Website and Privacy Statement

Introduction

CHOICE Health Network provides the following websites (hereinafter “Websites”):

• choice-health.org

The Websites allow our members and other users to, among other things, view health-related information, communicate with our practitioners and staff, arrange for clinical and health plan services, and access additional medical/health services.

This Privacy Statement applies to the Websites, which are owned and operated by CHOICE Health Network. This Privacy Statement describes how CHOICE Health Network collects and uses the personal information you provide on, and other information that is collected from, your use of the Websites. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

Personal information means information that is individually identifiable. Information that has been de-identified by CHOICE Health Network or others is no longer personal information and is not covered by the terms of this Privacy Statement.

All of your protected health information maintained by CHOICE Health Network , including information you provide on the Website, is also subject to the Notices of Privacy Practices issued by CHOICE Health Network under the Health Insurance Portability and Accountability Act (“HIPAA”). The Notices of Privacy Practices may contain additional provisions relating to the use and disclosure of your information that go beyond the terms of this Privacy Statement.

CHOICE Health Network is committed to protecting the privacy of the users of the Website. We will only use and disclose your personal information as stated in this Privacy Statement.

Website Privacy Statement

Use and disclosure of health information includes using the information to provide treatment to the individual, to make payments for such treatment, and to conduct

ongoing quality improvement activities. Our use and disclosure of an individual's personal information (including health information) is limited as required by state and federal law. We do not sell or rent personal information about visitors to the website.

Security

The Websites have security measures in place that are intended to help protect against the loss, misuse, unauthorized access or alteration of information under our control both during transmission and once the information is received. These measures include encryption of data using the Secure Socket Layer (SSL) system, and using a secured messaging service when we send your personal information electronically to the Website or the App. Despite these measures, the confidentiality and security of any communication or material transmitted to or from CHOICE Health Network via the Website, text message or email cannot be guaranteed. At your discretion, you may contact CHOICE Health Network. at the mailing address or telephone number listed in the "Questions, complaints, and contacts" section at the end of this Privacy Statement.

Revisions to the Privacy Statement

We may revise this Privacy Statement from time to time as we add new features or modify the way in which we manage information, or as laws change that may affect our services. If we make material changes to our Privacy Statement, we will post notice of these changes on our Website and the App prior to the changes becoming effective. Any revised Privacy Statement will apply both to information we have received about you prior to the time of the change, and any personal information created or received after the change takes effect. We will include a version number on this Privacy Statement consisting of the date (year, month, and day) it was last revised. We encourage you to periodically reread this Privacy Statement to see if there have been any changes to our policies that may affect you.

Website Data

In addition to web logs, (described below), CHOICE Health Network routinely gathers data on website and mobile application activity, such as how many people visit the Websites, the web pages or mobile screens they visit, where they come from, how long they stay, etc. The data is collected on an aggregate basis, which means that no personally identifiable information is associated with the data. This data helps us improve our content and overall usage. The information is not shared or sold with other organizations for their independent use.

The Website and the App do not honor a browser’s signal or header request not to track the user's activity.

Collecting,Using, and Disclosing Personal Information

Except as disclosed in this Privacy Statement, we do not collect any personally identifiable information about visitors to the Website or the App. The policies, sources, uses and disclosures of information are outlined in Sections 1 through 19 that follow:

1. Web logs

As is true of most websites, we gather certain information automatically. We maintain industry standard Web logs that record data about all visitors and customers who use the Website and we store this information for no longer than reasonably necessary to carry out its legitimate business purpose, or as legally required. These logs may contain the Internet domain from which you access the site (such as xfinity.com, att.com, etc.); the IP address which is automatically assigned to your computer when you get on the Internet (a static IP address may be identifiable as being connected to you, while a dynamic address is usually not identifiable); the type of browser and operating system you use; the date and time you visited; the pages or mobile screens you viewed; and the address of the website you linked from, if any. If you sign on to the Website or the App to use secured features, our Web logs will also contain an individual identifier and show the services you have accessed. All Web logs are stored securely and may only be accessed by CHOICE Health Network employees.

2. Internet cookies

We and our service providers may place Internet "cookies" or similar technologies (JavaScript, HTML5, ETag) on the computer hard drives of visitors to the Website or the App. Information we obtain helps us to tailor our site and the App to be more helpful and efficient for our visitors. For example, we are able to see the navigation path taken by users, and that information allows us to understand user success or challenges with the web experience. The cookie consists of a unique identifier that does not contain information about your health history. We use two types of cookies, "session" cookies and "persistent" cookies, along with other similar technologies.

A session cookie is temporary and expires after you end a session and close your web or app browser. We use session cookies to help customize your experience on our site, maintain your signed-on status as you navigate through our features, and to track your "click path" through our Web pages or mobile screens.

Persistent cookies remain on your hard drive after you've exited from our website, and we use them for several reasons. For instance, if you've given us permission to email you with information about your CHOICE Health Network benefits or for other reasons, we may place a persistent cookie on your hard drive that will let us know when you come back to visit our site. We sometimes use this type of persistent cookie with a "Web

beacon" (see below). Persistent cookies will not contain any personal health information about you such as a medical record number.

You may have software on your computer that will allow you to decline or deactivate Internet cookies, but if you do so, some features of the Website or the App may not work properly for you. For instructions on how to remove cookies from your hard drive, go to your browser's website for detailed instructions. In addition, further information regarding cookies may be available on other websites or from your Internet service provider. Commonly used browsers include Safari, Chrome, Firefox, Internet Explorer and iOS.

4. Web beacons

We may also occasionally use "Web beacons" (also known as "clear gifs," "Web bugs," "1-pixel gifs," etc.) that allow us to collect non-personal information about your response to our email communications, and for other purposes. Web beacons are tiny images, placed on a Web page or email, that can tell us if you've gone to a particular area on our website. For example, if you've given us permission to send you emails, we may send you an email urging you to use a certain feature on our website. If you respond to that email and use that feature, the Web beacon will tell us that our email communication with you has been successful. We do not collect any personal health information with a Web beacon, and do not link Web beacons with any other personal health information you've given us.

Since Web beacons are used in conjunction with persistent cookies (described above), if you set your browser to decline or deactivate cookies, Web beacons cannot function.

Our mobile application contains software development kits (SDKs) that may collect and transmit information back to us or third-party partners about your usage of that mobile application or other applications on your device. Such data, when collected by a 3rd party, that may show what click path was taken, what pages users visited and how long certain pages took to display, is not identifiable to you as an individual.

5. Re-targeting

We have contracted with a third-party ad network to manage our advertising on other sites. Our ad network service provider uses cookies, Web beacons, and other tracking technologies to collect information about your activities on this and other websites and to then provide you with RFMG advertising on other websites.

6. Emails, voice messages, and SMS text messaging

CHOICE Health Network may use third-party vendors to help us manage some of our email and voice/text messaging communications with you. While we do supply these vendors with email addresses or mobile telephone numbers of those individuals, we wish them to contact, your email address or mobile telephone number is never used for any purpose other than to communicate with you on our behalf. When you click on a link in an email, you may temporarily be redirected through one of the vendor's servers (although this process will be invisible to you) which will register that you've clicked on that link and have visited our Website. CHOICE Health Network never shares any information, other than your email address or telephone number, with our third-party email and voice/text messaging vendors, which may only share this information with its authorized subcontractors.

Even if you have given us permission to send emails or voice/text messages to you, you may revoke that permission at any time by following the "unsubscribe" information at the bottom of the email, or by following the instructions in the voice or text message.

7. Evaluation and quality improvement

We will periodically ask users to complete surveys asking about their experiences with features of the Website. Our surveys ask visitors for demographic information such as age, gender, and education, but will not request that users provide specific information about any medical condition. We use survey information for evaluation and quality improvement purposes, including helping CHOICE Health Network to improve information and services offered through the Website and the App. In addition, users giving feedback may be individually contacted for follow-up due to concerns raised during the course of such evaluation. Demographic information and Web log data may be stored for future evaluation and quality improvement activities.

8. Messages and transactions

Comments or questions sent to us using email or secure messaging forms will be shared with CHOICE Health Network staff and health care professionals who are most able to address your concerns. We will archive your messages once we have made our best effort to provide you with a complete and satisfactory response.

9. Credit card transactions

If you provide us with your credit card number for pharmacy prescriptions or other payments, we will treat your credit card number in a secure manner.

10. Children

We do not knowingly collect personally identifiable information from children under the age of 13. If CHOICE Health Network is made aware it is collecting information from a child under 13, we will delete this information immediately.

11. Disclosures

We may disclose personal information to any person performing audit, legal, operational, or other services for us. We will use information which does not identify the individual for these activities whenever reasonably possible. Information disclosed to vendors or contractors for operational purposes may not be re-disclosed to others by such a vendor or contractor, except as permitted by CHOICE Health Network and applicable law.

We may also disclose your personal information to third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us pursuant to written instructions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use your personal information they receive from us for any other purpose.

These services may include:

• payment processing

• providing customer service

• sending marketing communications

• fulfilling subscription services

• conducting research and analysis

• providing cloud computing infrastructure

We may also disclose your personal information:

• as required by law, such as to comply with a subpoena, or similar legal process

• as described in our Notices of Privacy Practices for protected health information

• when we believe in good faith that disclosure is necessary to protect our rights, protect you or others from threats of imminent harm, investigate fraud or other activity in violation of the law, or respond to a lawful request by public authorities (including to meet national security or law enforcement requirements)

• to protect the security and reliability of the Website and the App

• If CHOICE Health Network 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 and the App of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information

• to any other third party with your prior consent to do so

• to CHOICE Health Network entities to carry out business planning and development, business management, and general administrative activities, such as to provide, maintain and personalize our sites and services, and to communicate with you

12. Opt out

If a user makes a request to receive information (for example, requesting a subscription to one of our online publications) in an ongoing manner through the Website or the App by providing an email address or mobile phone number, the user may request to discontinue future mailings or messages. Similarly, if you receive information about a CHOICE Health Network service through email or voice/text message, you may make a request to discontinue receiving similar messages in the future. Materials sent to you by email or voice/text message may contain information about how to opt out. Please note, however, that you cannot opt out of certain messages, such as an email letting you know that a doctor has sent you a secure message or our Choose Health newsletter.

13. Other requests to limit use and disclosure of your personal information

State and federal laws may allow you to request that we limit our uses and disclosures of your personal information for treatment, payment, and health care operations purposes. We will consider all requests and if we deny your request, we will notify you in writing. Federal law requires us to agree to your request to restrict disclosures to a health plan or insurer relating to specific health care services if you have paid for those services in full. The law does not, however, require us to restrict any disclosures we think are important for treatment purposes.

14. Data retention

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy statement, including to meet our legal obligations, resolve disputes, and enforce our agreements, unless a longer retention period is required or permitted by law.

15. Social media

Our Website and the App include Social Media Features, such as the Facebook button. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy statement of the company providing them.

16. Location

An IP address (also called Internet address) is assigned to your device by your Internet Service Provider and is a requirement to use the internet. IP addresses are used to make the connection between your device and the websites and services you use. You can’t prevent a website or app from getting the IP address of your device. Your IP address includes some general information about your device location and we use that to display your proximate location in the website and mobile app user experience. We derive your internet device’s proximate location from your IP address, which is provided to us when you come to the website. We do this to provide you with a customized experience on our Website including the display of location-based information that’s relevant to you and your care.

With your permission, we may collect your precise device location using technologies like GPS, Wi-Fi, and Bluetooth, to help you find a facility, doctor, or directions within a facility or to provide you with timely notices when you visit a facility.

Questions, Complaints, and Contacts

If you have any questions about this Privacy Statement, our policies and practices concerning the Website, your rights under this Statement, and your dealings with the CHOICE Health Network you can contact CHOICE Health Network by email at admin@choice-health.org or by U.S. mail at the address below:

CHOICE Health Network
357 Van Ness Way- Suite 140
Torrance, CA 90501

(800)676-9870

Last revised: August 12, 2022