

Should we deny your request, we will explain to you the reasons behind our
denial.

We do not charge a fee to process or respond to your verifiable request unless
such request is manifestly unfounded or excessive. In such cases, we may charge
a reasonable fee, or refuse to act on the request. In either case, we will
communicate our choices and explain the reasons behind it.


CONTACT US

If you have questions, want to submit a request, have concerns about this Policy
or Included Health’s Privacy Practices, or would like to report a violation, see
the below contact options:

 * You may contact us by mail at:

Included Health, Inc.
c/o Privacy Officer
1 California Street, Ste. 2300
San Francisco, CA 94111

 * You may email us at privacy@includedhealth.com. 
 * If you are registered, you may click here to contact support or submit a
   message through the “chat” experience once logged-in.
 * Or you may call our general support toll free line at (855) 431-5533.

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