Some of the data disclosures to these third parties may be considered a “sale” or “sharing” of personal information as defined under the laws of California and other U.S. states. NOTICE: We may sell your sensitive personal data. Please see the “Your Choices” and “California” sections below for more details.

Please note that some of our services also include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal information to any of those third parties, or allow us to share personal information with them, that data is governed by their privacy statements. 

Finally, we may disclose de-identified information in accordance with applicable law.

Your Choices

We provide a variety of ways for you to control the personal information we hold about you, including choices about how we use that data. In some jurisdictions, these controls and choices may be enforceable as rights under applicable law

Access, portability, correction, and deletion. If you wish to access, correct, or delete personal information about you that we hold, you may access your account by logging into the Carewell services you use.

You may submit also requests to access, correct, or delete by calling us toll free at 1-800-696-2273, or via email to support@carewell.com. 

If you are unable to access, copy, correct, or delete certain personal information we have via the means described above, you can send us a request by using contact methods described in the “Contact Us” section below. Please note that if certain personal information is deleted pursuant to your request, we may be unable to provide services to you or provide support for past products or services that you may have purchased.

Communications preferences. You can choose whether to receive promotional communications from us by email and SMS. If you receive promotional email or SMS from us and would like to stop, you can do so by following the opt-out or unsubscribe instructions in that message or by contacting us as described in the “Contact Us” section below. You can also opt-out of promotional SMS from us by texting STOP to 29975. 

These choices do not apply to certain informational communications including surveys and mandatory service communications.

Data sales. Some privacy laws define “sale” broadly to include some the disclosures described in the “Our Disclosure of Personal Data” section above. To opt-out from such data “sales” please follow the instructions available at https://www.carewell.com/ccpa/ or utilize the Global Privacy Control described below. 

Targeted advertising. To opt-out from or otherwise control targeted advertising, you have several options. First, you can use the settings described in “How We Disclose Personal Information” to restrict advertising-related cookies. Second, you can use the Global Privacy Control setting in a web browser or browser extension as described below. Third, you can use the opt-out controls offered by the organizations our advertising partners may participate in, which you can access at: 

• United States: Network Advertising Initiative (http://optout.networkadvertising.org) and Digital Advertising Alliance (optout.aboutads.info)
• Canada: Digital Advertising Alliance of Canada (https://youradchoices.ca/) 
• Europe: European Digital Advertising Alliance (http://www.youronlinechoices.com/)

Fourth, you can use the other cookie or mobile ID controls described below. 

These choices are specific to the device or browser you are using. If you access our services from other devices or browsers, take these actions from those devices or browsers to ensure your choices apply to the data collected when you use them.

Browser or platform controls.

• Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated. 

• Global Privacy Control. Some browsers and browser extensions support the “Global Privacy Control” (GPC) or similar controls that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales and/or targeted advertising, as specified by applicable law. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting or similar control that is recognized by regulation or otherwise widely acknowledged as a valid opt-out preference signal.

• Do Not Track. Some Internet browsers may be configured to send “Do Not Track” (DNT) signals to the online services that you visit indicating you do not wish to be tracked. Unlike the GPC described above, there is not a common understanding of how to interpret the DNT signal; therefore, our websites do not respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the GPC, cookie controls, and advertising controls described above.

• Mobile advertising ID controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.

Email web beacons. Most email clients have settings that allow you to prevent the automatic downloading of images, including web beacons, and the automatic connection to the web servers that host those images.

Except for the automated controls described above, if you send us a request to exercise your rights or these choices, to the extent permitted by applicable law, we may decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or other rights of another person, would reveal a trade secret or other confidential information, or would interfere with a legal or business obligation that requires retention or use of the data. Further, we may decline a request where we are unable to authenticate you as the person to whom the data relates, the request is unreasonable or excessive, or where otherwise permitted by applicable law. If you receive a response from us informing you that we have declined your request, in whole or in part, you may appeal that decision by submitting your appeal using the contact method described at the bottom of this Policy. 

Security of Personal Information

We take reasonable and appropriate steps to help protect personal information from unauthorized access, use, disclosure, alteration, and destruction. To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.

Location of Personal Information

The personal data we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers process data, some of which may have laws that offer different levels of data protection than the country in which you reside. Currently, we primarily use data centers in the United States. The storage location(s) are chosen to operate efficiently and improve performance. We take steps to process and protect personal data as described in this Policy wherever the data is located.

California Privacy Rights

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (CCPA), you have certain rights with respect to that information. 

Notice at collection. At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this Policy by clicking on the above links.

Right to know. You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this privacy statement. You may make such a “request to know” by calling us toll free at 1-800-696-2273, or via email to support@carewell.com.

Right to request correction or deletion. You also have rights to request that we correct inaccurate personal information and that we delete personal information under certain circumstances, subject to a number of exceptions. You may submit requests to exercise these rights by calling us toll free at 1-800-696-2273, or via email to support@carewell.com. 

Right to opt-out / “Do Not Sell or Share My Personal Information”. You have a right to opt-out from future “sales” or “sharing” of personal information as those terms are defined by the CCPA. Note that the CCPA defines “sell,” “share,” and “personal information” very broadly, and some of our data disclosures described in this Policy may be considered a “sale” or “sharing” under those definitions. In particular, we let advertising and analytics providers collect identifiers (IP addresses, cookie IDs, and mobile IDs), activity data (browsing, clicks, app usage), device data, and geolocation data through our sites and apps when you use our online services, but do not “sell” or “share” any other types of personal information. If you do not wish for us or our partners to “sell” or “share” personal information relating to your visits to our sites for advertising purposes, you can make your request by following the instructions on our “Do Not Sell or Share My Personal Information” page, using a Global Privacy Control, emailing us using the contact information at the bottom of this Policy, or using other controls described in the “Your Choices” section of this Policy. If you opt-out using these choices, we will not disclose or make available such personal information in ways that are considered a “sale” or “sharing” under the CCPA. However, we will continue to make available to our partners (acting as our service providers) some personal information to help us perform advertising-related functions. Further, using these choices will not opt you out of the use of previously “sold” or “shared” personal information or stop all interest-based advertising.

We do not knowingly sell or share the personal information of minors under 16 years of age.

Right to limit use and disclosure of sensitive personal information. You have a right to limit our use of sensitive personal information for any purposes other than to provide the services or goods you request or as otherwise permitted by law. Note that we do not use sensitive personal information for any such additional purposes.

Verification of identity. To provide, correct, or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to send it from the email address associated with your account, or requiring you to provide other information as necessary to v verify your identity.

Authorized agents. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us..

Finally, you have a right to not be discriminated against for exercising these rights set out in the CCPA. 

Additionally, under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal information to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. Please be aware that we do not disclose personal information to any third parties for their direct marketing purposes as defined by this law.

California Customers may request further information about our compliance with this law by emailing support@carewell.com. Please note that businesses are required to respond to one request per

California Customer each year and may not be required to respond to requests made by means other than through the designated email address.  

California Notice of Financial Incentive

We offer, or may in the future offer, various incentive programs that may constitute a “financial incentive” under the CCPA, such as our Autoship and Save program, as well as any future rewards programs.

The details of these programs are described below and are subject to change.

You have the right to withdraw from these programs at any time and may do so by following the instructions in the chart below.

The value of the incentives provided pursuant to the programs depends on various factors, including, as may be applicable: whether and to what extent you purchase our products, whether you withdraw from the respective program, whether we can enhance the data through our efforts (for example, if we aggregate the data to analyze purchasing tendencies), our ability to understand our existing and future customers based on the information, whether the sales generated by the respective program exceed the cost to us of offering the program, the benefit and insights we realize and expect to realize when you continue to use our services, how many users sign up for the respective program, and increased customer goodwill towards us.