Privacy Policy

This Privacy Policy explains how Extra Health LLC. and its subsidiaries and affiliated companies (“EXTRA HEALTH,” “we,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies when you use our websites, mobile applications, and other online products and services that link to this Privacy Policy, contact our customer service team, engage with us on social media, or otherwise interact with us (collectively, our “Services”).

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us. For example, you share information directly with us when you create an account, sign up for our Services, use our website or mobile application, join our waitlist, fill out a form, submit or post content through our Services, communicate with us via third-party platforms, participate in a contest or promotion, request customer support, or otherwise communicate with us. As we add new Services, you may be asked to provide additional information.

• We may collect the following types of information from you:
• ● Personal identification information such as full name, date of birth, Social Security number, tax identification number, gender, nationality, signature, photographs, phone number, street address, and/or email.
• ● Business profile information such as Employer Identification Numbers, industry and/or business descriptions.
• ● Identification verification information such as government issued identity documents (i.e., driver’s license, passport, state identification card), visa information, proof of address, Social Security card, correspondence with the Internal Revenue Service, and/or company formation documents (e.g., Articles of Incorporation).
• ● Financial information such as bank account information, payment card information, ownership information, account balances, payment history, transaction information (including names, amounts, and timestamps), invoices, credit history, credit scores, receipts, and/or billing relationships.
• ● Employment information such as employment relationships, descriptions of roles or titles, and/or office locations.
• ● Tax information such as actual and estimated income, expenses, expense classifications, and/or tax documents (e.g., tax returns, W-2s, 1099s, tax filings).
• ● Transactional information such as recipient names, amounts, timestamps, and authentication data.
• ● Customer service data such as chat transcripts, voice recordings, video recordings, notes from our customer service teams, details about your interactions with us (i.e., timestamp, duration, and parties), and/or files you share with us.
• ● Audio, electronic, visual, or other similar information, such as call and video recordings.

Information We Collect Automatically When You Interact with Us

When you access or use our Services or otherwise transact business with us, we automatically collect certain information, including:

• ● Activity Information: We collect information about your activity on our Services, such as your consent to our terms and conditions and referrals from other websites.
• ● Transactional Information: We collect information about your financial activity, such as transaction amounts, participants, invoice details, and payment details.
• ● Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page or application you visited before navigating to our Services.
• ● Location Information: In accordance with your device permissions, we may collect information about the precise geolocation of your device. You may stop the collection of precise location information at any time (see the Your Choices section below for details).
• ● Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see our Cookie Policy (https://www.extrahealthcare.com/pages/cookie) and the Your Choices section below.

Information We Collect from Other Sources

We obtain information from third-party sources. For example, we may collect information about you from financial service providers, identity verification services, credit bureaus, advertising networks, data analytics providers, internet service providers, operating systems and platforms, social networks, data brokers, and mailing list providers. You may also provide us with access to health data (including steps, exercise time, weight, height, BMI, and calories burned) obtained by third parties, such as Apple and Google. You may also choose to provide us with access to certain personal information stored by third parties such as social media sites (such as Instagram, Facebook, Twitter, Snapchat, and TikTok). The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. By authorizing us to have access to information managed by a third party, you agree that we may collect, store and use this information in accordance with this Privacy Policy.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer that you are looking to use certain aspects of our Services based on your browsing behavior and past use of our Services.

USE OF INFORMATION

We use the information we collect to provide you with banking and other financial services. We also use the information we collect to:

• ● Provide, maintain, and improve our products and Services;
• ● Enforce our terms of service and other agreements;
• ● Process transactions and send you related information, including notices, confirmations, invoices, and receipts;
• ● Personalize and improve your experience on our Services;
• ● Send you technical notices, security alerts, and support and administrative messages;
• ● Respond to your comments and questions and provide customer service;
• ● Communicate with you about products, services, and events offered by EXTRA HEALTH and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
• ● Provide and administer our waiting lists and loyalty program;
• ● Monitor and analyze trends, usage, and activities in connection with our Services;
• ● Personalize the advertisements you see on third-party platforms and websites (for more information, see the Advertising and Analytics section below);
• ● Facilitate contests, waiting lists, sweepstakes, and promotions and process and deliver entries and rewards;
• ● Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of EXTRA HEALTH and others;
• ● Debug to identify and repair errors in our Services;
• ● Comply with our legal and financial obligations; and
• ● Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

• ● We share personal information with vendors, service providers, and consultants that need access to personal information to perform services for us. Examples of the types of service providers we may share your information with include companies that assist us with the following:
  • o Fraud prevention
  • o Network infrastructure and security
  • o Cloud storage
  • o Payment processing (e.g., ACH transfers)
  • o Account monitoring
  • o Customer support
  • o Data analytics
  • o Data processing
  • o Document processing, repository, and security services (including optical character recognition)
  • o Internet service
  • o Consumer relationship software management services
  • o Web hosting
  • o Information technology support
  • o Marketing and advertising
  • o Communication services (e.g., video calling platforms and chat services)
• ● We share personal information with third parties that assist us in marketing and advertising, including analyzing the effectiveness of our marketing and advertising across various websites and platforms. For example, we share personal information with Facebook, Tiktok, Snapchat, and Google Analytics.
• ● We share personal information with third parties where you elect to participate in our rewards programs. For example, we may share information with Apple or Google where you elect to participate in our health rewards initiative.
• ● We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• ● We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of EXTRA HEALTH, our users, the public, or others.
• ● We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• ● We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• ● We share personal information between and among EXTRA HEALTH and our current and EXTRA HEALTH parents, affiliates, and subsidiaries and other companies under common control and ownership.
• ● We share personal information with your consent or at your direction.

We also share aggregated or de-identified information that cannot reasonably be used to identify you.

ADVERTISING AND ANALYTICS

We allow others to provide analytics and advertising services on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about

your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by EXTRA HEALTH and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices or change your settings using the consent management tool on our Services. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.

We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Google Ads, Facebook, Tiktok, and Snapchat). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

HOW WE PROTECT YOUR INFORMATION

We store and process your information maintaining physical, electronic and procedural safeguards. We maintain physical security measures to guard against unauthorized access to systems and use safeguards such as firewalls and data encryption. We enforce physical access controls to our buildings, and we authorize access to personal information only for those employees or agents who require it to fulfill the responsibilities of their jobs.

YOUR CHOICES

Account Information

You may update and correct certain account information at any time by logging into your account, emailing us at info@extrahealthcare.com. If you wish to delete your account, please contact us, but note that we may retain certain information as required by law or for our legitimate business purposes.

Location Information

When you first launch our mobile application, you will be asked to consent to the app’s collection of precise location information. If you initially consent to our collection of such location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. You may also stop our collection of this location information by following the standard uninstall process to remove our mobile application from your device. If you stop our collection of this location information, our Services may no longer function properly.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services. For more information about cookies and how to disable them, see our Cookie Policy (https://www.extrahealthcare.com/pages/cookie).

Communications Preferences

You may opt out of receiving text messages or promotional emails from EXTRA HEALTH by following the instructions in those communications or by emailing us at info@extrahealthcare.com. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Mobile Push Notifications

With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

California Consumer Privacy Act

For details about the data points we collect and the categories of sources of such collection, please see the Collection of Information section above. For details about how we use and share your information, please see the Use of Information and Sharing of Information sections above. The chart below reflects the categories of personal information we have collected in the past 12 months, the sources and purposes of that collection, and the entities to whom the information was shared for business purposes.

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, (2) request deletion of your personal information, (3) opt out of any “sales” of your personal information that may be occurring, and (4) not be discriminated against for exercising these rights. You may make these requests directly to your member experience professional, using the EXTRA HEALTH application, or by emailing us at info@extrahealthcare.com. We will not discriminate against you if you exercise your rights under the CCPA.

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us.

Some Internet browsers include the ability to transmit “Do Not Track” or “DNT” signals to websites. We do not currently process or respond to these signals.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at info@extrahealthcare.com.