This Privacy Notice applies to personal information processed by Members HQ (“Members HQ,” “We,” “Us,” and “Our”) in the course of Our business, as collection from Our Benefits Hero mobile application (“Mobile App”) and Our related online and offline offerings (collectively, the “Services”).

1. Personal Information. When you use Our Services, We may collect the following categories of personal information:
   
   
   1. Information you provide to Us.
      
      
   2. Setting up Benefits Hero. When you download and open the Mobile App, Members HQ will ask you for some personal details including but not limited to your last name, email address, and last four digits of our social security number in order to verify your identity.  
      
      
   3. Integrated Features. Members HQ may offer integrated features such as virtual care, pharmacy benefits, and other integrated features.  Members HQ and other individuals who use Our Services may collect the information you submit or make available through these integrated features.
      
      
   4. Communications with Us. We may collect personal information from you such as email, address, phone number, mailing address, member identification, and family information and contact details when you communicate with us.
      
      
   5. Automatic Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, device information and other information about how you use the Services. Information We collect may be associated with your account and the devices you use.
      
      
   6. Information from Other Sources. We may obtain information about you from other sources, including through third-party vendors. For example, if you use our Services to access third party vendors, such as a pharmacy benefit services or a virtual care visit.
      
      
2. How We Use Your Information. We process personal information for a variety of business purposes, including:
   
   
   1. To provide the Services, Products, or Information Requested.
      1. Fulfill Our Services for you;
      2. Tailor content and recommendations for you;
      3. Manage your information;
      4. Respond to questions, comments, and other requests;
      5. Process your payment card and/or other financial information to facilitate your use of the Services;
      6. Provide access to certain areas, functionalities, and features of Our Services; and
      7. Answer requests for customer or technical support.
         
         
   2. Administrative Purposes.
      1. Pursue legitimate interests, such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
      2. Measure interest and engagement in the Services;
      3. Develop of new products and services;
      4. Improve Our products and Services;
      5. Ensure internal quality control and safety;
      6. Verify individual identity;
      7. Carry out audits;
      8. Communicate with you about activities on the Services and changes to Our agreements;
      9. Prevent and prosecute potentially prohibited or illegal activities;
      10. Enforce Our agreements; and 
      11. Comply with Our legal obligations.
          
          
   3. Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways We market to you include email campaigns, texts, push notifications and personalized advertising related to the Services you are using with us.  If you have any questions about Our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact Us at any time as set forth below or change your application settings.
      
      
   4. De-identified and Aggregated Information Use. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trend, reports, or statistics, or other analyses We create. De-identified and aggregated information is not personal information, and We may use, share, and publish such information in a number of ways, including research, analysis, analytics, and any other legally permissible purposes.
      
      
   5. Technologies. Our uses of such Technologies fall into the following general categories:
      
      
      1. Operationally Necessary. This includes Technologies that allow you access to Our Services that are required to identify irregular behavior, prevent fraudulent activity and improve security or that allow you to make use of Our functions;
         
         
      2. Performance Related. We may use Technologies to assess the performance of Our Services, including as part of Our analytic practices to help Us understand how Our users use the Services;
         
         
      3. Functionality Related. We may use Technologies that allow Us to offer you enhanced functionality when accessing or using Our Services. This may include identifying you when you sign into Our Services and keeping track of your specified preferences or past pages viewed;
         
         
      4. Advertising or Targeting Related. We may use first-party or third-party Technologies to develop and deliver content, including ads relevant to your interests, on Our Services or on third-party sites.
         
         
   6. Consent. Members HQ may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
      
      
3. How We Disclose Your Information
   
   

   1. Service Providers. We may share any personal information We collect about you with Our third-party service providers. The types of service providers to whom We entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) marketing and advertising; (iv) payment processing; (v) customer service activities; and (vi) the provision IT and related services.

      B. Business Partners. We may provide personal information to business partners to provide you with a product or service you have requested. We may also provide relevant personal information to business partners with whom We jointly offer products or services.

      C. Interest-Based or Personalized Advertising. Through Our Services, Members HQ may allow third-party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit third party services within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your personal information with third party advertising partners, you may follow the instructions below.

      D. APIs and Software Development Kits. We may use third party APIs and software development kits (“SDKs”) as part of the functionality of Our Services. APIs and SDKs may allow third parties including advertising partners to collect your personal information to provide content that is more relevant to you. For more information about Our use of APIs and SDKs, please contact Us as set forth below.

      E. Disclosures to Protect Us or Others. We may access, preserve, and disclose your personal information if We believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, Our or others’ rights, property, or safety; (iii) to collect amounts owed to Us; (iv) when We believe disclosure is necessary or appropriate to prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (v) if We, in good faith, believe that disclosure is otherwise necessary or advisable.

      F. Merger, Sale, or Other Asset Transfers. If We are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

4. International Data Transfers. All information processed by Us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States and other Countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
   
   
5. Your Choices.
   
   
   1. Email & Text Communications. If you receive an unwanted email or text message from Us, you can use the unsubscribe link found at the bottom of the email or email Us at care@benefitshero.io with the subject line “Opt-Out” or text “STOP” to our text message. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding Us and Our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Notice).
      
      
   2. Mobile Devices. We may send you push notifications through Our App.  You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device or within Our App.  With your consent, We may also collect precise location information if you use Our App.  You may opt-out of this collection precise location information if you use Our App. You may opt-out of this collection by changing the settings on your mobile device.
      
      
      1. General. You may have the right to object to or opt out of certain uses of your personal information Where you have consents to the processing of your personal information, you may withdraw that consent at any time by contacting Us as described below. 
         
         
   3. Technologies and Personalized Advertising. If you would like to opt-out of the Technologies We employ on the Services, you may do so by blocking, disabling, or deleting them as your browser or device permits.  Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android and iOS. The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from advertisers that participate in self-regulatory programs. Please note, you mut separately opt out in each browser and on each device.
      
      
   4. “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that We do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
      
      
6. Individual Rights in Personal Information. For purposes of the certain state and federal laws, Members HQ does not “sell” your personal information.  In accordance with applicable law, you may have the right to: (i) request confirmation of whether We are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to Us, or ask Us to send that information to another company (the “right of data portability”); (iv) restrict Our uses of your personal information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; and (vi) request erasure of personal information held about you by Members HQ, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact Us as set forth below. We will process such requests in accordance with applicable laws. To protect your privacy, Members HQ will take steps to verify your identity before fulfilling your request.
   
   
7. Data Retention. We retain the personal information We receive as described in this Privacy Notice for as long as you use Our Services or as necessary to fulfill the purpose(s) for which it was collected, provide Our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce Our agreements, and comply with applicable laws.
   
   
8. Security of Your Information. We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and We cannot ensure or warrant the security of any information you provide to Us. To the fullest extent permitted by applicable law, We do not accept liability for unauthorized disclosure. By using the Services or providing personal information to Us, you agree that We may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If We learn of a security system’s breach, We may attempt to notify you electronically by sending a notice through the Services or by sending an email to you.
   
   
9. Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to Our Services. These third-party services are not controlled by Us. We encourage Our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
   
   
10. Children’s Information. The Services are not directed to children under 13 (or other age as required by local law), and We do not knowingly collect personal information from children. If you learn that your child has provided Us with personal information without your consent, you may contact Us as set forth below. If We learn that We have collected any child’s personal information in violation of applicable law, We will promptly take steps to delete such information.
    
    
11. Changes to Our Privacy Notice.  We may revise this Privacy Notice from time to time at Our sole discretion. If there are any material changes to this Privacy Notice, We will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use the Services after the new Privacy Notice takes effect.
    
    
12. Contact Us. If you have any questions about Our privacy practices or this Privacy Notice, please contact Us at: care@benefitshero.io. If you receive an unwanted email from Us, you can use the unsubscribe link found at the bottom of the email or email Us at care@benefitshero.io.