Privacy Policy

Well360 Health & Prevention LLC and its affiliated partners (“Well360,” “we,” “our,” or “us”) own and operate the website located at https://well360connect.com/ and any related mobile applications, platforms, or digital services (collectively, the “Platform”). Your access to and use of the Platform, including any content (“Content”), products, services, features, or materials available through the Platform, as well as any affiliated websites, software, or applications owned or operated by Well360 (collectively referred to as the “Service”), are subject to this Privacy Policy unless otherwise stated. Capitalized terms not otherwise defined in this Privacy Policy shall have the meanings set forth in the applicable Well360 Terms and Conditions.

We are committed to respecting and protecting the privacy of users who access and use our Service. This Privacy Policy explains how Well360 collects, uses, maintains, and discloses information in connection with the services we provide. By creating an account, registering, logging into the Service, or otherwise accessing or using any part of the Service, you acknowledge and agree to the most current version of this Privacy Policy.

We may update this Privacy Policy from time to time to reflect changes in our practices, services, technology, or legal requirements. Any updates will be posted on our Platform and the “Last Updated” date will be revised accordingly. If material changes are made to this Privacy Policy, we may provide additional notice or obtain consent where required by applicable law.

If you are using the Service on behalf of another individual, you represent and warrant that you are authorized to act on that individual's behalf and that such individual acknowledges and accepts the practices and policies described in this Privacy Policy.

Limitations on Use by Minors

The Service is generally intended for use by individuals who are at least eighteen (18) years of age or such older age as may be required by applicable state laws in the jurisdiction in which an individual utilizes the Service. If we obtain actual knowledge that we have collected personal information through the Platform from a person under eighteen (18) years of age, we will use reasonable efforts to refrain from further using such personal information or maintaining it in retrievable form.

Protected Information

When you create an account with Well360 Health & Prevention LLC (“Well360”), you establish a direct relationship with Well360 and, where applicable, with affiliated healthcare providers, medical partners, and community service organizations that support the delivery of services available through the Platform. As part of this relationship, you may provide information including, but not limited to, your name, email address, phone number, mailing address, and other account or transactional information. This information is generally not considered “protected health information” or “medical information.”

However, in connection with certain services available through the Platform, you may provide health or medical information that may be subject to specific privacy protections under applicable federal or state laws. Well360 may collect, process, and use such information solely for the purpose of providing healthcare coordination, prevention services, referrals, support programs, and related services.

It is important to understand that the application of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) depends on the specific relationship and services involved. Certain healthcare providers, affiliated medical partners, laboratories, or other healthcare organizations with whom Well360 collaborates may be subject to HIPAA or other applicable privacy regulations. Any health-related information that is protected under HIPAA or other applicable laws (“Protected Information”) will be collected, used, maintained, and disclosed only as permitted by applicable law.

Protected Information does not include information that has been properly de-identified in accordance with applicable laws and regulations. Any healthcare providers or affiliated organizations that provide healthcare services through or in connection with Well360 may maintain their own Notice of Privacy Practices explaining how they collect, use, and disclose Protected Information.

By accessing or using the Service, you acknowledge that you may receive applicable privacy notices from healthcare providers or affiliated organizations involved in providing services through the Platform.

Notice of Privacy Practices

Please refer to Well360 Health & Prevention LLC’s Notice of Privacy Practices and any applicable healthcare provider privacy notices made available through the Platform or upon request.

By accessing or using any part of the Service, you understand that information you submit to Well360 that is not intended solely for the purpose of diagnosis, treatment, healthcare coordination, or services provided by healthcare professionals, affiliated providers, or community partners may not be considered Protected Information and will instead be governed by this Privacy Policy and any applicable state or federal privacy laws.

For clarity, information you provide when registering for an account or using the Platform—including, but not limited to, your name, date of birth, username, email address, mailing address, and phone number—is generally not considered Protected Information unless otherwise required under applicable law.

Esta versión mantiene la intención legal original, pero queda alineada con Well360 y evita referencias regulatorias o entidades específicas que no existen en tu estructura actual.

Collection of Personal Information

The personal information we collect depends on how you interact with Well360 Health & Prevention LLC (“Well360”), the services you use, and the choices you make while accessing our Platform and related services.

We collect information about you from different sources and in various ways when you use our services, including information you provide directly, information collected automatically, information obtained from third-party sources, and information we infer or generate based on your interactions with us.

Information You Provide Directly

We collect personal information that you voluntarily provide to us, which may include:

• Name and contact information, such as your name, email address, phone number, and mailing address.
• Demographic information, including date of birth, gender, zip code, and similar information.
• Social media and third-party integrations, including information associated with social media platforms or third-party applications that you choose to connect with our services.
• Payment information, such as payment card details and transaction-related information when applicable.
• Content and uploaded files, including photographs, documents, forms, messages, and other information you submit through the Platform or communication channels.

Sensitive Personal Information

Depending on the services you request, we may collect certain categories of sensitive information, including:

• Government-issued identification information, where required for verification or eligibility purposes.
• Account credentials and account access information.
• Information regarding communications you submit through the Service.
• Demographic information that may be protected under applicable law.
• Health-related information necessary to provide healthcare coordination, prevention services, support programs, or related services.
• Information related to sexual health or sexual orientation where voluntarily provided and necessary for healthcare or support services.

Information Collected Automatically

When you access or use our Platform, we may automatically collect certain information, including:

• Device and browser information, such as IP address, device identifiers, browser type, operating system, language settings, and device configurations.
• Geolocation information, depending on your device settings and permissions.
• Usage information, including pages visited, time spent on pages, referral URLs, access times, and interactions with our Platform and services.
• Inferences and analytics, including information generated from usage patterns and interactions to improve services and personalize user experiences.

Information Obtained from Third-Party Sources

We may also obtain information from third-party sources including:

• Third-party applications and connected services
• Marketing and community partners
• Service providers working on our behalf
• Publicly available sources
• Healthcare partners and affiliated organizations, where permitted by applicable law

You may choose not to provide certain information or disable certain automatic data collection methods through your browser or device settings. However, some features or services may not function properly if required information is not available.

Well360 may work with healthcare providers, medical partners, laboratories, community organizations, and affiliated service providers in order to facilitate healthcare coordination, prevention programs, referrals, support services, and access to related resources. As part of these services, we may maintain or process additional health-related information necessary to provide such support and services.

Cookies, Mobile IDs, and Similar Technologies

We use cookies, web beacons, mobile analytics and advertising IDs, and similar technologies to operate our websites and online services and to help collect data, including usage data, identifiers, and device information.

What are cookies and similar technologies?

Cookies are small text files placed by a website and stored by your browser on your device. A cookie can later be read when your browser connects to a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. This allows the web server to recognize your browser over time, each time it connects to that web server.

Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website or email. When your browser opens a webpage or email that contains a web beacon, it automatically connects to the web server that hosts the image (typically operated by a third party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our websites (such as embedded videos, plug-ins, or ads) results in your browser connecting to the third-party web server that hosts that content. We also include web beacons in our email messages or newsletters to tell us if you open and act on them.

Mobile analytics and advertising IDs are generated by operating systems for mobile devices (iOS and Android) and can be accessed and used by apps in much the same way that websites access and use cookies. Our apps contain software that enables us and our third-party analytics and advertising partners to access these mobile IDs.

How do we and our partners use cookies and similar technologies?

We, and our analytics and advertising partners, use these technologies in our websites, apps, and online services to collect personal information (such as the pages you visit, the links you click on, and similar usage information, identifiers, and device information) when you use our services, including personal information about your online activities over time and across different websites or online services. This data is used to store your preferences and settings, enable you to sign-in, analyze how our websites and apps perform, track your interaction with the site or app, develop inferences, deliver and tailor interest-based advertising, combat fraud, and fulfill other legitimate purposes. We and/or our partners also share the data we collect or infer with third parties for these purposes. For more information about the third-party analytics and advertising partners that collect personal information on our services, please see the “Disclosure of Personal Information” section of this Privacy Policy.

What controls are available?

There are a range of cookie and related controls available through browsers, mobile operating systems, and elsewhere. See the “Choice and Control of Personal Information” section below for details.

Use of Personal Information

We use the personal information we collect for purposes described in this Privacy Policy or as otherwise disclosed to you, subject to the limitations addressed in the “Protected Information” section above. For example, we use personal information for the following purposes:

Purpose of Use of Personal Information

Product and Service Delivery We use personal information to provide, maintain, and deliver the services offered through Well360, including facilitating access to healthcare coordination, prevention services, referrals, educational resources, and support programs. We may also use information to improve user experience, personalize services, troubleshoot technical issues, and ensure the functionality of our Platform. In certain situations, services may be supported by technology tools, automation systems, or artificial intelligence features designed to improve efficiency and user experience, as further described in the Well360 Terms and Conditions.

Information used for these purposes may include contact information, demographic information, payment information where applicable, uploaded content and files, device information, geolocation data, usage data, health-related information, and information voluntarily provided through communications with Well360.

Business Operations We use personal information to support our business operations, including account administration, customer support, payment processing where applicable, maintaining records, improving internal processes, monitoring and securing our systems, preventing fraud or unauthorized activities, verifying identity where necessary, complying with legal obligations, and protecting the rights, safety, and property of Well360, our users, and affiliated partners.

Information used for these purposes may include contact information, demographic information, payment information where applicable, communications, device and usage information, account-related information, health-related information when necessary, and other information required to provide and maintain our services.

Product improvement, development, and research. To develop, test, or improve the Service and content, features and/or products or services offered via the Service. Additionally, to identify or create new products or services. Lastly, to analyze traffic and user behavior or activity to and through Service. Contact information, demographic data, payment information, content and files, biometric information, identifiers and device information, geolocation data, usage data, inferences. Sensitive information: government ID, account access information, sensitive demographic data, contents of communications, biometric information for identification, health data, information about sex life or sexual orientation.

Personalization. To understand you and your preferences to enhance your experience and enjoyment using our services.Contact information, demographic data, payment information, content and files, biometric information, identifiers and device information geolocation data, usage data, inferences. Sensitive information: government ID, account access information, sensitive demographic data, contents of communications, biometric information for identification, health data, information about sex life or sexual orientation.

Customer Support We use personal information to provide customer support, fulfill your requests, respond to questions, and assist you with accessing services available through Well360. This may include helping coordinate appointments, referrals, prevention services, support programs, and related healthcare resources. In certain situations, you may interact with automated tools, chat systems, AI-supported features, or other communication channels designed to improve response times and service efficiency, as further described in the Well360 Terms and Conditions.

Information used for these purposes may include contact information, demographic information, communications submitted through the Platform, uploaded content or files, device and usage information, account information, and health-related information where necessary to provide requested services.

Communications We may use personal information to send you communications related to Well360 services, healthcare coordination, support programs, appointment confirmations, reminders, updates, technical notices, security alerts, and administrative information. We may communicate with you through email, phone calls, text messages, mail, or other available communication methods in order to provide support and facilitate access to services.

Information used for these purposes may include contact information, demographic information, communications, account information, device and usage information, and health-related information when necessary to provide requested services.

Marketing We may use personal information to communicate with you regarding new services, programs, educational resources, promotions, events, community initiatives, and information related to Well360 or selected partners whose services may be relevant to your interests.

Information used for these purposes may include contact information, demographic information, usage information, communication preferences, and other information voluntarily provided through the Platform.

Advertising We may use certain information to promote and market Well360 services, programs, and community initiatives. Advertising activities may include improving the relevance of content, measuring campaign effectiveness, and providing information that may be relevant to your interests.

Information used for these purposes may include contact information, device information, geolocation information, usage data, and other information permitted by applicable law.

We may combine information collected from different sources to improve our services and provide a more seamless, efficient, personalized, and user-friendly experience.

Additionally, we may use information regarding your interactions with the Platform, including browsing activity and use of services, to improve our programs, personalize content, understand user interests, and measure the effectiveness of our communications, outreach initiatives, and marketing efforts. Depending on your activity on the Platform, this may include information related to pages or services you access, including health-related content.

Where required by applicable law, we will obtain your consent before collecting, processing, or using sensitive personal information. We do not use Protected Information for advertising or marketing purposes. When sensitive personal information is subject to additional legal requirements or restrictions, we process and protect such information in accordance with applicable laws and regulations.

We may use information that has been de-identified or aggregated in a manner that no longer reasonably identifies an individual for legitimate business, research, analytics, reporting, service improvement, or operational purposes, as permitted by applicable law. We maintain reasonable safeguards designed to prevent re-identification of de-identified information except where permitted or required by law.

Disclosure of Personal Information

We may disclose personal information as necessary to provide services you request, fulfill transactions, support healthcare coordination, comply with legal obligations, or otherwise as permitted or required under applicable law. Subject to the limitations described in the “Protected Information” section above, we may disclose personal information to the categories of recipients described below when necessary to provide services or operate our Platform.

Service Providers We may share personal information with third-party vendors, contractors, or service providers who perform services on our behalf and assist us in operating our Platform and delivering services. Examples include providers of customer support, technology infrastructure, data storage, communications services, analytics, security monitoring, and system maintenance. These service providers may have access to personal information only to the extent necessary to perform services on our behalf and are expected to maintain appropriate safeguards for protecting such information.

Additionally, when you use communication channels available through Well360, including messaging platforms, contact forms, support systems, or automated communication tools, certain communications may be stored or processed by authorized service providers in order to facilitate service delivery and improve user experience.

Marketing and Community Outreach Partners Well360 may work with selected marketing, outreach, educational, or community partners to support awareness initiatives, prevention programs, educational campaigns, and community engagement efforts. Information shared for these purposes will be limited to what is reasonably necessary and handled in accordance with applicable laws and this Privacy Policy.

Well360 does not sell Protected Information or use Protected Information for advertising purposes. Any use of personal information for communications, outreach, or promotional activities will be conducted in accordance with applicable laws and any required consent requirements.

Financial services & payment processing. When you provide payment data, for example to make a purchase, we will disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services. For more information about such disclosures, please see the “Transactions” section below. Affiliates. We enable access to personal information across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our services and operate our business.

The Labs, Pharmacies, Medical Groups, or their Providers. We facilitate information disclosure between you and the Medical Groups, Pharmacies, Providers, and Labs, as applicable, to enable them to provide services to you via the Service and to collect payment on their behalf. Member Benefit Partners. We may disclose personal information to non-affiliated third-party partners to facilitate your enrollment in services, promotional programs, or discounts offered by such partners (collectively, “Member Benefits”). For example, if you elect to redeem a Member Benefit discount, we may provide that partner with identifying information and to verify your eligibility and ensure the delivery of the Member Benefit to you.

Corporate transactions. We may disclose personal information as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.

Legal and law enforcement. We will access, disclose, and preserve personal information when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.

Security, safety, and protecting rights. We will disclose personal information if we believe it is necessary to:

protect our customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone; operate and maintain the security of our services, including to prevent or stop an attack on our computer systems or networks; or protect the rights or property of ourselves or others, including enforcing our agreements, terms, and policies.

Third party analytics and advertising companies also collect personal information through our website and apps including identifiers and device information (such as cookie IDs, device IDs, and IP address), geolocation data, usage data, and inferences based on and associated with that data, as described in the “Cookies” section of this Privacy Policy. These third-party vendors may combine this data across multiple sites to improve analytics for their own purpose and others. For example, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information at www.google.com/policies/privacy/partners.

Other third-party analytics and advertising providers we use on our websites include, for example:

Company/Service Purpose(s) Privacy Notices Manage Settings (opt-out)

NOTICE: We will not sell your sensitive personal data. "Sell" in this context refers to "sell" as defined in certain state privacy laws.

Please note that some of our services also include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal information to any of those third parties, or allow us to share personal information with them, that information is governed by their privacy statements.

Finally, we may disclose de-identified information in accordance with applicable law.

Choice and Control of Personal Information

We provide ways for you to access and manage the personal information we maintain about you, including choices regarding how your information is used. Depending on your jurisdiction, certain privacy rights and controls may be available to you under applicable law.

Access, Correction, and Deletion Rights You may request access to, correction of, updates to, or deletion of personal information that Well360 maintains about you. To exercise any of these rights, please contact us using the contact information provided at the end of this Privacy Policy. We will review and respond to requests in accordance with applicable laws and regulations.

In certain jurisdictions, you may also have the right to request information regarding categories of third parties with whom your personal information has been shared, subject to applicable legal requirements.

Data Sharing and Privacy Choices Well360 does not sell Protected Information. To the extent applicable privacy laws define certain forms of information sharing as a “sale” or similar activity, you may exercise your privacy rights and choices by contacting us directly using the contact information provided in this Privacy Policy.

We may also recognize certain browser-based privacy controls, including Global Privacy Control (GPC), where required by applicable law.

Targeted Advertising Preferences If applicable, you may request to opt out of certain forms of targeted communications or marketing activities by contacting us directly or by following the instructions included within such communications.

Device and Browser Controls Certain privacy choices may be device-specific or browser-specific. If you access Well360 services from multiple devices or browsers, you may need to update your settings separately on each device or browser.

Communication Preferences You may choose whether to receive promotional communications from Well360 through email, text message, or other communication channels. If you no longer wish to receive promotional communications, you may opt out at any time by following the unsubscribe instructions included in the communication or by contacting us directly.

Please note that opting out of promotional communications does not affect service-related messages, appointment notifications, account updates, security notifications, or other communications necessary to provide services or fulfill legal obligations.

Browser or platform controls.

Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.

Global Privacy Control. Some browsers and browser extensions support the “Global Privacy Control” (GPC) or similar controls that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales and/or targeted advertising, as specified by applicable law. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting or similar control that is recognized by regulation or otherwise widely acknowledged as a valid opt-out preference signal.

Do Not Track. Some browsers include a “Do Not Track” (DNT) setting that can send a signal to the websites you visit indicating you do not wish to be tracked. Unlike the GPC described above, there is not a common understanding of how to interpret the DNT signal; therefore, our websites do not respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the GPC, cookie controls, and advertising controls described above.

Mobile advertising ID controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.

Email web beacons. Most email clients have settings that allow you to prevent the automatic downloading of images, including web beacons, which prevents the automatic connection to the web servers that host those images.

Except for the automated controls described above, if you send us a request to exercise your rights or these choices, to the extent permitted by applicable law, we may decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or other rights of another person, would reveal a trade secret or other confidential information, or would interfere with a legal or business obligation that requires retention or use of the data. Further, we may decline a request where we are unable to authenticate you as the person to whom the data relates, the request is unreasonable or excessive, or where otherwise permitted by applicable law. If you receive a response from us informing you that we have declined your request, in whole or in part, you may appeal that decision by submitting your appeal using the contact method described at the bottom of this Privacy Policy.

Finally, please note that this Privacy Policy applies only to your “personal information,” which is separate from “medical information” or “protected health information.” To understand our information practices and your rights with respect to such information, visit the Medical Groups Notice of Privacy Practices.

Data Retention

We retain personal information for as long as necessary to provide the services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and for other legitimate and lawful business purposes. Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the information, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.

Jurisdictional Issues

The Service may only be used within certain states within the United States as described in our Terms and Conditions. Accordingly, this Privacy Policy, and our collection, use, and disclosure of information about you, is governed by U.S. law.

Miscellaneous

We strive to use reasonable physical, technical, and administrative measures to protect information from unauthorized access, use, disclosure, alteration, and destruction. However, you must keep your account password secure and your account confidential, and you are responsible for any and all use of your account. To help us protect personal information, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts. If you have reason to believe that the security of your account has been compromised, please notify us immediately in accordance with the “Contacting Us” section below.

Miscellaneous

When using the Service, you may choose not to provide certain information; however, doing so may limit your ability to access specific features or services available through the Platform. You may also choose to opt out of receiving certain promotional communications, such as newsletters, updates, or marketing messages, by following the unsubscribe instructions included in those communications or by contacting us directly.

Please note that even if you choose to opt out of promotional communications, Well360 may continue to send you service-related communications, including account notifications, appointment information, security alerts, administrative messages, or other communications necessary to provide services and fulfill legal obligations.

At this time, Well360 may not respond to browser-based “Do Not Track” signals or similar mechanisms intended to restrict the collection of information across websites and online services. If our practices change in the future, we will update this Privacy Policy accordingly.

Well360 Health & Prevention LLC reserves the right to supplement, amend, revise, or otherwise modify this Privacy Policy at any time. Any changes will be posted through the Platform and will become effective as of the revised “Last Updated” date. If material changes are made that affect how we collect, use, or disclose personal information, we may provide additional notice through email, the Platform, or other reasonable means where required by applicable law.

It is your responsibility to review this Privacy Policy periodically each time you access or use the Service.

Contacting Us If you have any questions regarding this Privacy Policy, your privacy rights, or how your information is collected, used, or maintained, please contact us at:

Well360 Health & Prevention LLC Website: Well360 Connect Email: [email protected]

ATTN: Privacy Officer