Privacy Policy

Effective Date: January 15, 2026

Welltheos LLC, doing business as W3LL (“W3LL,” “we,” “us,” or “our“), values the privacy and security of the information entrusted to us. This Privacy Policy explains how we collect, use, disclose, and safeguard information in connection with the W3LL.com website and the W3LL Broker Agency Cloud platform (collectively, the “Services“).

This Privacy Policy applies to licensed insurance brokers and agents (“Users”) and other authorized business users who access or use the Services. By accessing or using the Services, you acknowledge that you have read and understand this Privacy Policy and agree to the practices described below. If you do not agree, you should not use the Services.

This Privacy Policy is intended for a United States audience. All information collected is processed and stored in the United States.

  1. Relationship to Other Agreements
    This Privacy Policy is incorporated by reference into the W3LL Terms of Service and operates alongside the W3LL Business Associate Agreement (“BAA”), where applicable. To the extent information constitutes Protected Health Information (“PHI”) under the Health Insurance Portability and Accountability Act of 1996, as amended (“HIPAA”), the BAA and HIPAA govern W3LL’s use and disclosure of such PHI.
  2. Information We Collect

A. Information You Provide

The Services are intended solely for use by licensed insurance brokers and agents. In connection with broker-led enrollment and related administrative functions, W3LL may collect information provided by Users and information Users submit about individuals they represent (such individuals, “Consumers”).

Depending on how you interact with the Services, we may collect the following categories of information:

    • Broker and Agent Information: name, business contact information, licensing details, National Producer Number (NPN), appointment status, credentials, and account information;
    • Consumer Information Submitted by Brokers: personal identifiers, health information, and eligibility-related data that Users submit on behalf of Consumers in connection with insurance applications or enrollment transactions;
    • Financial and Eligibility Information: information necessary to facilitate premium payments, eligibility determinations, or government subsidy assessments, where applicable;
    • Communications: information provided in communications with W3LL support or compliance teams.

W3LL does not offer accounts to, or permit direct access by, individual health plan members or consumers. Any Consumer information processed through the Services is provided by Users acting on behalf of such individuals. Users are solely responsible for providing any privacy notices, disclosures, or authorizations required by applicable law to the Consumers they represent.

  1. How We Use Information

We use information collected through the Services for the following business and compliance purposes:

    • To provide, operate, and maintain the broker-facing Services;
    • To enable Users to facilitate health insurance enrollment, eligibility determinations, renewals, updates, and cancellations on behalf of Consumers;
    • To verify broker and agent licensing, appointments, training, and compliance requirements;
    • To communicate with Users regarding accounts, transactions, security alerts, audits, and service updates;
    • To process payments and related transactions initiated by Users, where applicable;
    • To monitor, analyze, and improve the performance, security, and integrity of the Services;
    • To detect, prevent, and investigate fraud, misuse, or unauthorized activity;
    • To comply with applicable laws, regulations, CMS and Exchange requirements, audits, and governmental requests;
    • To enforce the Terms of Service, the BAA, and other applicable agreements.

W3LL does not use Consumer information for direct marketing to Consumers and does not sell personal information.

  1. How We Share Information

We may disclose information as follows:

    • With Insurance Carriers and Covered Entities: to process applications, enrollments, renewals, updates, or cancellations;
    • With Government Entities: including CMS, state-based exchanges, or regulators, as required for compliance, oversight, audits, or program integrity;
    • With Service Providers: vendors that perform services on our behalf (such as hosting, analytics, payment processing, or security), subject to contractual confidentiality and security obligations;
    • For Legal and Compliance Purposes: to comply with applicable law, legal process, subpoenas, court orders, or lawful government requests;
    • Business Transfers: in connection with a merger, acquisition, reorganization, or sale of assets, subject to appropriate confidentiality protections.

We do not share personal information with third parties for their own direct marketing purposes.

  1. Cookies, Analytics, and Similar Technologies

We use cookies, web beacons, and similar technologies to operate and improve the Services, understand usage patterns, and enhance user experience. These technologies may collect information such as session activity, browser characteristics, and general location information.

We may use third-party analytics providers (such as Google Analytics, 6sense, or similar tools) to help analyze traffic and usage trends. These tools collect information in aggregate form and do not permit us to identify individual users directly.

You may control cookies through your browser settings. Disabling cookies may affect the functionality of the Services.

  1. Communications

You may receive transactional or service-related communications from W3LL, such as account notices, security alerts, and operational updates. These communications are necessary for the operation of the Services.

If you opt in to receive marketing communications, you may unsubscribe at any time by following the instructions provided in those communications. Opting out of marketing messages does not affect transactional communications.

  1. Data Retention

We retain information for as long as necessary to provide the Services, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. Retention periods may vary depending on the nature of the information and applicable legal requirements.

  1. Data Security

We maintain administrative, technical, and physical safeguards designed to protect information against unauthorized access, disclosure, alteration, or destruction. However, no system can be guaranteed to be completely secure, and we cannot guarantee absolute security.

You are responsible for maintaining the confidentiality of your login credentials and for all activity conducted through your account.

  1. Consumer Requests, Choices, and Data Rights

Although W3LL does not provide accounts or direct access to individual health plan members or consumers, we recognize that applicable privacy laws may permit Consumers to request access to, correction of, or deletion of certain personal information.

Where a Consumer submits a request relating to personal information processed through the Services, such requests should generally be directed to the broker or agent who collected the information and maintains the direct relationship with the Consumer. W3LL may, as appropriate, assist Users in responding to such requests to the extent required by applicable law and consistent with our contractual and regulatory obligations.

W3LL may deny or limit a request to delete or modify information where retention is required or permitted by law, regulation, CMS or Exchange requirements, tax, audit, fraud-prevention, security, or dispute-resolution obligations, or where the information is necessary to maintain the integrity of the Services.

Requests relating to information that W3LL controls in its capacity as a service provider or business associate may be submitted by email to privacy@w3ll.com. We will respond in accordance with applicable law.

  1. Children’s Privacy

The Services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that such information has been collected, we will take appropriate steps to delete it.

  1. External Links and Social Media

The Services may contain links to third-party websites or social media platforms. This Privacy Policy does not apply to those third parties, and W3LL is not responsible for their privacy practices or content.

Any information you post on public or social media platforms may be viewed by others and should be shared with caution.

  1. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The revised version will be posted on the website with an updated effective date. Your continued use of the Services after the effective date constitutes acceptance of the updated policy.

  1. Contact Us

If you have questions or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Email: privacy@w3ll.com
Mail:
W3LL
1500 Stony Brook Road
Stony Brook, NY 11794

State Privacy Rights Addendum

This State Privacy Rights Addendum (“Addendum“) supplements the W3LL Privacy Policy and applies solely to individuals whose personal information is processed through the Services and who reside in states that have enacted comprehensive consumer privacy laws, including California, Colorado, Connecticut, Utah, and Virginia (collectively, “State Privacy Laws“).

  1. W3LL’s Role

W3LL does not offer accounts to, or interact directly with, individual health plan members or consumers. Personal information relating to consumers is submitted to W3LL by licensed insurance brokers or agents acting on the consumer’s behalf. In this context, W3LL generally acts as a service provider or processor, rather than as a consumer-facing business or controller, for purposes of State Privacy Laws.

  1. Categories of Personal Information

The categories of personal information processed by W3LL may include:

    • Identifiers (such as name, contact information, and government-issued identifiers);
    • Commercial and transaction information related to insurance enrollment and administration;
    • Internet or network activity information related to use of the Services;
    • Professional or employment-related information relating to brokers and agents;
    • Sensitive personal information and health-related information submitted by Users on behalf of consumers, as permitted by law.
  1. Purposes of Processing

W3LL processes personal information for the following purposes:

    • To provide, operate, secure, and maintain the broker-facing Services;
    • To facilitate health insurance enrollment, eligibility determinations, renewals, updates, and cancellations;
    • To comply with CMS, Exchange, carrier, and other regulatory requirements;
    • To prevent fraud, misuse, and unauthorized access;
    • To comply with legal obligations and enforce applicable agreements.
  1. Sale and Sharing of Personal Information

W3LL does not sell personal information as defined under State Privacy Laws. W3LL does not share personal information for purposes of cross-context behavioral advertising or targeted advertising.

  1. Consumer Rights Under State Privacy Laws

Subject to applicable exemptions and limitations, State Privacy Laws may provide consumers with certain rights, including the right to:

    • Request access to certain personal information;
    • Request correction of inaccurate personal information;
    • Request deletion of personal information;
    • Opt out of certain processing activities, where applicable under law.

Because W3LL does not maintain a direct relationship with consumers, requests relating to consumer personal information should generally be directed to the broker or agent who collected the information and maintains the consumer relationship. W3LL may assist brokers and agents in responding to verified requests to the extent required by applicable law and consistent with contractual, regulatory, and retention obligations.

  1. Limitations on Requests

W3LL may deny or limit a request where retention or processing of the information is required or permitted by law, including obligations relating to:

    • CMS, Exchange, and insurance regulatory requirements;
    • Tax, audit, and recordkeeping obligations;
    • Fraud prevention, security, and system integrity;
    • Legal claims, investigations, or dispute resolution.
  1. Submitting Requests

Verified requests relating to information that W3LL processes in its capacity as a service provider or business associate may be submitted by email to privacy@w3ll.com. W3LL may require additional information to verify the identity of the requester and the requester’s authority. Responses will be provided in accordance with applicable law.

  1. California-Specific Notice

W3LL does not use or disclose sensitive personal information for purposes other than those permitted under the California Consumer Privacy Act and its implementing regulations.