Welltheos’ Website Privacy Policy

Welltheos LLC doing business as W3LL (“W3LL“, “we”, or “us”) is committed to protecting the privacy of your personal information. We protect the privacy of that information in accordance with federal and state laws, as well as our own company privacy policies. We want to thank you for visiting our website (“Site”) at www.welltheos.com/wbe. The purpose of this Privacy Policy is to inform you of how your information is collected, used, and handled throughout the use of this website. This Privacy Policy applies to all products and services (referred to collectively as “Services”) that are offered and hosted by W3LL.

By visiting and using our Site, you consent to our processing of your information as set forth in this Privacy Policy. If you do not agree with this policy, please do not use our Site. We reserve the right to update and modify our Privacy Policy at any time. Your continued use of our Site following the posting of changes to this policy will be deemed your acceptance of those changes This website is intended for a United States audience. Any information you provide, including any personal information, will be transferred to and processed by a computer server located within the United States.

Limit Use of Information for Health Insurance Purposes

You may request that we limit the collection, creation, disclosure, access, maintenance, storage and use of your Personally Identifiable Information for the sole purpose of our assisting you in applying for health insurance or obtaining an eligibility determination, facilitating payment for your first premium, assisting you in updating or canceling your enrollment in a health insurance plan, and for performing other authorized functions specified in our agreements with CMS. You may request such a limitation by sending an email to Privacy@W3LL.com, calling us at 888-780-7122, or mail at:
W3LL
1500 Stony Brook Road
Stony Brook, New York USA 11794
Attn: Legal Dept.

What Information Do We Collect?

W3LL gives brokers, agents, and members access to health plans through this Site. We will ask you to provide us with personal information to help you find and apply for health insurance for you and your family. We collect the minimum necessary amount of information to accomplish this purpose. We only use and disclose your personal information in accordance with our privacy policy. Additionally, we use industry-leading technologies to ensure the security and confidentiality of the personal information you provide us.

Throughout this policy, when we refer to “personal information,” we are referring to information that can be used to distinguish or trace your identity, such as name, social security number, date of birth, phone number, email address, or credit card number.

We may collect from you “protected health information” which includes any information about your health or medical history that you may provide in a health insurance application.

We may also collect from you financial or other sensitive personal information in an application to obtain an advanced premium tax credit (or “subsidy”) determination from the government. If you provide information directly to one of our partners or any other third-party, then your information would be governed by such other party’s privacy policy.

We may receive information about you from other sources, including publicly available databases or third-parties from whom we have obtained data, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. Examples of the types of personal information that may be obtained from public sources or third-parties and combined with information we already have about you, may include: (a) address information from third-party sources to verify your address so we can properly communicate with you and to prevent fraud and/or (b) data about our customers from third-parties that is combined with information we already have about you, to create more tailored advertising and products. You do not have to provide us with personal information if you do not want to; however, that may limit your ability to use certain functions of this website or to request certain services or information.

How Will Your Information Be Used and Shared?

We may use your personal information in the following ways:

To send periodic service-related emails or respond to a request from you. We may use the email address you provide to respond to your inquiries, questions, and/or other requests, and to send you service-related emails, such as account verification, changes or updates to features of the Site, and technical / security notices.

To personalize the Site for you.

To process an application completed by you. If you submit an application for an insurance product offered on the Site, then we will disclose the personal information you provide to your chosen insurance company to process your application.

To process payments as requested by you. We may disclose your personal information to other companies that help us process payments. Be assured that the companies we partner with to process payments are not allowed to use your personal information for their own purposes and are contractually obligated to maintain strict confidentiality.

To provide you with information that we believe may be useful to you, such as information about health products or services provided by us or other businesses.

To perform analytics and to improve or optimize our services, our Site functionality, marketing, or for other business needs.

To comply with applicable laws, regulations, and legal process. In certain situations, W3LL may disclose your personal information in response to lawful requests by law enforcement authorities, to comply with a subpoena, or similar legal process. We may disclose your personal information when we believe, in good faith, that the disclosure is required or permitted under law to:

cooperate with regulators or law enforcement authorities;

to resolve consumer disputes;

to protect your (and others) health, safety, or welfare;

to protect our rights, the rights of affiliates or related third-parties, or take appropriate legal action, such as to enforce our Terms of Use;

to investigate fraud;

to otherwise respond to a government request; or

as otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law.

If W3LL is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

You may change or update your personal information by emailing us at W3ll.com”>info@W3LL.com, or in writing by mailing us at W3LL, 1500 Stony Brook Road, Stony Brook, New York USA 11794. Please note we may not be able to revise information which has already been shared with a third-party.

Session Cookies and Beacons

W3LL uses Google Analytics and Raygun to collect visitor data and analyze traffic on our site, and may use other tools and technologies, now or in the future, to support or enhance the functionality of the W3LL website. These technologies help us provide a better experience when you visit our Site and allow us to improve our Site.

Our service providers, advertising partners and ad networks may use cookies and beacons to collect and share non-personal information about your activities both on our Site and on other websites, including, for example, to provide you targeted advertising based upon your interests. In addition, third parties that are unaffiliated with us may also collect information about you, including tracking your browsing history, when you use our Site. We do not have control over these third- party collection practices. If you wish to minimize these third- party collections, and you can adjust the settings of your browsers or install plug-ins and add-ins.

Google Inc. (“Google”) is an example of a service provider that uses cookies or similar technologies to collect information about your browsing activities over time and across different websites following your visit to our Site. Google Analytics is a web analytics service provided by Google that uses first-party cookies to track users’ interactions and collect other information about how you use our Site. Google Analytics collects information anonymously. We then use the information to compile reports, including usage trends, to help us improve our Site. You can opt out of Google Analytics without affecting how you visit our Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/, or review the Google Analytics Terms of Service at https://www.google.com/analytics/terms/us.html.

For more information about opting out of being tracked by Google Analytics across all websites you use, please visit https://tools.google.com/dlpage/gaoptout/.

• Browser Cookies. A browser cookie is a small text file placed on the hard drive of your computer when you visit a website or click on a URL. The cookie then communicates with servers, ours or those of other companies that we authorize to collect data for us, and allows recognition of your personal computer. We associate cookies with personal information only if you use the logged in areas of the Site, order a Service, use the personalization services available as part of the Site, or ask us to contact you with additional marketing information. Otherwise, we do not collect personal information from browser cookies and we do not associate browser cookies with your personal information. You may use the tools available on your computer or other device to set your browser to refuse or disable all or some browser cookies, or to alert you when cookies are being set. However, if you refuse or disable all browser cookies, you may be unable to access certain parts or use certain features or functionality of our Site. Unless you have adjusted your browser settings so that it refuses all cookies, we may use cookies when you direct your browser to our Site. To learn more about cookies, you can visit http://www.allaboutcookies.org .

• Beacons. Our Site and e-mails may contain small electronic files known as beacons (also referred to as web beacons, clear GIFs, pixel tags and single-pixel GIFs) that permit us to, for example, count users who have visited those pages or opened an e-mail and for other website-related statistics. Beacons in e-mail marketing campaigns allow us to track your responses and your interests in our content, offerings and web pages. You may use the tools in your device to disable these technologies as well.

This information is collected for traffic analysis only.

Email Communications

You may receive certain communications from us related to our Site. If you provide us with your e-mail address in order to receive communications, you can opt out of marketing e-mails at any time by following the instructions at the bottom of our e-mails and adjusting your e-mail preferences. Please note that certain e-mails may be necessary for the operation of our Site. You will continue to receive these e-mails, if appropriate, even if you unsubscribe from our optional communications.

Network Advertising Initiative

Certain websites you visit may provide options regarding advertisements you receive. If you wish to minimize the amount of targeted advertising you receive, you can opt out of certain network advertising programs through the Network Advertising Initiative (NAI) Opt-Out Page. Please note that even if you choose to remove your information (opt out) you will still see advertisements while you’re browsing online. However, the advertisements you see may be less relevant to you. For more information or to opt out of certain online behavioral advertising, please visit http://www.aboutads.info.

Additionally, many advertising network programs allow you to view and manage the interest categories that they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The NAI Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies.

Do Not Track

Some browsers support a “Do Not Track” (or DNT) feature, a privacy preference that users can set in certain web browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit. Our Website does not currently recognize or respond to DNT signals, so DNT settings do not change the way the Site operates.

Please note that we cannot control how third- party websites or online services you visit through our Website respond to Do Not Track signals. Check the privacy policies of those third- parties for information on their privacy practices.

Text Alerts

You may receive certain information, updates and/or offers from us via text communications. If you provide us with your mobile number in order to receive such communications, you can opt out of receiving text messages atany time by contacting us at customer_support@w3ll.com.

Updating Information

The accuracy of the information we have about you is very important. To review, correct or delete your personal information, please contact us at customer_support@w3ll.com. For more information about your choices, or to review or correct your personal information, please follow the prompts on the Site, or contact us as indicated in the “Contact Us” section of this Privacy Policy.

We will retain your information for as long as your account is active or as needed to provide the services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Please note that once your application has been submitted to your chosen health insurance company or any other relevant party (such as the federal government in the case of an application involving advanced premium tax credits) you may be required to contact the insurance company or such other party directly to update your application.

Website Security

We have implemented commercially-reasonable measures designed to protect the information that you provide on this Site. We exercise reasonable efforts to safeguard the security and confidentiality of your personal information and insurance information; however, transmissions protected by industry standard technology and administered by humans cannot be guaranteed to be secure. We will not be liable for unauthorized disclosure of personal information that occurs through no fault of W3LL including, but not limited to, errors in transmission, uses of your data by a third-party, your failure to comply with your security obligations, and the unauthorized acts of W3LL employees.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Information for Children Under 13

This Site is not directed at children 13 years of age or younger. If you are under 13, do not use or provide any information on this Site. Do not register on the website, or provide any information about yourself to us, including your name, address, telephone number, email address or any screen name or user name you may use.

If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we may have any information from a child under13 without parental consent, please contact us at the W3ll.com”>info@W3LL.com.

Social Media Disclaimer

We welcome and encourage open discussion on W3LL social media sites – including but not limited to our blogs, Facebook, Twitter, LinkedIn and YouTube pages. We make reasonable efforts 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.

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 sites and that you not disclose personally identifiable information like your location, health insurance ID numbers, personal medical information, financial information, etc. We are not responsible for the content of any comments or responses posted by others to this Site or social media site managed or monitored by W3LL. We do not control the placement of any marketing or advertising displayed on our pages by social media or third-party organizations. The inclusion of links to other websites does not imply any endorsement of the material on the websites.

Your California Privacy Rights

If you are a resident of California, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by Welltheos LLC to a third-party for the third-party’s direct marketing purposes. This right granted to California residents applies only to their activities within the State of California. To make such a request, please send an email to privacy@W3LL.com or write to us at:

W3LL
1500 Stony Brook Road
Stony Brook, New York USA 11794

Please note, we do not share personal information or insurance with third-parties for their direct marketing purposes other than as described in this Privacy Policy. If our practices change, we will provide you with the relevant information as required by applicable law.

Effective Date

The Effective Date of this Privacy Policy is March 6, 2018.