Privacy Policy

Last updated and effective as of February 13, 2023

The Services are not intended for use in the event of an emergency or other urgent situation. If you believe you may have a medical emergency, call 911 or your local emergency medical system immediately.

This Privacy Policy explains how information about you is collected, used and disclosed by Wheel Health, Inc. (“Wheel Health”) and our corporate affiliates, including without limitation any subsidiaries, and our professional entities that employ or engage healthcare providers (collectively, “Wheel”, “we”, “us” or “our”). This Privacy Policy applies to information we collect when you use our (a) website located at www.wheel.com (the “Website”); (b) our application programming interface, access tokens, HTML scripts, code snippets, tools, instructions, documentation, and other materials made available by Wheel (collectively, the “Wheel API”); (c) the Wheel Dashboard located at app.wheel.com; and (d) any other services owned or operated by Wheel which link to this Privacy Policy (collectively, the “Services”).

This Privacy Policy does not apply to information that is protected health information (“PHI”) under the Health Insurance Portability and Accountability Act (“HIPAA”). Any collected information that constitutes PHI is governed by, and will be used and disclosed solely as permitted under, the business associate agreement between Wheel Health and your healthcare provider (each, a “Provider”), as required by law, to safeguard PHI. For more information about the privacy of PHI, please contact your Provider. Any information provided directly to a Provider is treated in accordance with that Provider’s notice of privacy practices, and we encourage you to ask the Provider for information about their practices before providing any information to them.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed of our information practices and the ways you can help protect your privacy.

By accessing or using the Services, you consent to our collection, use, and sharing of your information in accordance with this Privacy Policy. This Privacy Policy is not a contract and does not create any contractual rights or obligations.

Please use the links below to jump to the sections of our Privacy Policy to learn more:

• Collection of Information

• Use of Information

• Sharing of Information

• Third-Party Analytics

• Links to Third Party Sites

• Security

• How We Respond to “Do Not Track” Signals

• Note to International Users

• Your Choices

• California Residents

• Children's Online Privacy Policy

• Contact Us

Collection of Information

As used in this Privacy Policy, “Personal Information” means any information that can be used to individually identify a person or household, and may include, but is not limited to, name, email address, postal or other physical address, title, and other information reasonably linkable to an individual or household with or without other identifying information in our possession. Personal Information also includes information relating to a person’s professional background, and may include, but is not limited to, resume, educational history, professional specialty, professional licenses and/or certifications, geographic areas of professional practice, legal claims relating to professional background, and years of professional experience.

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive features of the Services, fill out a form, request customer support, apply for a job with us, or otherwise communicate with us.

The types of information we may collect from you include:

• Account Information: When you register for an account on our Services, you will need to provide us with certain Personal Information to complete the registration, including information that can be used to contact or identify you, which may include your name, email address, username, password, and phone number.

• If you use the Services as a client user (“Client”), we may collect information about your mode of virtual care delivery, the types of Providers you are seeking, current telehealth capabilities, quantity of patient visits per month, and any other information you choose to provide.

• If you use the Services as a Provider, we may collect information about your practice, including, but not limited to, your name, address, email address, phone number, areas of expertise, years of experience, NPI number, whether you have a collaborative agreement with a supervising physician in any states, referral information, license information, malpractice details, resume information, communications you have with other users through the Services, and any other information you choose to provide.

• Health Information: This includes details of your exchanges with Providers and their responses, suggestions, and guidance, and interactions with our digital services. Any PHI will be collected, used and disclosed in accordance with the business associate agreement that we have entered into with the Provider.

• Other Information You Choose to Provide: We may collect additional information that you provide, such as when you request technical or customer support, communicate with us, or apply for a job with us.

Information We Collect When You Use the Services

When you access or use our Services, we automatically collect information about you, including:

• Usage Information: We collect information about your activity on our Services. For example, we may collect information about how Providers use the Wheel Dashboard. We also collect information about onboarding trainings taken, earnings to date, and rates per consult.

• Log Information: We may collect log information about your use of the Services, including the type of browser you use, access times, pages viewed and visited, and your IP address.

• Information Collected by Cookies and Other Tracking Technologies: We and our service providers may use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used on our Services or emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see “Your Choices” below.

Information We Collect from Other Sources

We may obtain information from other sources and use it as contemplated herein, including to provide the Services to and otherwise communicate with you.

Use of Information

We may use information about you for various purposes, including to:

• Provide, maintain and improve our Services;

• Provide and deliver the products and services you request, and send you related information;

• Send you technical notices, updates, security alerts, and support and administrative messages;

• Inform you of job opportunities and evaluate your suitability for a job;

• Respond to your comments, questions, and requests, and provide customer service;

• Communicate with you about products, services, offers, promotions, rewards, and events offered by Wheel and others, and provide information we think will be of interest to you;

• Monitor and analyze trends, usage, and activities in connection with our Services;

• Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of Wheel and others; and

• Carry out any other purpose for which the information was collected.

We also may use aggregated or de-identified information, which cannot reasonably be used to identify you, for various purposes, including, for example, to improve our automation and improve care. Once aggregated or de-identified, the data does not personally identify you, is no longer personal information, and is not subject to this Privacy Policy.

Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

• With vendors, consultants and other service providers, including, but not limited to, hosting providers and payment processors, who need access to such information to carry out work on our behalf;

• In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;

• With other users of the Services;

• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Wheel or others;

• In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;

• To prevent, investigate, or take action against violation of the Terms of Use;

• Between and among Wheel and its current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and

• With your consent or at your direction.

Third-Party Analytics

From time to time, we may partner with certain third parties, such as Google Analytics, to collect, analyze, and use some of the information described above. For example, we may allow third parties to set cookies or use web beacons on the Services or in email communications from Wheel. The information collected by third parties using these technologies may be used to engage in analysis and reporting. These third parties may set and access cookies on your computer or other device and may collect information about your online activities across different websites or services over time, including on websites and mobile applications that are not owned or operated by Wheel. You may review Google Analytics’ security and privacy principles by clicking here and opt out of the use of cookies in web browsers by Google Analytics by clicking here.

Links to Third Party Sites

Our Services may contain links to other web sites. Other web sites may also reference or link to our Services. These other web sites are not controlled by Wheel. We encourage our users to be aware when they leave our Services to read the privacy policies of each and every web site that collects personally identifiable information. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other web sites or mobile applications. Visiting these other web sites is at your own risk.

Security

While Wheel takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction, please be advised that when information is transmitted over the internet, it cannot be guaranteed to be completely secure.

How We Respond to "Do Not Track" Signals

Some web browsers have “Do Not Track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. At present, our Services do not respond to “Do Not Track” signals and consequently, the Services will continue to collect information about you even if your browser’s “Do Not Track” feature is activated.

Note to International Users

The Services are intended for use in the United States of America only. If you access our Services or contact us from outside of the United States of America, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States of America; and (ii) that by accessing our Services or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States of America in accordance with this Privacy Policy.

Your Choices

Account Information

You may update, correct, or delete information about you at any time by logging into your account or by emailing us at [email protected]. If you wish to deactivate your account, you may do so by logging into your account and selecting that option under Account Settings, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Promotional Communications

You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at [email protected]. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Services.

California Residents

California Shine the Light: Residents of the State of California have the right to request information from Wheel regarding other companies to whom the company has disclosed certain categories of information during the preceding year for the other companies' direct marketing purposes. If you are a California resident and would like to make such a request, please email [email protected].

California Consumer Privacy Act
: The California Consumer Privacy Act ("CCPA") provides California residents with the right to receive certain disclosures regarding the collection, use, and sharing of "Personal Information," as well as the right to know/access, delete, and limit sharing of Personal Information. The CCPA defines "Personal Information" to mean "information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household." Certain information we collect may be exempt from the CCPA because it is considered public information (e.g., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.

To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.

Right to notice at collection regarding the categories of personal information collected

You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. This notice should be provided at or before the time of collection. The categories we use to describe the information are those enumerated in the CCPA.

Personal identifiers
: We collect your IP address automatically when you use our Services. We use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and to serve targeted advertisements based on your online activities. If you provide us with your name, phone number, and email, then we will collect those personal identifiers as well. We use this information to notify you of work opportunities should one arise. We may collect your Social Security number or Driver's License number. We use this information to identify you, authenticate and collate information about you, prevent fraud, and conduct background checks or other screening activities.

Geolocation data
: As described above, we collect your IP address automatically when you use our Services. We may be able to determine your general location based on your device's IP address. When you use the Services for the first time, we may ask for your permission to collect your precise location (i.e., your GPS coordinates).

We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.

We may share any of the above-listed information with Service Providers, which are companies that we engage for business purposes to conduct activities on our behalf. Service Providers are restricted from using Personal Information for any purpose that is not related to our engagement. The categories of Service Providers with whom we share information and the services they provide are described in this Privacy Policy.

Protected classifications
: We collect your age in order to comply with laws that restrict collection and disclosure of personal information belonging to minors.

Right to know about personal information collected, disclosed, or sold

You have the right to request that we disclose to you the Personal Information we collect, use, disclose, or sell. In order to process your request to know/access your Personal Information or delete your Personal Information we may ask you to take additional steps to verify your request or identity.

Verification procedures

In order to process your request to know about or delete personal information we collect or disclose, we must verify your request. We do this by providing personal identifiers we can match against information we may have collected from you previously.

If you have authorized someone else to make requests on your behalf, we will require that you provide notarized statements confirming the identity and authority of that person. Such notarized statements can be obtained by emailing [email protected].

Right to know/access information

You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect our customers' Personal Information, we are required to verify your identity before we can act on your request.

Right to request deletion of information

You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. To protect our customers' Personal Information, we are required to verify your identity before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Right to information regarding participation in data sharing for financial incentives

You have the right to be free from discrimination based on your exercise of your CCPA rights. We may run promotions from time to time wherein we incentivize a consumer to share certain pieces of information with us. Participation in these incentives is voluntary, and you may opt out of the data sharing at any time.

Right to opt out of sale of personal information to third parties

Wheel does not offer an opt-out from the sale of personal information because Wheel does not engage in the sale of personal information as contemplated by the CCPA. As noted elsewhere in this disclosure, we share personal information with other businesses for a variety of reasons. While we often benefit from such exchanges, we do not share personal information for the sole purpose of receiving compensation for that information.

How to submit a request

You may submit a request to exercise your rights by emailing [email protected], where you can request and download specific pieces of information we have collected.

Authorized agent

You may authorize another individual or a business registered with the California Secretary of State, called an authorized agent, to make requests on your behalf. We require that you and the individual complete notarized affidavits in order to verify the identity of the authorized agent and confirm that you have authorized them to act on your behalf.

California Consumers

Wheel Health, Inc. respects your privacy and is committed to maintaining the confidentiality of your personal information. This privacy notice (this “Notice”) for California residents applies solely to residents of the State of California (“consumer” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and, as amended, the California Privacy Rights Act of 2020 (“CPRA”). This Notice describes how Wheel Health, Inc. (“Wheel”) and our corporate affiliates (collectively, “Wheel,” “we,” “us,” or “our”) collect information (“Personal Information”) that is subject to the CCPA and CPRA, your rights under the CCPA and CPRA, and how you can enforce those rights under the CCPA and CCPRA.

This Notice is not applicable to Wheel Health’s professional entities that employ or engage healthcare providers, and consumers should refer to the Notice of Privacy Practices.

Examples of Personal Information We Collect from You

Category

Examples

Identifiers

Name, Home Address, Phone Number, DOB, SSN, Email, LinkedIn

Personal Information under the CCPA

Name, SSN, Address, Phone Number, Education, Employment Status/History, Financial Information (direct deposit info and compensation)

Sensitive Personal Information under the CPRA

SSN, Direct Deposit Info, Ethnicity/Race, Disability, Hispanic/Latino, Sexual Orientation, Tobacco User

Education Information

Education (School, Degree, Graduation Year, Field of Study)

Professional/Employment-related Information

Hire Date, Job Title (and Job Code), Employee ID #, Wheel Email Address, Employment Status, Offer Letter, Resume, Cover Letter, Current Job Title, Current Company

Use of Personal Information

Although not an exhaustive list, Wheel uses and discloses your Personal Information for the following purposes:


• Recruitment, interviewing, and vetting candidates for employment

• Background checks for employment and client engagement services

• Administering our applications, software, and systems

• Onboarding and decisions about continued employment or engagement

• Payroll and other compensation

• Organization management and administration

• Responding to employment/contractor verification inquiries

• Research and analytical purposes to improve products and services as necessary

Retention Period

We store personal information for as long as necessary to carry out the purpose for which we originally collected it and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

Use of Sensitive Personal Information

Under the CPRA, we collect the types of sensitive personal information described in the Examples of Personal Information We Collect From You section above. Wheel Health only collects and uses sensitive personal information for certain limited purposes, such as your Social Security Number.

Your Rights Regarding Your Personal Information

You have the following rights regarding your Personal Information maintained by Wheel:

Right to Know

You have the right to know about the Personal Information that the Wheel collects about you. You can request that we disclose to you:

• Categories of Personal Information that Wheel has collected about you, disclosed about you for a business purpose, or sold;

• Categories of sources from which the Personal Information is collected;

• Categories of third parties with whom Wheel shares or to whom Wheel sells Personal Information;

• The business or commercial purpose for collecting and selling Personal Information; and

• Specific pieces of Personal Information that Wheel has collected about you.

Instructions on exercising your rights are below.

Right to Delete

You have the right to request Wheel delete Personal Information collected from you, subject to certain exceptions. Wheel will need to assess federal, state, and local retention requirements when responding to your deletion request.

Instructions on exercising your rights are below.

Right to Opt Out of Sale or Sharing

You have the right to submit a request to opt out of any sale or sharing of your Personal Information. While Wheel does not sell your Personal Information we may share your Personal Information with a third-party vendor after entering into a service provider agreement. Sharing is done for purposes such as background screenings, sanction screenings, etc.

However, WE DO NOT SELL, DISCLOSE, SHARE OR TRANSFER DATA FOR THE COMMERCIAL BENEFIT OF ANY PARTY. WE MAY PAY MONETARY COMPENSATION TO THOSE PROVIDING OR ASSISTING US IN PROVIDING THE SERVICES THAT YOU HAVE REQUESTED WHEN YOU ENGAGED OUR SERVICES AND SOME OF THOSE SERVICES MAY REQUIRE ACCESS OR PROCESSING OF YOUR PERSONAL INFORMATION.

PERSONAL DATA OR THE BENEFIT OF ITS USE IS NEVER PROVIDED IN COMPENSATION FOR SERVICES.

As described in this Notice, that does not mean that we do not share your data with other parties, but any disclosure of data is solely performed for the operation of the site and provision of services. These disclosures include administrative functions, security functions, or operational and necessary services without which we cannot operate our business or provide services to you.

Right to Correct Inaccurate Personal Information

You have the right to request that Wheel corrects personal information that is inaccurate.

Instructions on exercising your rights are below.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to request that Wheel limits use and disclosure your of “Sensitive Personal Information," which is defined above and includes (1) precise geolocation data, (2) racial or ethnic origin, (3) union membership, (4) the contents of certain employee email and text messages, and (5) biometric information. However, this right only applies to use of Sensitive Personal Information other than what would be reasonably expected by an average consumer/employee, so there are some exceptions.

Instructions on exercising your rights are below.

How To Exercise Your Rights

To submit a request to exercise any of your rights described in this Notice, please email [email protected].

WE WILL NOT DISCRIMINATE AGAINST YOU FOR EXERCISING YOUR RIGHTS UNDER THE CCPA OR CPRA. We will not deny you our services, charge you different prices or rates, or provide you with a lower quality of services if you exercise your rights under the CCPA.

If you would like to submit a complaint about our use of your personal information or our response or handling of your requests regarding your personal information, you may contact us at [email protected]. You can also submit a complaint to the California Office of the Attorney General here. For more information on the California Consumer Privacy Act please visit https://www.oag.ca.gov/privacy/ccpa.

Children's Online Privacy Policy

Wheel is committed to protecting the privacy of children who use our site. The Children’s Online Privacy Protection Act (“COPPA”) protects children under age 13 (“Children”). Wheel does not knowingly collect any personal information (as that term is defined in the COPPA) from children under the age of 13 through our website. If you think we have collected such personal information from a child under the age of 13 through our website, please email our Privacy Officer at [email protected].

Contact Us

If you have any questions about Wheel’s privacy practices, please contact us at: [email protected].

© 2020 Wheel Health, Inc.

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