Effective date: January 1, 2020

At MyHealthID, Inc. ("MyHealthID," "we," or "us"), our most important value is ‘Patients First', which means that we are committed to protecting your privacy and we take great care with your personal information that we gather when you access or use MyHealthID.com and related websites, applications, and services owned and operated by MyHealthID and that link to this Privacy Policy (collectively, the "Services"). This Privacy Policy is meant to help consumers that use our Services to explore providers or book appointments ("Consumers") and providers and health systems that use our marketing services ("Clients," and collectively with Consumers, "you," or "your")understand how we treat your personal information. BY USING OR ACCESSING THE SERVICES IN ANY MANNER, YOU ACKNOWLEDGE THAT YOU ACCEPT THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY, AND YOU HEREBY CONSENT THAT WE WILL COLLECT, USE, AND SHARE YOUR INFORMATION IN THE FOLLOWING WAYS. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU MAY NOT USE THE SERVICES. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL'S OR ENTITY'S BEHALF. A Consumer's use of MyHealthID's Services is at all times subject to the Agreement (as the term "Agreement" is defined in our Terms of Use, which incorporates this Privacy Policy).You may print a copy of this Privacy Policy by clicking here. You can also learn more at MyHealthID.com/trust.Thank you so much for choosing MyHealthID.

Privacy Policy Table of Contents

HIPAA and PHI

Personal Data

Tracking Tools, Advertising and Opt-Out

Data Security and Retention

Children's Privacy

How We Use Information That is Neither Personal Data nor PHI

Controlling Your Personal Data & Notifications

California Rights

Changes to this Privacy Policy

Contact Information

HIPAA and PHI

Certain demographic, health and/or health-related information that MyHealthID collects about Consumers as part of providing the Services to our Clients may be considered "protected health information" or "PHI" under the Health Insurance Portability and Accountability Act ("HIPAA"). Specifically, when MyHealthID, acting as a "Business Associate" (as such term is defined in HIPAA) receives identifiable information about a Consumer from or on behalf of a Client, or Customer's doctor, dentist, or other healthcare specialist, professional, provider, organization or agent or affiliate thereof (collectively, "Healthcare Providers"), this information is considered PHI. Personal data that a Consumer provides to MyHealthID outside of the foregoing context is not PHI. For example, when you provide information directly to us, such as when creating an account or using our interactive tools and services, searching for Healthcare Providers or available appointments with Healthcare Providers, and completing medical history forms ("Medical History Forms"); or when you voluntarily provide information in free-form text boxes through the Services or through responses to surveys and questionnaires, or post reviews; or when you send us an email or otherwise contact us, that information is not PHI.

HIPAA provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed. MyHealthID may only use and disclose PHI in the ways permitted by a Consumer's Healthcare Provider(s) or authorized by a Consumer.

Personal Data

The following subsections detail the categories of Personal Data that we collect and have collected over the past twelve (12) months. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules or regulations. For each category of Personal Data, these subsections also set out the source of that Personal Data, our commercial or business purpose for collecting that Personal Data and the categories of third parties with whom we share that Personal Data.More information regarding those sources and categories are set forth below.

Consumer Personal Data

THE FOLLOWING SUBSECTIONS APPLY ONLY TO CONSUMERS. IF YOU ARE A CLIENT, PLEASE SEE THE CLIENT PERSONAL DATA SECTION BELOW.

Categories of Personal Data We Collect

Categories of Sources of Personal Data

Commercial or Business Purposes for Collecting Data

How We Share Your Personal Data

  • Selected Recipients
  • Client Personal Data

    THE FOLLOWING SUBSECTIONS APPLY ONLY TO CLIENTS. IF YOU ARE A CONSUMER, PLEASE SEE THE CONSUMER PERSONAL DATA SECTION ABOVE.

    Categories of Personal Data We Collect

    Categories of Sources of Personal Data

    Commercial or Business Purposes for Collecting Data

    How We Share Your Personal Data

    In certain circumstances, we may share your Personal Data with the following categories of service providers and other third parties for the indicated business purposes:

    THE FOLLOWING SECTIONS APPLY TO BOTH CONSUMERS AND CLIENTS.

    Business Transfers

    All Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

    Tracking Tools, Advertising and Opt-Out

    The following sections provide additional information about how we collect your Personal Data.

    Information Collected Automatically

    The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, mobile identifiers, and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser and tell us how and when you visit and use our Services. We do this to analyze trends, learn about and advertise to our user base, and operate and improve our Services. For example, we use Cookies to tailor the Services or customize advertisements by tracking navigation habits, measuring performance, storing authentication status so re-entering credentials is not required, customizing user experiences with the Services and for analytics and fraud prevention. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

    We use the following types of Cookies:

    • Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested.For example, certain Cookies enable you to log into the secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
    • Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
    • Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services such as by collecting information about the number of visitors to the Services, what pages visitors view on our Services, how long visitors are viewing pages on the Services, mouse clicks, mouse movements, scrolling activity, and text typed into the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services' content for those who engage with our advertising. For example, Google Inc. ("Google") uses cookies in connection with its Google Analytics services. Google's ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google's use of cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
    • Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled "Information about Interest-Based Advertisements."
    • Web Beacons. Web Beacons (e.g., clear GIFs or pixel tags) are tiny graphic image files embedded in a web page or email that may be used to collect information about the use of our Services, the web services of selected advertisers and the emails, special promotions or newsletters that we send. The information collected by Web Beacons allows us to analyze how many people are using the Services, using selected publishers' web services or opening emails, and for what purpose, and also allows us to enhance our interest-based advertising (discussed further below).
    • Mobile Device Identifiers. Mobile device identifiers help MyHealthID learn more about our users' demographics and internet behaviors. Mobile device identifiers are data stored on mobile devices that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it.Mobile device identifiers enable collection of Personal Data (such as media access control, address and location, and tracking data, including without limitation IP address, domain server, type of device(s) used to access the Services, web browser(s) used to access the Services, referring webpage or other source through which you accessed the Services, other statistics and information associated with the interaction between your browser or device and the Services).
    • Cross Device Matching. To determine if users have interacted with content across multiple devices and to match such devices, we may work with partners who analyze device activity data and/or rely on your information (including demographic, geographic and interest-based data). To supplement this analysis, we may also provide de-identified data to these partners. Based on this data, we may then display targeted advertisements across devices that we believe are associated or use this data to further analyze usage of Services across devices.

    You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You may also be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. You can also delete all Cookies that are already on your computer. Although you are not required to accept Pverfiy's Cookies, if you block, reject, or delete them, you may have to manually adjust some preferences every time you visit a site and some of the Services and functionalities may not work.

    To explore what Cookie settings are available to you, look in the "preferences" or "options" section of your browser's menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

    Your browser may offer you a "Do Not Track" option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Not all browsers offer a Do Not Track option and there is currently no industry consensus as to what constitutes a Do Not Track signal. Please note that, for these reasons and because of our use of Cookies, our Services, like many website operators, do not support "Do Not Track" requests sent from a browser at this time. To find out more about "Do Not Track," you can visit www.allaboutdnt.com.

    Information about Interest-Based Advertisements:

    We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors ("Interest-Based Ads"). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived or inferred from the online activity or usage patterns of particular users on the Services and/or services of third parties. Such information may include IP address, mobile device ID, operating system, browser, web page interactions, geographic location and demographic information, such as gender and age range. Such information may be gathered through tracking users' activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including Web Beacons, from an ad network to you through the Services. Web Beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. This information helps MyHealthID learn more about our users' demographics and internet behaviors. Web Beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web Beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

    We comply with the Digital Advertising Alliance ("DAA") Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative ("NAI"), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer's online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA's or NAI's consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices, or install the DAA's AppChoice app (for iOS; for Android) on your mobile computing device. When you use these opt-out features, an "opt-out" Cookie will be placed on your computer, tablet or mobile computing device indicating that you do not want to receive Interest-Based Ads from NAI or DAA member companies. If you delete Cookies on your computer, tablet or mobile computing device, you may need to opt out again. For information about how to opt out of Interest-Based Ads on mobile devices, please visit http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device. You will need to opt out of each browser and device for which you desire to apply these opt-out features.

    Please note that even after opting out of Interest-Based Ads, you may still see MyHealthID advertisements that are not interest-based (i.e., not targeted toward you). Also, opting out does not mean that MyHealthID is no longer using tracking tools — MyHealthID still may collect information about your use of the Services even after you have opted out of Interest-Based Ads and may still serve advertisements to you via the Services based on information collected via the Services.

    Data Security and Retention

    The security of your Personal Data is important to us. We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. We endeavor to follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and in storage. For example, the Services use industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of Personal Data. We store and process your information on our servers in the United States and abroad. We maintain what we consider industry standard backup and archival systems. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, for example, by making good faith efforts to store Personal Data in a secure operating environment that is not open to the public, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot and do not guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.

    If at any time during or after our relationship we believe that the security of your Personal Data may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us in your account profile. Please keep your e-mail address in your account up to date. You can update that e-mail address anytime in your account profile. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your e-mail account using your computer or mobile device and email application software. You consent to our use of e-mail as a means of such notification. If you prefer for us to use the U.S. Postal Service to notify you in this situation, please e-mail us at Privacy-@.com. Please include your address when you submit your request. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this e-mail address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Data.

    We retain Personal Data about you consistent with all internal policies and procedures. We may retain Personal Data to comply with our legal obligations, resolve disputes or collect fees owed, or as is otherwise permitted or required by our data retention policies and procedures.

    Children's Privacy

    The Services are not directed to or intended for use by children under 13 years of age. If you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. By accessing, using and/or submitting information to or through the Services, you represent that you are not under the age of 13. As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under the age of 13. If we learn that we have received any Personal Data directly from a child under age 13 without first receiving his or her parent's verified consent, we will use that Personal Data only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services. We will then subsequently delete that child's Personal Data. If you believe that a child under 13 may have provided us with Personal Data, please contact us at Privacy@.com.

    If you are between age thirteen (13) and the age of majority in your place of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. If you are a parent or legal guardian of a minor child, you may, in compliance with the Agreement, use the Services on behalf of such minor child. Any information that you provide us while using the Services on behalf of your minor child will be treated as Personal Data as otherwise provided herein.

    If you use the Services on behalf of another person, regardless of age, you agree that MyHealthID may contact you for any communication made in connection with providing the Services or any legally required communications. You further agree to forward or share any such communication with any person for whom you are using the Services on behalf.

    How We Use Information That is Neither Personal Data nor PHI

    We may use information that is neither Personal Data nor PHI (including non-PHI Personal Data that has been de-identified and/or aggregated) to better understand who uses myHealthID and how we can deliver a better digital healthcare experience, or otherwise at our discretion.

    Controlling Your Personal Data & Notifications

    If you are a registered user of the Services, you can modify certain Personal Data or account information by logging in and accessing your account. If you wish to close your account, please email us at Privacy@ MyHealthID.com. MyHealthID will use reasonable efforts to delete your account as soon as reasonably possible. Please note, however, that MyHealthID reserves the right to retain information from closed accounts consistent with all internal data retention policies and procedures.

    You must promptly notify us if any of your account data is lost, stolen or used without permission.

    California Rights

    The California Consumer Privacy Act of 2018 ("CCPA") provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights. If you have any questions about this section or whether any of the following applies to you, please contact us at Consumer-Privacy@MyHealthID.com and indicate "California Rights" in the subject line of your communication.

    Access

    You have the right to request certain information about our collection and use of your Personal Data over the past 12 months, including the following:

    • The categories of Personal Data that we have collected about you.
    • The categories of sources from which that Personal Data was collected.
    • The business or commercial purpose for collecting or selling your Personal Data.
    • The categories of third parties with whom we have shared your Personal Data.

    • The specific pieces of Personal Data that we have collected about you.

    If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient.

    pIf we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data purchased by each category of third-party recipient.

    Deletion

    You have the right to request that we delete the Personal Data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

    Exercising Your Rights

    To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a "Valid Request." We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.

    We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

    You may submit a Valid Request using the following methods:

    • Submitting a request by following the instructions found at https://www. MyHealthID.com/privacy-settings
    • Emailing us at: Consumer-Privacy@MyHealthID.com

    Personal Data Sales Opt-Out

    In this section, we use the term ‘sell' as it is defined in the CCPA. We sell your Personal Data, subject to your right to opt-out of these sales.

    We sell your Personal Data to the following categories of third parties:

    • Advertisers

    Over the past twelve months, we have sold the following categories of your Personal Data to third parties:

    • Demographic Data
    • Web analytics or other similar network activity information

    You have the right to opt-out of the sale of your Personal Data. You can opt-out using the following methods:

    • Submitting a request by following the instructions found at https://www. MyHealthID.com/privacy-settings
    • Emailing us at: Consumer-Privacy@MyHealthID.com

    We do not sell the Personal Data of minors under 16 years of age without affirmative authorization

    We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

    We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates, or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

    Other California Resident Rights

    Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties' direct marketing purposes; in order to submit such a request, please contact us at Consumer-Privacy@MyHealthID.com.

    Changes to this Privacy Policy

    We reserve the right to amend our Privacy Policy at our discretion and at any time. When we make changes to the Privacy Policy, we will notify you by email or through a notice on our website homepage. Use of the information we collect is subject to the Privacy Policy in effect at the time such information is collected.