Benovate Holdings, Inc. Platform Privacy Statement

Updated 11/21/18

Introduction

Benovate Holdings, Inc., recognizes that you may have questions about our collection, use and disclosure of personally identifiable information ("PII") that you send to us and other information we collect during the course of your visit to the Benovate platform, portal or mobile applications ("Platform"). We value our relationship with you and want to help keep your experience on our Platform secure, enjoyable, efficient and easy. Contact

If you have any questions or comments about this Privacy Statement, please contact us at helpdesk@benovate.com.

What we Collect

We collect PII from you when you choose to provide it to your employer, third party administrator (TPA), or that you directly provide to us so you can receive information and/or services from us. Generally, PII consists of a first name or initial and last name in combination of one or more of the following: social security number, insurance identification number, employer identification number or address information.

We also collect certain personal health information ("PHI"), such as your height, weight (BMI), diabetes-related information, lab data, telehealth claims and physician visit information, health risk assessment results, and third party assessments.

We collect tracker information, such as: daily steps, weight, fitness (workouts that you’ve done), nutrition (what you've eaten), sleep quality and more.

We also collect Non-Personal Information ("NPI") from you. NPI is information which cannot be easily used to personally identify you and includes, for example, the type of web browser you use to access our Platform, the URL of the previous website you visited, clickstream patterns, your ISP, your operating system and your IP address.

PII, PHI and NPI are collectively referred to as "Information."

How we use the Information we Collect

PII or PHI may be used for our business purposes and in a manner consistent with this Privacy Statement. This use includes, but is not limited to, maintaining, evaluating and improving our sales, services to you, and our Platform.

Individual PII and PHI is used solely to provide our service to you. Your PII and PHI is not provided to third parties that are unrelated to the services we offer you.

We share aggregated data with third parties. Aggregated data cannot be used to personally identify you.

We report to third parties on global usage patterns, but not on an individual basis that can personally identify you.

NPI is used to track your usage of the Platform and other internal purposes, such as Platform maintenance, evaluation and end user-experience.

If you would like to opt-out from our Application tracking, please notify us at helpdesk@benovate.com. Note that if you opt-out, we may no longer be able to deliver services to you.

Our Role as a Data Processor

In the provision of our various services, we act as a processor for the PII and PHI that you, your employer or your administrator choose to provide to us.

Disclosure to Third Parties

We reserve the right to disclose any Information we collect to third parties we directly work with ("Authorized Representatives").

Access and Correction of PII or PHI

You may request that we make changes to your PII or PHI at any time. If we are not the source-of-truth for the data, we will direct you to the correct source to request the change. If you are unable to make the change yourself, please contact us at helpdesk@benovate.com. We require that you validate your identity before any change is made.

Deletion of PII or PHI

You may submit a request to delete your PII or PHI at helpdesk@benovate.com. Before updates are made through this means, appropriate validation of your identity will be made.

Protecting PII or PHI

We strive to maintain reasonable data security measures. However, no security measures are invulnerable to attack. We are not responsible for the security of your PII or PHI that you transmit to us over networks that we do not control, including, but not limited to, wireless networks.

Taking your PII or PHI

You may request that we provide you with the PII or PHI you have provided to us in a machine-readable data file in a standard format (such as 'csv'). If you would like to receive this file, please contact us at helpdesk@benovate.com.

Disclosure to Successors

We may disclose Information to any successor-in-interest of ours, such as, but not limited to, a company that acquires us.

Disclosure to Unaffiliated Third Parties

We may disclose PII or PHI to prevent an emergency, to protect or enforce the rights of a third party, as required or permitted by law (including, but not limited to, compliance with a subpoena).

We do not disclose information to other unaffiliated third parties – we will never sell your PII or PHI to a third-party.

Length of Information Storage

We will keep your Information for as long as is necessary for the continued provision of services to you, or where we have a legitimate interest to continue doing so.

Privacy Statement Changes

We reserve the right to modify, add or remove any terms and conditions in this Privacy Statement without prior notice or liability to you. Any changes we make will be effective immediately following posting on the Platform.

If you are subscribed to our mailing list with a valid e-mail address, you will receive an announcement from us indicating an update to the Privacy Statement has been made.

Children's Privacy

Our Platform and services are not intended for users younger than 13 years of age. Accordingly, we will not knowingly collect or use any PII from children that we know are under 13 years of age. In addition, we will delete any Information in our database that we know originates from a child under the age of 13.

EU-US and Swiss-US Privacy Shield

Cookies and Other Technologies

We use cookies in this Platform. The cookie settings on this Platform are set to 'allow all cookies'.

Our Platform does not currently recognize automated browser signals regarding tracking mechanisms, such as "do not track" instructions. In most mainstream browsers, you can usually set your privacy preferences regarding the use of most cookies and similar technologies. Look under the heading "Tools" (or similar heading) in your browser for information about controlling cookies. You can set your browser in most instances to notify you before you receive a cookie, giving you the chance to decide whether to accept it or not. You may also be able to set your browser to turn off cookies.

If you continue using the Platform without changing these settings, you consent to the use of cookies. You can, however, change your browser settings at any time to control the use of cookies. For more information, please refer to your browser settings.

Links to Third Party Sites

We deliver third party online advertisements on our Platform. You should familiarize yourself with those web site privacy policies/statements to understand their privacy practices.

Data Controller and Contact Information

The data controller of this Platform is Benovate Holdings, Inc. You can contact us at:

2829 University Ave SE, Suite 820
Minneapolis, MN 55414

Data Protection Officer

For questions about your PII, or to lodge a complaint, contact:

Michael Birdman, CEO
Phone: 877-236-6828
E-mail: helpdesk@benovate.com

Other Contact

If you have any general questions or concerns about this Platform, or this Privacy Statement, please feel free to contact us at helpdesk@benovate.com.