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Effective June 6, 2017

Web Site Privacy Policy

Table of Contents

Introduction

The Finity Communications, Inc. ("Finity") Privacy Policy describes how we collect and use information received through this site. This policy does not apply to information that may be received by phone, text message, social media, postal mail, or in person.

Does this privacy policy apply to me?

Yes, by visiting this site, you are accepting Finity's Privacy Policy. You are also consenting to the application of the laws of the State of Oregon and the venue of Multnomah County, Oregon for the resolution of any disputes that arise in connection with your use of this site.

You may have reached this site directly or by clicking on a link on another site or advertisement. Finity has no control over and is not responsible for the privacy policies or terms of use on sites owned or operated by other companies. We recommend that you regularly check the policies for all sites that you visit to remain informed about how your information is collected and used.

How will I know if this privacy policy has been revised?

Finity may revise this Privacy Policy at any time, without prior notice. By visiting this site, you are accepting all revisions. The current policy will always be dated and posted on this site. We recommend that you review it periodically to remain informed about Finity's privacy policies and standards.

What if I access this site from outside the U.S.?

This site is designed for use within the United States. If you access this site from outside the U.S., you are accepting that your information will be captured and stored by a U.S.-based server and will be subject to U.S. laws and regulations. You further accept responsibility for compliance with any applicable foreign laws and regulations.

What is an Internet "cookie?"

Internet cookies are small files stored by your computer's browser that contain non-personally identifiable information. Many Web sites use cookies to collect information about you. You have the option to delete or block these cookies using your browser privacy settings at any time. Deleting or blocking cookies may affect the functionality of this site.

Does this site use Internet cookies?

UNLESS YOU VOLUNTARILY PROVIDE IT, Finity does not use cookies to collect or store any personally identifiable information. We do collect anonymous traffic data about visitors to this site using Google Analytics, including IP address, device type and capabilities, OS version, browser type and capabilities, number of visitors, length of visits, and time spent on pages.

We may use this information to evaluate your use of the site, compile activity reports for Web site operators, provide other services relating to Web site activity and Internet usage, and for any other lawful purpose. This data may also be shared with third-party companies that have retained Finity to provide certain products or services to you (e.g., your employer, health plan provider, healthcare provider, health coaching provider, third-party health services entity, or financial institution), or to comply with a court order or other legal requirement.

You may refuse the use of cookies by selecting the appropriate settings on your browser. If you do this, you may not be able to use the full functionality of this site. By using this site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

If you affirmatively provide us with personally identifiable information, read the following section.

What if I voluntarily submit personal information on this site?

If you voluntarily and affirmatively submit personally identifiable information (e.g., your name, e-mail address, phone number, health information, credit card number, account numbers, etc.), Finity may use your information to:

What if I share personal information in a chat room or forum?

This Privacy Policy does not apply to personal information you may share in a chat room, discussion forum, bulletin board, or through social media. Any such information is not secure and may be visible to all visitors. We recommend that you carefully consider the lack of privacy in a chat room before posting any information that may become public.

Does this site collect information protected by HIPAA?

Yes, as part of our health and wellness products and services, Finity may collect information that is protected by the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") and related laws and regulations (collectively, the "HIPAA Rules").

PHI includes information that personally identifies an individual or that may be used to personally identify an individual. Examples of PHI include:

The HIPAA Privacy Rule protects all personally identifiable health information ("PHI") from improper use or disclosure by Covered Entities (such as health plans) and certain Business Associates.

This site, and the products and services that may be available through it, are designed to comply with the applicable HIPAA Rules. We collect your PHI only if you affirmatively and voluntarily submit the information as part of the health and wellness program, products, and services available through this site.

For example, as part of the registration process for a wellness challenge or health activity, you may be asked to submit your name, age, height, weight, health conditions, health risk factors, etc.

The PHI we collect may be shared with your employer to administer your health program or incentive, your health plan, or plan sponsor, third-party health service entities, or to comply with a court order or other legal requirement. To find out how your employer, health plan, or plan sponsor may use your PHI, we recommend that you review their privacy policies and terms of use.

Does this site collect genetic information?

Finity does not collect genetic information for any purposes that are prohibited by the Genetic Information Nondiscrimination Act of 2008 ("GINA"). GINA generally prohibits health plans from collecting genetic information, including family medical history, prior to or in connection with enrollment, for underwriting purposes, or as part of a Health Risk Assessment (HRA).

Your employer, plan sponsor, or health plan provider may collect genetic information for lawful purposes. To find out how any such third parties may use your genetic information, we recommend that you review their privacy policies and terms of use, or contact them directly.

Does this site collect Social Security Numbers?

Yes, as part of the products and services available through this site, Finity may collect your Social Security Number or it may be provided to us by your employer, health plan provider, or plan sponsor.

We use advanced encryption, security technology, and rigorous administrative procedures to protect your Social Security Number from unauthorized use or disclosure.

How do you use personal information collected on this site?

Finity does not sell any of the personally identifiable information we collect. In the course of business, we may share your personal information with your employer, plan sponsor, or health plan. We may also share some of your personal information with third parties such as healthcare providers, financial institutions, third-party health service entities, retailers, and credit card companies for the purposes of administering a wellness program or rewards program.

We may sometimes receive personal information about you from third-party entities. Those entities may apply different policies to the use of your personally identifiable information. Finity does not endorse or control the use of information shared with or received from any such third-party entities.

Will you publicize my name if I'm given a reward?

Finity reserves the right to use your name in the event that you are rewarded with an achievement reward, participation reward, gift card, raffle prize, health premium discount, HSA/HRA contribution, or other type of reward. Your name may appear on the site for employer incentive purposes or to notify other participants in your company that the reward has been awarded.

Can I opt-out of receiving communications?

Yes, Finity provides an opt-out button if you do not wish to receive certain types of communications through this site.

We have no control over the opt-out policies of other companies, including your health plan, plan sponsor, employer, etc.

How does this site protect personal information?

Finity uses advanced encryption, security technology, and other safeguards to prevent unauthorized access to this site and to maintain the security of collected data and information.

We are not responsible for any harm that may occur if you voluntarily or accidentally disclose your personal information, including your User Name or Password, to any third parties.

Is information provided by email secure?

No, email is an inherently insecure mode of communication. Emails may be misdirected, redirected, forwarded, or shared with or without your permission. We recommend that you carefully consider the information you transmit by email, especially personally identifiable information and PHI.

How do I correct errors in my personal information?

Depending on the services available, you may be able to update your information through your user profile or Personal Health/Financial Center. You can also click on the Customer Support link.

Who can I contact about this Privacy Policy?

If you have questions or concerns about this Privacy Policy, you can contact Finity at legal@finity.com.

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