Switchbridge has created this Privacy Policy to explain how and why we collect information from users of the Wellth App and how Switchbridge protects your personal privacy within the Wellth App. Switchbridge takes very seriously its obligation to protect the confidentiality of your personal information.

To understand your rights fully, we encourage you to read this Privacy Policy and the Terms of Use Agreement (which is incorporated by reference). Switchbridge reserves the right at any time and without notice to change this Privacy Policy by posting such changes on the Wellth App. Any such change will be effective immediately upon posting unless otherwise provided in the posting. By using the Wellth App, you agree to this Privacy Policy. You should visit this page from time to time to review the current Terms of Use because by your use of the Wellth App you agree to be bound by the Terms of Use and Privacy Policy in effect at that time. Your use of the Wellth App following revisions and modifications of the Privacy Policy constitutes your agreement to the current policy. If you do not agree to the Privacy Policy, do not use the Wellth App.

Switchbridge is fully committed to protecting the security and privacy of your personal information and we comply with all applicable laws concerning data security and privacy.

As used in this Privacy Policy, “Switchbridge” means Switchbridge and where appropriate, its affiliated and parent organizations.

What Information We Collect and How We Use That Information

The Wellth App is used to help you manage and track your medical and fitness information and to allow you to share that information with certain third parties, including health plans, insurance carriers, caregivers, healthcare providers, authorized service providers and emergency first responders. Necessarily, information and data that identifies you directly or indirectly is collected and maintained to help serve those purposes. For example, you may complete a Health Risk Assessment (HRA) through the Wellth App or otherwise input or upload (or cause or authorize to be uploaded) certain medical information, fitness information, etc. to the Wellth App. Your responses on the HRA and the information you input (or otherwise cause to be uploaded) to the Wellth App (which may include but not be limited to health plan claims information, family information, records of fitness activities in which you engage, records of medical conditions and treatment, biometric data, preventive health screenings, etc.) are also maintained on the Wellth App if you choose to use the Wellth App to track those activities and records and/or make them available to healthcare providers, first responders, etc.

Information collected can be used by you to track your own progress. Information may also be used by the Wellth App to offer you services or notify you of information and promotions that may be beneficial to you based on information you have provided and/or requested through the Wellth App.

These are the types of information we gather: Contact information, insurance plan information, biometric data, medical conditions, prescription and medications, fitness metrics, allergies, emergency contacts and other related data.

This information will be used by the Wellth App and by Switchbridge to: Provide you with centralized and accessible storage of the Wellth App data in a central application, while also analyzing data and providing information about your health and how you can be healthier. Many services are on an “opt-in” basis and can be discontinued by you at any time.

Opting Out

We understand that you may want to opt out of direct messaging from your health benefits, wellness programs, and disease specific support tools and/or teams that are actively trying to assist you in your health journey. Switchbridge at times, may allow health, fitness, financial health literacy, and the like to contact you based on your participation in the Wellth app, and/or by direction of your employer who offers such benefits to assist in the health of their workforce. Participation in such programs is at your discretion. The Wellth app delivers content, articles, promotion tools, health lessons, and similar via the interface within Wellth. As noted, by sharing these tools in no way is an endorsement of the programs, tools, education, methods of intervention, or statement of need by allowing you to explore such tools. However, should you choose to Opt-Out of such tools, the Wellth app will notify the above mentioned groups to request no contact, to honor such request. Please allow up to 30 business days for the request to be shared, and accepted by such tools, benefits programs, wellness intervention, etc. As these groups operate independently outside of Switchbridge’s control, we take no responsibility for the actions of such groups, beyond sharing your preferences of contact and requesting an opt-out of any communications.

How We Protect Your Information

We agree to respect your privacy and treat all individually identifiable information that we receive from or about you (your “Personal Information”) as confidential. The Personal Information that you provide through the Wellth App will be used by Switchbridge to allow you to manage and track and your medical information (as set forth in the Terms of Use Agreement) and allow you to share such information with your health plans/insurance carriers, caregivers, healthcare providers, authorized service providers and emergency first responders.

It is our goal to maintain compliance with the highest standards of mobile application privacy so you may safely use the Wellth App for the indicated purposes. We do that by making use of industry standard data and communications encryption technologies, by separating patient and protected healthcare information in transmissions of this data wherever possible via electronic means and by taking all reasonable measures to

prevent unauthorized access to any of your information within the control of Switchbridge.

To ensure privacy of your information, never share your mobile device or your username and password for the Wellth App or mobile device with anyone whom you do not want to access your information.

The Wellth App does offer links to, or refer to, websites and/or third party applications that we do not control. The Privacy Policy does not apply to such other websites or applications and Switchbridge has no responsibility for the privacy practices of such websites or applications not controlled by Switchbridge. You understand that while connected, or attempting to connect, to a website or third party application, (including but not limited to an application of a healthcare provider, health plan/insurance carrier, first responder, etc.), such website or application may collect, store, process, maintain, upload, sync, transmit, share, disclose and use certain data and related information, including but not limited to information or data regarding the characteristics or usage of your device, system, application software, and peripherals, as well as your personal information, location data and other content.

Please contact your healthcare institution, healthcare provider, health plan/insurance carrier, etc. if you have questions about their policies or terms.

Security

The security of your information and data while using the Wellth App is very important to us. We take reasonable measures to protect personally identifiable information and to protect such information from loss, misuse, unauthorized access, and unintended disclosure. All information provided to the Wellth App is transmitted using SSL (Secure Socket Layer) encryption. SSL is a proven coding system that lets your browser automatically encrypt, or scramble, data before you send it to us. We also protect any account information by placing it on a secure portion of the Wellth App that is only accessible by certain qualified employees of Switchbridge. Unfortunately, however, no data transmission over the Internet or via mobile application is 100% secure. While we strive to protect your information, we cannot guarantee, ensure or warrant the security of such information. If we become aware of a security breach compromising your personal information, we will make all legally required disclosures. In addition, healthcare providers and insurers with whom you connect may use a variety of physical, administrative and technical measures to protect your personal information, although we have no control over such entities.

Children's Privacy

The Wellth App is not intended for children under the age of 18 and should not be used by children under 18. Under no circumstances should the Wellth App be used by children under 13 years of age, pursuant to the Children’s Online Privacy Protection Act of 1998 (as amended) and we will not knowingly collect personally identifiable information from any person we know to be in this age group.

Contacting the Wellth App

If you have any questions about this Privacy Policy, the practices of the Wellth App, or your dealings with the Wellth App, you can contact us by filling out the form below.

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