Privacy Policy

iWILL 'til i'mWELL, Inc., as well as our vendors, partners, consultants, and affiliates respect the privacy of its members and users of web site. Our policy regarding privacy information that is collected and how that data is used is outlined below.

iWILL 'til i'mWELL has developed all the system technologies, including the interfaces to the technology systems provided by third party providers. iWILL 'til i'mWELL, Inc. manages the data security for this site. All data is stored in encrypted format that meets standards defined by HIPAA (Health Insurance Portability and Accountability Act). All data transfer is executed using similar standards that meet or exceed HIPAA, and no data is transferred to users that do not have specific data access keys.

The importance of security for all personal information associated with you, your family, and that which you share with your primary care physician (PCP), is of extreme concern to us. At iWILL 'til i'mWELL, we put into practice state of the art care in providing secure transmission of your information from your personal computer to our servers. Personal information collected by our web site is stored in secure operations environments that are not available to the public; and firewalled. Only those employees who require access to your information in order to do their jobs are allowed access, and each have signed a confidentiality agreement that is on-file. Any employee who violates our privacy or security policies is subject to disciplinary action, up to, and including, termination and civil and/or criminal prosecution.

Any information that you submit to us via our Website - whether a survey, registration form, personal history form, or e-mail will be used exclusively by the consulting physicians and only for the specific reason for which they were submitted.

We take every reasonable precaution to protect your personal information including encryption and passwords.

iWILL 'til i'mWELL is the sole owner of the information collected on this site. We will not sell, share or lease this information to others. iWILL 'til i'mWELL does not sell customer lists, e-mail addresses, cookies or other data.

Cookies are data stored on the user's hard drive containing information about the user's browsing history. Usage of a cookie is not linked to any personally identifiable information while visiting the iWILL 'til i'mWELL.com website. Once users close their browser, cookies simply terminate. iWILL 'til i'mWELL software never uses cookies to retrieve information from your computer that was not already originally sent in a cookie. Except as described in this Policy, we do not use information transferred through cookies for any promotional or marketing purposes, nor is that information shared with any third parties whatsoever.

By using this site and the iWILL 'til i'mWELL service, you signify your acceptance of this Privacy Policy, as stated. If you do not agree to this policy, you should not continue, and you should not use our service. Should we make any changes to the iWILL 'til i'mWELL Privacy Policy, we will post these changes prominently so users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We recommend that you read this Privacy Policy each time you use our Website in case you missed our notice of changes to the Privacy Policy. Your continued use of the services and site following the posting of changes to these terms will mean you accept those changes.

iWILL 'til i'mWELL welcomes your questions and comments about privacy, in general, and our privacy policy, specifically. If you have any questions about our policies or our site, please Contact Us.

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED, AND DISCLOSED, AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY AND REPORT ANY ISSUES, OR CONCERNS, TO: iWILL 'til i'mWELL HIPAA COMPLIANCE DEPARTMENT, 123 E San Carlos St San Jose, CA 95112; PHONE. 833-237-5455.

The Health Insurance Portability & Accountability Act of 1996 (HIPAA) is a federal program requiring that all medical records and other individually identifiable health information used, or disclosed, by us in any form, whether electronically, on paper, or orally, are kept properly confidential. This Act gives you, the Patient, significant new rights to understand and control how your health information is used. HIPAA provides penalties for covered entities that misuse personal health information.

We have prepared this "Notice of HIPAA Privacy Practices" to explain how we are required to maintain the privacy of your health information and how we may use and disclose your health information.

We may use and disclose your medical records for each of the following purposes: treatment, payment, and health care operations:

TREATMENT means providing, coordinating, or managing health care and related services by one or more health care providers

PAYMENT means such activities as obtaining payment or reimbursement for services, billing or collection activities and utilization review. HEALTHCARE OPERATIONS include managing your Electronic Medical Record to facilitate diagnostic medical consultations with associated physicians, as well as conducting quality assessment review and service improvement planning activities, auditing functions, cost-containment analysis, and customer service.

We may also create and distribute de-identified health information by removing all references to individually identifiable information.

We may contact you to provide information about our services or other health-related services that may be of interest to you.

Any other uses and disclosures will be made only with your written authorization. You may revoke such authorization in writing and we are required to honor and abide by that written request, except to the extent that we have already taken actions relying on your authorization.

You have the following rights with respect to your protected health information, which you can exercise by presenting a written request to the iWILL 'til i'mWELL HIPAA Compliance Department at 123 E San Carlos St San Jose, CA 95112; PHONE. 833-237-5455:

• You have the right to ask for restrictions on the ways we use and disclose your health information for treatment, payment, and healthcare operations. You may also request that we limit our disclosures to persons assisting your care. We will consider your request, but are not required to accept it.
• You have the right to request that you receive communications containing your protected health information from us by alternative means or at alternative locations. For example, you may ask that we only contact you at home or by mail.
• Except under certain circumstances, you have the right to inspect and copy medical, billing and other records used to make decisions about you. If you ask for copies of this information, we may charge you a nominal fee for copying, packaging, and postage.
• If you believe that information in your records is incorrect, or incomplete, you have the right to ask us to correct the existing information, or add missing information. Under certain circumstances, we may deny your request, such as when the information is accurate and complete.
• You have a right to receive a list of certain instances when we have used or disclosed your medical information. If you ask for this information from us more than once every twelve months, charges may apply, to cover our costs for administration, archive retrieval, copying, packaging, and postage.

Effective Date: 1/1/2019

Last Updated: 1/1/2023

This Privacy Notice for California Residents section applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you").

Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, iWILL 'til i'mWELL ("Company" or "The Company") and iWILL 'til i'mWELL's portals located at https://portal.getiWILL 'til i'mWELL.com ("Website"), have collected the following categories of personal information from its consumers within the last twelve (12) months:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's and CPRA's scope, like:

1. health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
2. personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

iWILL 'til i'mWELL obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.

We may use, or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA and CPRA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of iWILL 'til i'mWELL's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by iWILL 'til i'mWELL about our Website users is among the assets transferred.

iWILL 'til i'mWELL will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

iWILL 'til i'mWELL may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

• Service providers.
• Data aggregators.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

[Category A: Identifiers.]

[Category B: California Customer Records personal information categories.]

[Category C: Protected classification characteristics under California or federal law..]

[Category D: Commercial information.]

[Category E: Biometric information.]

[Category F: Internet or other similar network activity.]

[Category G: Geolocation data.]

[Category H: Sensory data.]

We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers.
• Data aggregators.

Sales of Personal Information

Company does not sell personal information. In the preceding twelve (12) months, Company has not sold personal information.

The CCPA and CPRA provide consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA and CPRA rights, and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that iWILL 'til i'mWELL disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

You have the right to request that iWILL 'til i'mWELL delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you or your benefit provider(s) have requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or your benefit provider(s), or otherwise perform our contract with you or your benefit provider(s).
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us or that of the benefit provider(s).
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

You have the right to request that iWILL 'til i'mWELL corrects inaccurate personal information

Right to Limit Use and Disclosure

You have the right to request that iWILL 'til i'mWELL limits the use and disclosure of sensitive personal information.

Exercising Access, Data Portability, Deletion, Correction, and Limit Use and Disclosure Rights

To exercise the access, data portability, deletion, correction, and limit use and disclosure rights described above, please submit a verifiable consumer request to us by either:

• Submitting a request via our Privacy Center at privacy.iwilltilimwell.com
• Calling us at 833-237-5455; or
• Writing us at 123 E San Carlos St San Jose, CA 95112

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

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

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

iWILL 'til i'mWELL reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.