PRIVACY POLICY
(Effective July 9, 2018)

Wellthie, Inc. (“Company”, “us”, and “we”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Information (as defined below) we collect from users of our technology platform, “Platform”.

  1. User Consent. By using this Site, including, without limitation, the Platform, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of the Data, including your Personal Information, (as defined in Section 2 below), in accordance with this Privacy Policy.
    1. For Employees: This information may be provided by you directly, by your employer, your broker of record, or a third party acting on your behalf.
    2. For Employers: This information may be provided by your broker of record, or a third party acting on your behalf.
  2. Types of Data We Collect (the “Data”)
    1. “Personal Information” means (i) data that allows someone to identify or contact your employees, you, or dependents, including, for example, names, home address, work address, Social Security Numbers, telephone numbers, e-mail addresses, and dates of birth, (ii) any other non-public information about your employees, you, or dependents that is associated with or linked to any of the foregoing data, including but not limited to number of times signed in, date of sign in, account creation date, broker code, or license number, and (iii) medical and insurance information that you or your dependents provide in response to questions in applications or questionnaires that you complete through the Platform or otherwise through this Site.
    2. Information You Provide to Us. We may collect Personal Information from you, as well as employee and payroll information related to your employees, you or dependents, such as enrollment options, plans available, and cost of plans, when you use the Platform.
    3. Information Collected via Technology. To make our Site more useful to you, our servers (which may be hosted by a third party service provider) may collect information from your employees, you, or dependents, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.We may also use cookies, URL information, web beacons and similar technology to gather information regarding the date and time of your visit, web pages reviewed and the information for which you searched and which you viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. You can remove Persistent Cookies from your computer by following “help” directions from your Internet browser.
    4. Information Collected from Third Party Companies. We may receive Personal Information about you from companies that provide our services or companies that offer their products and/or services on our Site, including our sponsors. We may add this information to the information we have already collected from you via our Site in order to improve the services we provide.
  3. Use of the Data
    1. General Use. In general, the Data described in Section 2, including the Personal Information you submit to us, or which is submitted on your behalf, is used either to respond to requests that you make, or to aid us in serving you better. We use the Data in any or all of the following ways:
      • Share with insurance companies providing products or services in which you have expressed an interest;
      • Identify you as a user of our Site;
      • Provide improved administration of our Site;
      • Improve the quality of experience when you interact with our Site;
      • Respond to your inquiries, or to solicit your feedback; and
      • To send to you newsletters, surveys, emails, offers, and other promotional materials related to our Site.
    2. Creation of Anonymous Data. We may create “Anonymous Data” records from the information that you provide or that we collect, by excluding Personal Information that makes the information personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our services and improve Site navigation. We may combine Anonymous Data related to multiple users of the Platform and the Site, and reserve the right to use Anonymous Data for any purpose (including, but not limited to, analytical and marketing purposes), and to disclose Anonymous Data to third parties in our sole discretion.
  4. Disclosure of Data. We only disclose the Data, including your Personal Information (as defined in Section 2 above), in the manner described In Section 3, and as described below.
    1. Third Party Service Providers. We may share the Data with third party service providers to: provide you with the services that we offer you through our Site; to conduct quality assurance testing; to provide technical support; and/or to provide other services to our company. These third party service providers are required not to use your Personal Information other than to provide the services requested by us.
    2. Sponsors. We may share the Data with our sponsors whose website portal you were able to access through our Site, to enable them to send you information about their products and services. By using sponsor sites, you are agreeing to their separate terms and conditions, and privacy policies (see “Third Party Websites” in Section 5 below).
    3. Affiliates and Acquisitions. We may share some or all of the Data with our corporate affiliates, such as joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company, business, or our assets, that company will possess the Data collected by us and will assume the rights and obligations regarding the Data as described in this Privacy Policy.
    4. Other Disclosures. Regardless of any choices you make regarding the Data, and in addition to the disclosures described above, we may disclose all or any part of the Data if we believe in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on us; (iii) to protect or defend our rights or property, or other users of our services or the services of companies that offer their products and/or services on our Site, including our sponsors ; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use. If you disagree with the collection or use of your “Data” as described in this Policy, please contact [email protected].
  5. Third Party Websites. When you link to any other website or location from our Site, you will leave our Site and go to another website and another entity may collect Data from you. We have no control over, do not review, and cannot be responsible for, these third party websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these third party websites or content, or to any collection of data after you click on links to such third party websites. Please review the privacy policies of the third party websites for information on how they may collect, use and maintain your Data.
  6. Security of Your Data. We are committed to protecting the security of your Data. We use a variety of industry-standard security technologies and procedures to help protect your Data from unauthorized access, use, or disclosure. No method of transmission over the internet, or method of electronic storage, is 100% secure, however. While we use reasonable commercial efforts to protect your Data, we cannot guarantee its absolute security.
  7. Changes to This Privacy Policy. This Privacy Policy is subject to change in order to comply with applicable law and to reflect our business practices regarding the way we use your Personal Information. Accordingly, we may modify this Privacy Policy from time to time as reflected by the effective date listed above. Our Site will include the most current form of the Privacy Policy. Your continued use of our Site or Service following any such update shall represent your acknowledgement of such changes and agreement to be bound by the updated Privacy Policy.
  8. Contact Information. We welcome your comments or questions regarding this Privacy Policy. Please e-mail us at [email protected].