Privacy Policy and Terms

1. Introduction

This Privacy Policy and Terms ("Privacy Policy" or "Policy") describes how GuideWell Simplifi, Inc. ("GuideWell Simplifi," or "we," "our," or "us") collects and uses Personal Information about you through the use of our Website, mobile applications, and through email, text, and other electronic communications ("Electronic Communications") between you and GuideWell Simplifi. For purposes of this Policy, "GuideWell Simplifi" includes GuideWell Simplifi's affiliated companies that support GuideWell Simplifi.

This Policy describes the types of information we may collect from you or that you may provide when you visit or use our website (our "Website"), our Member Portal ("Member Portal"), our GuideWell Simplifi mobile applications (our "App"), or other GuideWell Simplifi digital tools used to communicate with you and collect your information, and our practices for collecting, using, maintaining, protecting, and disclosing that information. For purposes of this Policy, our Website, Member Portal, App, and all related tools, services, and functionality that we provide through them are referred to as our "Digital Services."

This Policy applies to information we collect: through our Digital Services; in email, texts, and other electronic messages, uploads, and other collection mechanisms when you interact with our Digital Services; and when you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this Policy.

The Policy does not apply to information collected by: us offline or through other means, including any other website operated by GuideWell Simplifi or any third-party; or any third-party, including through any application or content (including advertising) that may link to or be accessible from or on the Digital Services.

If you are an enrollee covered under a GuideWell Simplifi health plan then our Notice of Privacy Practices, and not this Privacy Policy, governs our collection of information that we may use in the course of providing or administering your health insurance coverage. Our Notice of Privacy Practices can be found at .

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Digital Services. By accessing or using our Digital Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of our Digital Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

2. Health Information

Some information we collect may include health and/or medical information that constitutes your protected health information ("PHI") records protected under the U.S. Health Insurance Portability and Accountability Act of 1996 and its implementing regulations ("HIPAA"). You understand that if you choose to use our Digital Services to download, print, or share any of your PHI records then such information may no longer be protected under HIPAA.

3. Children Under the Age of 18

Our Digital Services are not intended for users or visitors under 18 years of age. No one under age 18 may provide any information to or through the Digital Services. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on or in our Digital Services or on or through any of their features, including your name, address, telephone number, email address, or any screen name or username you may use.

4. Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you, but individually does not personally identify you, and information that we combine with information about our other users. This includes information that we collect directly from you or through automated collection technologies.

Generally

We collect several types and categories of information from and about users of our Digital Services, more specifically:

• Information by which you may be personally identified, which may include your name, postal address, billing address, shipping address, e-mail address, telephone number(s), date of birth, health information, financial information, and other personal information described in this Policy ("Personal Information").
• Information that is about you, but individually does not identify you, such as traffic data, logs, referring/exit pages, date and time of your visit to, or use of, our Digital Services, error information, clickstream data, and other communication data and the resources that you access and use on or through our Digital Services.
• Information about your Internet connection, the equipment you use to access or use our Digital Services and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through or use our Digital Services. Information collected automatically may include usage details, IP addresses, session replay and recoding technology (recording your movements, clicks, etc. on our Digital Services), and information collected through cookies, web beacons, pixels tags and other tracking technologies.
• Through the use of the global positioning system and Cell ID ("Geolocation") which allows us to collect your precise or estimated location in real-time.
• From third parties, for example, including affiliates, vendors, covered entities, and other business partners.

Information You Provide to Us

The information we collect on or through our Digital Services includes:

• Personal Information such as the data identified above.
• Information that you provide by filling in forms on our Digital Services. This includes, or may include, information provided at the time of registering to use our Digital Services, using our services or other services available through the Digital Services, purchasing products, or requesting further services. We may also ask you for information when you report a problem with our Digital Services.
• Information we need to process your inquires and requests, such as when you are shopping for insurance, getting quotes from us, search for the right plan, searching for a doctor, applying for insurance, etc.
• If you are an existing member, we will need personal information from you to confirm your membership, set up your online account, and provide you with the information and functionality when you use the member-only portions of our Member Portal and Digital Services.
• Records and copies of your correspondence, including email addresses, if you contact us.
• Your responses to surveys that we might ask you to complete for research, development, and marketing purposes.
• Details of transactions you carry out through our Digital Services and of the fulfillment of an application, order, or other requests. You may be required to provide financial information before completing a transaction through our Digital Services.

You may also provide information to be published or displayed (hereinafter, "posted") on public areas of the Digital Services or transmitted to other users of the Digital Services or third-parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Digital Services with whom you may choose to share your User Contributions. Therefore, we cannot, and do not, guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Digital Services, we may use automatic data collection technologies (such as session replay and tracking technologies referred to above) to collect certain information about your equipment, browsing actions, and patterns, including, more specifically:

• Usage Details. Details of your visits to our Digital Services, such as traffic data, location, logs, referring/exit pages, date and time of your visit to or use of our Digital Services, error information, clickstream data, and other communication data and the resources that you access and use on or in the Digital Services.
• Device Information. Information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, browser type, and App version information.
• Location Data. Information about your location collected through Geolocation technology.

The information we collect automatically may include Personal Information. Also, we may aggregate, associate, and/or maintain the information we collect with Personal Information we obtain in other ways or receive from third parties. In addition to other permitted uses, it helps us to improve our Digital Services and to deliver a better and more personalized service by enabling us to:

• Estimate our audience size and usage patterns.
• Improve our customer service responses and response times.
• Improve our product and service offerings.
• Store information about your preferences, allowing us to customize our Digital Services according to your individual interests.
• Recognize you when you return to our Digital Services.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). We and our service providers may use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Digital Services through your computer or mobile device. A cookie is a small file or piece of data sent from a website and stored on the hard drive of your computer or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access or use certain parts of our Digital Services. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or use our App.
• Pixels and Web Beacons. Pages on our Digital Services, or our e-mails, may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related Digital Services statistics (for example, recording the popularity of certain Digital Services content and verifying system and server integrity).

5. How We Use Your Information

We may use information that we collect about you or that you provide to us, including any Personal Information:

• To provide to you our Digital Services and its functionality, contents, and services.
• To provide our products and services.
• To provide you with information, products, or services that you request from us or that may be of interest to you.
• To process, fulfill, support, and administer transactions and orders for products and services.
• To provide you with notices about your GuideWell Simplifi account, coverage, or policy.
• Enforce our rights arising from contracts.
• To contact you in response to a request.
• To fulfill any other purpose for which you provide the information.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Digital Services or any products or services we offer or provide though them.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about plans, products, goods, and services that may be of interest to you, including through e-mail and newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications or by visiting your Account Preferences page. You may still, however, receive transactional or other content that is not commercial marketing content.

6. Disclosure of Your Information

We may disclose Personal Information that we collect, or that you provide as described in this Policy:

• To affiliates, contractors, service providers, and other third parties we use to support our businesses. The services provided by these organizations include, but are not limited to, providing it and infrastructure support services, advertising, marketing, and payment processing services. Advertising and marketing partners such as Facebook, Instagram, Google, and other advertising networks may receive and use your personal information to assist us with our advertising and marketing efforts.
• To a buyer or other successor in interest in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our digital services users are among the assets transferred.
• To fulfill the purpose for which you provide the information.
• For any other purpose disclosed by us when you provide the information.
• With your consent.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To affiliates and third parties to market or advertise their products or services to you if you have not opted out of these disclosures, unless prohibited by applicable law and regulation. This type of sharing may be deemed a sale of personal information under some laws or jurisdiction. Facebook, Instagram, Google, and other advertising networks may have the ability to use your personal information for their own marketing, advertising, or business purposes.
• To enforce or apply our website and member portal terms of use, and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect our rights, property, or safety or that of our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

We may also disclose aggregated information about our users, and information that does not identify any individual.

7. Choices About How We Use and Disclose Your Information

We may offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Information for our advertising to you, and other targeted content.

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. These third parties may aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with control over your Personal Information:

• Tracking Technologies and Advertising. You can set your browser or operating system to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Digital Services may then be inaccessible or not function properly.
• Promotional Offers from GuideWell Simplifi. If you do not wish to have your email address used by GuideWell Simplifi to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or logging onto your Account Preferences page. This opt-out does not apply to information provided by GuideWell Simplifi as a result of enrollment in a plan, a product purchase, or your use of our services. You may still receive transactional or other content that is not commercial marketing content. You may have other options with respect to marketing and communication preferences through our Digital Services.
• Disclosure of Your Information to Affiliates and Third Parties. By using our Digital Services, you consent to our sharing of your Personal Information with our affiliates and third parties for their promotional purposes to the extent permitted by applicable law and regulation. If you wish to unsubscribe from such affiliate and third parties' promotions, you can do so by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from them or other mechanism provided the affiliate or third-party.
• Targeted Advertising. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative ("NAI") websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt-out, you will continue to see ads, but they will not be based on your online activity. We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt-out of receiving targeted ads from members of the NAI on its website.

8. Your Rights Regarding Your Information and Accessing and Correcting Your Information

You may contact us to access or change your Personal Information. You may also be able to review and change your personal information by logging into the Digital Service and visiting your Account Preferences page.

You can review certain Personal Information by logging into our Sites and visiting either the user settings or preferences sections of our Sites. Depending on the nature of your GuideWell Simplifi product or service, you may be able to change some Personal Information on our Sites or by notifying us through the Contact Information below. In some cases, you may have to contact a third-party, for example, your employer or a government agency. We may not be able to change or delete certain information in order to comply applicable laws and regulations.

9. Do Not Track Signals

We do not honor do-not-track signals that may be sent by some browsers.

Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they "do not track" your online activities. We do not honor such signals.

10. Data Security

Information transmitted over the Internet is not completely secure and by accessing our Digital Services you agree to accept this inherent risk. You can help protect your Personal Information and other information by keeping your password to our Digital Services confidential and not sharing it with anyone.

We are not responsible for circumvention of any privacy settings or security measures contained for the Digital Services.

11. Electronic Communications

You should be careful when sending health information to us and communicating with us electronically. Information submitted to us, or communicated, through our Website (e.g., outside of a secure portal or messaging application) may not be encrypted. There are certain risks associated with sending PHI and Personal Information through unencrypted means.

Risks of Using Unencrypted Electronic Communications

The use of unencrypted Electronic Communications has a number of risks that you should consider. These risks include, but are not limited to, the following:

• Electronic Communications can be circulated, forwarded, stored electronically and on paper, and broadcast to unintended recipients.
• Senders can misaddress an Electronic Communication and send the information to an undesired recipient.
• Backup copies of Electronic Communications may exist even after the sender and/or the recipient has deleted his or her copy.
• Employers and on‐line services have a right to inspect Electronic Communications sent through their company systems.
• Electronic Communications can be intercepted, altered, forwarded, or used without authorization or detection.
• Electronic Communications can be obtained and used as evidence in court.
• Cell phones and other personal devices containing Electronic Communications can be lost or stolen resulting in disclosure of messages to unauthorized individuals.

You acknowledge and consent to the foregoing risks of Electronic Communications.

General

• IN A MEDICAL EMERGENCY, DO NOT USE EMAIL, CALL 911. Do not use Electronic Communications for urgent medical problems. Please call your physician or 911 in the event of a medical emergency. Urgent messages or needs should be relayed to us by using regular telephone communication and may include text or mobile application messages when enabled and available.
• Electronic Communications to us should not be time sensitive. While we try to respond to messages promptly, we cannot guarantee that any particular Electronic Communications will be read and responded to within any particular period of time except as otherwise required by law or regulation for certain communications. If you have not heard back from us within three days, call our office to follow up if we have received your message.
• You should speak with a GuideWell Simplifi representative to discuss complex and/or sensitive situations rather than send Electronic Communications regarding such situations unless you have affirmatively opted-in to specific care or other health related GuideWell Simplifi programs that may require separate consent and/or confirmation to use secure or other messaging platforms.
• You should use your best judgment when considering the use of Electronic Communications for communication of sensitive medical and other information unless you have affirmatively opted-in to specific care or other health related GuideWell Simplifi programs that may require separate consent and/or confirmation to use secure or other messaging platforms. GuideWell Simplifi and its personnel are not responsible for the content of messages you send to GuideWell Simplifi.
• GuideWell Simplifi is not liable for breaches of confidentiality caused by you or any third-party.
• It is your responsibility to follow up with a GuideWell Simplifi representative if warranted.

12. Changes to Our Privacy Policy

We may change this Policy at any time. The date this Policy was last revised is identified at the top of the page.

GuideWell Simplifi may from time-to-time revise this Policy by updating the locations where it is posted or referenced by the Digital Services. You should, therefore, periodically review this Policy so you are aware of any such revisions. Your continued use or access to our Digital Services shall constitute your agreement to the revised Privacy Policy.

13. Contact Information

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the "Contact Us" page found in our Digital Services.

How to Contact Us:

Telephone: 1-855-521-9359
Email: guidewellsimplifiteam@guidewellsimplifi.com