State Consumer Privacy Notice

Depending on your state of residency, you may have rights as outlined in this Notice.

This State Consumer Privacy Notice applies to residents of California, Colorado, Connecticut, Utah, or Virginia, and sets forth your rights under your respective state’s comprehensive privacy law. This State Consumer Privacy Notice supplements our Privacy Policy. It explains what Personal Information (PI) we collect about you, where and from whom we obtain it, why we collect it, and your respective state rights regarding it. If you are a California, Colorado, Connecticut, Utah, or Virginia resident, this notice applies to any PI that we collect about you.

Personal Information (PI) We Collect and Disclose for Business

Purposes

In the preceding twelve (12) months, depending on the product or service you have used we may have collected the following categories of PI and have disclosed/shared it for the business purposes described as follows:

(Some Personal Information included in the categories below may overlap with other categories.)

Category of PI	Examples	Collected	Categories of Third Parties That We Disclose PI for Business Purposes	Shared for Advertising Purposes	Categories of Third Parties That We Shared PI for Advertising Purposes
Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.	Yes	Contracted Service Providers, Vendors, and other third parties at your request	Yes	Contracted Service Providers
Personal Information Categories	A name, signature, physical characteristics or description, address, telephone number, bank account number, credit card number, debit card number, or any other financial information, medical information.	Yes	Contracted Service Providers, Health Care Providers, Vendors, Insurance Carriers, and other third parties at your request	No	Not applicable
Protected Classification Characteristics	Age, race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status, genetic information (including familial genetic information).	Yes	Contracted Service Providers, Vendors, and other third parties at your request	No	Not applicable
Sensitive Personal Data Categories	Financial account information and account login credentials, precise geolocation information, genetic data, biometrics data, wellness data.	Yes	Contracted Service Providers, Vendors, and other third parties at your request	No	Not applicable
Commercial Information	Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes	Contracted Service Providers, Vendors, and other third parties at your request	No	Not Applicable
Biometric Information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Yes	Contracted Service Providers, Vendors, and other third parties at your request	No	Not applicable
Internet and/or Network Activity	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	Yes	Contracted Service Providers, Vendors, and other third parties at your request	Yes	Contracted Service Providers
Geolocation data	Physical location or movements	Yes	Contracted Service Providers, Vendors, and other third parties at your request	No	Not Applicable
Sensory Data	Audio, electronic, visual, thermal, or similar information	Yes	Contracted Service Providers, Vendors, and other third parties at your request	No	Not applicable
Inferences drawn from other personal information	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes	Contracted Service Providers, Vendors, and other third parties at your request	No	Not applicable

We will retain the above categories of PI consistent with our internal record-retention policies and for as long as is necessary to provide products and services to you or as required by law.

Personal information Does Not Include

De-identified or aggregated consumer information
Publicly available information from government records
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
PI covered by other privacy laws, including: The Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Categories and Sources of PI

We obtain the categories of PI listed above from:

You or your authorized representative
Service providers
Affiliates
Publicly available information
Organizations where you are employed or affiliated or
Activity on our apps and websites

Collection from these sources may occur online or other electronic means, and may occur automatically where state law permits such profiling absent an explicit request to opt-out.

Why We Collect PI

We collect your PI for one or more of the following business purposes:

To respond to an email or particular request from you
To communicate with you
To personalize services for you
To process an application as requested by you
To administer surveys and promotions
To provide you with information 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, websites, and advertising
To comply with applicable laws, regulations, and legal processes
To protect someone's health, safety, or welfare
To protect our rights, the rights of affiliates or related third parties, or take appropriate legal action
To keep a record of our transactions and communications
To detect and protect against security incidents
To debug to identify and repair errors
As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law

Sharing Your PI

At times, some of our products or services may share your PI with third parties to display advertisements to you based on your activities, preferences, or interests. If we do this, we will provide that you may opt-out of this activity using our cookie management tool on our website.

Third parties are not allowed to use or disclose your PI other than as specified in our contract and as permitted by law.

If we seek to use your PI for a materially different purpose than we previously disclosed in this notice, we will notify you and will not use your PI for this new purpose without your explicit consent.

Sensitive Personal Data

We only process Sensitive Personal Data to render services or offer products to you.

Virginia and Colorado residents, your acceptance of this Privacy Policy constitutes your opt-in consent to our processing of any Sensitive Personal Data about you.

Your Rights

You have the right to request that we disclose certain information to you about our collection and use of your PI. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- What PI we collect about you
- Where and from whom we collect PI about you
- Our business purpose for collecting PI about you
- The types of third parties with whom we share your PI
- The specific pieces of PI we collect about you, in a readily-usable format — note that we will not disclose your actual financial account number, any health insurance or medical identification number, an account password, or security questions and answers
- The types of PI that we disclosed about you for a business purpose, and the categories of third parties to whom we disclosed your PI
You have the right to be informed about the PI that we collect about you at the time that or before we collect it. This is that notice.
You have the right to request that we delete any PI about you that we have.
You have the right to request a correction of any inaccurate information in the PI we collect about you.
You have the right to stop us from sharing your PI to display advertisements to you based upon your activities, preferences, and interests.
If we use your sensitive PI for purposes other than to render services or offer products to you, you will have the right to request that we limit the processing of your sensitive PI.
You will not be discriminated against or penalized for exercising your rights to your PI, and we will honor your rights by not:
- Denying you services
- Charging you different prices or rates for services
- Imposing penalties, or
- Providing you with a different level or quality of services
Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why and you may appeal this decision (see additional information in the Appeals section below).

How to Exercise Your Rights

You may exercise your rights by emailing us at support@wellos.com or by submitting this form.
If we do share your PI, you may opt-out of the sharing of your PI by using our cookie management tool on our website.
You may be required to submit proof of your identity for these requests to be processed.
We will not be able to comply with your request if we are unable to confirm your identity.
You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization.

Timing

We will acknowledge receipt of your request within 10 days of receipt of your submission. You will receive our response to your request within 45 days of your request, unless we provide you with notice that it will take more than 45 days to respond (in that case, we won’t take more than 90 days to respond).

Appeals

If the business denies any of your requests, you may have a right to appeal by emailing us at privacy@rvohealth.com.
We will respond to your appeal within 45 days of receipt, unless we notify you that we will require an additional 15 days to respond.
If you remain concerned about the result of that appeal, you may contact the attorney general in your state of residency.

Changes

We will review this notice annually and update it from time to time. Any changes will be posted on this page and will become effective as of the “Last Revised” date. We encourage you to review this notice periodically to be sure you are aware of those changes.

Last Updated: November 7, 2023