Privacy Policy

Last Updated: November 7, 2023

RVO Health LLC, including its family of brands such as Wellos and Healthline (collectively “RVO Health”, “we”, “us”, “our”) is dedicated to making health easier to navigate, more accessible, and more affordable for you and your family.

This Privacy Policy (“Privacy Policy”) explains the information we collect, use, and share through our websites, apps, products and services, (collectively “Services”), to operate, improve, develop, and provide the Services to you (“you”, “users”). This Privacy Policy also describes the choices available to you regarding our use of this information.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using our Services, you agree to this Privacy Policy and to our collection, use, disclosure, and storage of information as described herein.

PRODUCTS OR SERVICES COVERED BY THIS PRIVACY POLICY

We may reference certain types or groupings of RVO Health products or services in this Privacy Policy to help you better understand our data collection and use practices related to those products or services.

Our products and services covered by this Privacy Policy include, without limitation:

• The Wellos Program (“Wellos”). Wellos is an all-in-one wellness service that gives you the tools you need to make health happen. It includes certain health tools like online wellness coaching, the ability to track your weight and weight loss goals, the ability to track what you eat, drink, and your physical activity, achievements, and other services and tools.

Our Policy does not apply to the practices of other companies or other websites or software applications that may be linked from or made available through our Services.

The inclusion of a link on our websites or through our Services or the ability to utilize a third-party website or software application through our Services does not imply that we endorse, or otherwise monitor the privacy or security practices of that third-party website or software application or the accuracy of its content, and your use of the third-party website or software application is governed by the third-party's privacy policy.

INFORMATION WE COLLECT

Depending on how you use our Services, we may collect information about you in three ways,: directly from you, from third parties, and automatically. Such Information may include information that identifies you such as your full name, telephone number, email address, postal address, certain account numbers, your User ID that you create or is assigned to you, wellness information, financial information and other information described in this Privacy Policy.

Information You Provide

When you use our Services, you may provide certain Information directly to us. For example, you may input a name or email address to register for our Services or share information through a chat session.

Information Provided by Third Parties

We may collect information from third parties if you choose to connect to certain wellness applications or wellness trackers. Such information may include calories, macro & micronutrients, and wellness activities.

Information Collected Automatically

We also may obtain Information that is automatically collected through the Services. The automatically collected Information may include demographic, de-identified, aggregated, or certain information from your device such as technical information about your device, web browser information, and server log files collected by us or provided by you. See Cookies and Tracking below for more information on automatically collected information.

You may limit the Information you provide or make available to us; however, that may limit your ability to access or use certain functions of the Services or to request certain services or information.

Mobile Devices and Applications

In addition to the Information identified above, we may collect the following Information:

Information that Identifies You

• Wellness information;
• Information created by us;
• Location data such as GPS, Wi-Fi, or carrier network location (see below for more details); and
• User files stored on your device like calendars, photos, and videos, if you grant permission through your device settings.

What You Do on Your Device

• Camera use. Certain features may have access to your camera, if you grant permission in your device settings.;
• Local storage;
• Use of screen, e.g., what points are touched, frequency, etc.; and
• Patterns of app usage...

Device or System Data

• Mobile Device Identifier, e.g., UDID, Android ID; and
• Technical information about your device and system and application software, e.g., type of phone, Operating System (OS), and IP address.

HOW WE USE YOUR INFORMATION

We may use your Information:

• To respond to an email, chat or other instant message or particular request from you;
• To communicate with you;
• To provide you with content, services, and functionality through our Services or other services that we may offer;
• To process a registration for a product or service as requested by you;
• To authenticate you on any portion of our Services and with vendors acting on our behalf;
• To administer surveys and promotions;
• To personalize your experience on our Services;
• To provide you with informational or promotional offers, as permitted by law, that we believe may be useful to you, such as information about products or services provided by us or other businesses;
• To perform analytics and to improve our products, Services, and advertising;
• To facilitate the provision of software updates and product support;
• To improve products and other services related to the Services or to provide services or technologies to you;
• To comply with applicable laws, regulations, and legal process;
• To protect someone's health, safety, or welfare;
• To protect our rights, the rights of affiliates or related third parties, or to take appropriate legal action, such as to enforce our Terms of Use;
• To keep a record of our transactions and communications; and
• As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law or for any other purpose with your consent.

We may use Information to contact you through any contact information you provide through our Services, including any email address, telephone number, or cell phone number. We may communicate, electronically or via telephone or cellphone with you about your programs, products, or services that are or may be available to you in connection with your transactions with us including, but not limited to, Services updates, general wellness reminders or information, newsletters, and surveys.

We may, when permitted, combine your Information with other information, whether online or offline, maintained or available to us from you or from other sources, such as from our vendors, and we may use and disclose combined data for the purpose described in this Section or for internal business purposes. We may, when permitted, use and disclose de-identified and aggregated data for any purpose, which may include, without limitation, disclosures to third parties for analytics purposes such as evaluating the Services and providing additional benefits, programs, and services.

HOW WE SHARE YOUR INFORMATION

Disclosures to Service Providers and Partners

RVO Health and third party vendors acting on our behalf, may disclose your Information to RVO Health Partners, third party service providers, or vendors acting on our behalf for the purpose of providing the Services and related services to you or other users, including, without limitation, registering you to use the Services (e.g., authenticating your identity), logging you into the Services, providing you with information you have requested through the Services or related services, related to your use of the Services, connecting you with resources and other services (e.g., coaching services), helping us send and manage email, hosting or operating some of our Services and related computers and software applications, and, for any Services that require you to pay a fee, processing your payment and managing your subscription. Third party service providers or vendors acting on our behalf are authorized to use your Information to provide us services or as required by law, and they are also permitted to aggregate or de-identify your Information such that it is not identifiable to you.

Sale, Merger, or Similar Transaction

We may share Information if all or part of the Company is sold, merged, dissolved, acquired, or disbanded to any extent in a similar transaction, or in connection with steps that may need to be taken in anticipation of such events.

Safety, Security, and Compliance with Law

We may share Information in response to a court order, subpoena, search warrant, or to comply with laws or regulations. We may cooperate with law enforcement authorities in investigating and prosecuting activities that are illegal, violate our rules, or may be harmful to other visitors. Your information may also be disclosed when we reasonably believe disclosure is necessary to protect our rights (including to enforce our Terms of Use), or to protect your safety or the safety of others.

Other Brands, Subsidiaries, and Affiliated Companies

We may also share Information within the Company, including among affiliates or brands under common control with the Company, or with our parent company, or subsidiaries.

Aggregate or De-Identified Information

We may create and share aggregate or de-identified information about the use of the Services, such as by creating reports on usage trends.

HOW TO MANAGE YOUR INFORMATION

Our Services may permit you to view your profile, if applicable, and access related Information about you and to request changes to such Information. Please remember, however, if we have already disclosed some of this Information to third parties, we may not have access to that disclosed information and may not be able to force the modification of any Information by the third parties to whom we have made those disclosures.

Communication Preference Management

Our Services may permit you to select how you would like to receive certain communications. You can view and update your communication preferences in your Account/Profile settings after logging into the Services.

We may offer mobile applications that enable us to communicate with you through push notifications. Where mobile applications are offered, you may be able to manage push notifications in your mobile phone or tablet settings. You may also be able to control preview settings in your email applications.

If you need additional assistance in opting out of a communication, please email support@wellos.com for assistance. Please be aware that opt-outs may not apply to certain types of communications, such as account status, Service updates, or other communications.

Informational Calls and Texts

When you provide us a telephone number, whether landline or mobile, we may contact you, using automated, pre- recorded, or non-automated means, to provide you information about existing benefits, programs, products, services, or tools.

Personal Information collected through our texting programs will not be shared, sold, or disclosed to third parties for their own marketing purposes.

We reserve the right to modify this section at any time. The modified section will be effective immediately upon posting. Your continued receipt of Informational Electronic Communications and Informational Calls and Texts will constitute your acceptance of the modified section.

Cookies and Tracking

The Company may use various technologies, including cookies, tokens, tags, web logs, web beacons, scripts, and web server logs to gather automatically collected information and may aggregate this information from visitors of our Services or to enable certain features of our Services. This information may include demographic data, technical information about the technology (e.g., phone, computer) you use to connect to the Services, web browser information, your IP address, and browsing behavior such as pages visited and how often they are visited (collectively, "Activity Information"). We may also use third-party analytics companies to provide these services.

We may also allow third parties to use cookies and other technologies to collect Activity Information and to track browsing activity over time and across third-party websites such as web browsers used to read our Services, which websites are referring traffic or linking to our Services, and to deliver targeted advertisements to you. We do not control these third-party technologies, and their use of such technologies is governed by their own privacy policies. For more information about third-party advertising networks and similar entities that use these technologies, see youradchoices.com/control, and to opt-out of such ad networks' and services' advertising practices, go to optout.aboutads.info and optout.networkadvertising.org/. Once you click the links, you may choose to opt out of such advertising from all participating advertising companies or only from advertising provided by specific advertising companies. Please note that, to the extent advertising technology is integrated into the Services, you may still receive advertisements even if you opt out of tailored advertising. In that case, the ads will just not be tailored. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Activity Information is captured using various technologies and may include cookies. "Cookies" are small text files that may be placed on your computer or mobile device when you visit a Service or click on a URL using your web browser. Cookies may include "single-session cookies" which generally record information during only a single visit to a website and then are erased, and "persistent" cookies which are generally stored on a computer or mobile device unless or until they are deleted or are set to expire. You may disable cookies and similar items by adjusting your browser preferences at any time; however, this may limit your ability to take advantage of all the features of our Services. In addition, you may also have additional means to manage the collection of Activity Information by:

• Managing the use of "flash" technologies, with the Flash management tools available at Adobe's website;
• Visiting the Adobe Digital Marketing Suite to "Opt-Out" of data aggregation and analysis;
• Clicking on the "Privacy Preferences" link at the bottom of the home web page, if applicable;
• Visiting Google to "Opt-Out" of display advertising or customize Google display network ads;
• Visiting Google to “Opt-Out” of sharing site visit information with Google Analytics; and

Please note that we do not currently respond to web browser "Do Not Track" signals that provide a method to opt out of the collection of Information about online activities over time and across third-party websites or online services because, among other reasons, there is no common definition of such signals and no industry-accepted standards for how such signals should be interpreted.

We gather Activity Information about you to improve the quality of our services, such as the best method and time to contact you. Without limiting the other ways in which we may use Information as described herein, we may otherwise use and disclose your Activity Information unless restricted by this Policy or by law. Some examples of the ways we use your Activity Information include:

• Customizing your experiences, including managing and recording your preferences;
• Authenticating your account information;
• Marketing, product development, and research purposes;
• Tracking resources and data accessed on the Services;
• Developing reports regarding Service usage, activity, and statistics;
• Assisting users experiencing problems with our services;
• Updating and servicing our Services;
• Enabling certain functions and tools on the Services; and
• Tracking paths of visitors to the Services and within the Services.

As described above, we may use tracking technologies that allow us to recognize your device when you return to our Services within a period of time, as determined by us, and to support automatic login to your Services. To maintain your privacy, you should affirmatively log out of your account prior to your session ending (whether you end your session or we end your session, for example if our Services has "timed out" - i.e., we have ended your session automatically after a period of inactivity as determined by us in our sole discretion). Unless you affirmatively log out of your account, you may be automatically logged back in the next time you or any user of your devices visits the Services.

PROTECTING YOUR INFORMATION

We maintain administrative, technical, and physical safeguards designed to protect the Information that you provide on our Services. These safeguards vary based on the sensitivity of the Information that is being collected, used, and stored. We cannot guarantee the security of our Services, nor can we guarantee the security of the Information you transmit to us over the Internet, including your use of email. We are not liable for the illegal acts of third parties such as criminal hackers.

It is your responsibility to safeguard the devices you use to access our Services (such as laptops, tablets and mobile devices), and to use appropriate security settings on those devices. If those devices are lost, stolen or misplaced, others may be able to access your account and your personal Information using those devices. You should affirmatively log out of your account (i) prior to ending your session, or (ii) if you will be inactive on the Services for more than a few minutes; otherwise, the next user of that computer or device, particularly a public one or one not owned by you, may be able to access your account and the Information in your account if your session has not ended.

You agree that we are not responsible for any harm that may result from someone accessing your account or personal Information on any computer or device where you do not, for any reason, take the necessary steps to log out of your account prior to ending a session on such device or computer.

We retain Information for as long as necessary for the purpose for which it is collected, subject to a longer period if the Information is relevant to a legal challenge.

CHILDREN UNDER 13

We will not intentionally collect any personal information (as that term is defined in the Children's Online Privacy Protection Act) from children under the age of 13 through our Services without receiving parental consent. If you think that we have collected such personal information from a child under the age of 13 through our Services, please Contact Us immediately.

ADDITIONAL RIGHTS FOR CALIFORNIA RESIDENTS

California “Shine the Light” Privacy Rights

California law permits our customers who are California residents to request certain information regarding the disclosure of certain personal information to third parties for their direct marketing purposes.

If we have disclosed any personal information to third parties for direct marketing purposes, we will provide a list of the categories of personal information, along with the names and addresses of these third parties to you at your request. To make such a request, write to us at the email address found in the Contact Us section of this Policy.

This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the specified email or postal address. You should put "California Privacy Rights-Direct Marketing" in the email subject line and in the body of your request. You must provide us with specific information regarding yourself so that we can accurately respond to the request.

STATE CONSUMER PRIVACY NOTICE

If you are a resident of California, Colorado, Connecticut, Utah, or Virgina, you may review our State Consumer Privacy Notice here.

SOCIAL MEDIA DISCLAIMER

We encourage you to read, share, follow us and provide commentary on Facebook®, Twitter®, Pinterest®, Instagram® and other social media sites ("Social Media Site"). Before you post on our pages or accounts, please make sure you read our social media disclaimer:

We are under no obligation to screen or monitor your posts or any other user content; however, we reserve the right to monitor participation to ensure that you stay on topic, are courteous and avoid making offensive comments. Your posts and user content must adhere to the following requirements and cannot:

• Contain any third-party material including logos, drawings, tattoos, photographs, pictures, sculptures, paintings and other images or works of art, phrases, trademarks, trade secrets, or other items without explicit, prior, written permission to use such materials;
• Contain sexually explicit, graphic, gratuitous or unnecessarily violent content or defamatory or derogatory content against any ethnic, racial, gender, religious, sexual orientation, professional or age group, or contain any pornographic or nude material;
• Contain any private information about yourself or any other individual, including without limitation, information related to the health of the individual, financial information about the individual, or any identification or account numbers related to the individual, with or without their permission or consent;
• Contain any software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software, hardware, or telecommunications equipment; and
• Contain any advertising, promotional materials, "junk mail," "spam," "chain letters," "pyramid schemes," or promote illegal activity and/or illegal contests, sweepstakes, gambling, including any online casino, sports books, bingo, poker, or any other form of solicitation.

We reserve the right to edit comments for content, remove off-topic contributions, delete offensive comments or remarks, block offensive contributors, and delete actual or suspected spam content from any Social Media Site. Please be aware that once you post something online, there is the potential for numerous individuals to read your words, even years from now. Therefore, we suggest that you exercise caution when posting on any Social Media Site and that you not disclose Information like your location, personal medical information, financial information, etc. We are not responsible for the content of any comments or responses posted by others to any Service or Social Media Site we manage or monitor. We do not control the placement of any marketing or advertising displayed on our pages by social media or third-party organizations.

Please remember that content posted on any of our social media profiles or platforms is for general informational purposes only and should not be considered medical advice and should not replace a consultation with your health care or financial professional. Always consult an appropriate health care or financial professional for your specific needs. If you are experiencing a medical emergency, call 9-1-1 or your local emergency number.

We reserve the right to respond to any post or user content and may occasionally privately request your contact information to assist you offline, with your consent, by routing the matter to the appropriate persons or department for further handling.

All trademarks are the property of their respective owners.

CHANGES TO THIS POLICY

We may change this Policy at any time. If we do so, such change will appear on this page. You may always visit this Policy to learn of any updates. Your continued access to or use of the Services constitutes your consent to these changes to this Policy.

CONTACT US

To contact us regarding this Policy or related privacy practices, please email us at privacy@rvohealth.com.