Consumer Health Data Privacy Policy

Categories of CHD Collected

As described further in our Privacy Policy, and depending on how you interact with WELL and applicable law, we may collect the following categories of CHD, as broadly defined in the MHMDA, Nevada CHD Law, and CTDPA:

• Individual health conditions, treatment, diseases, or diagnoses: E.g. in connection with you seeking healthcare services or medications from WELL.
• Social, psychological, behavioral, and medical interventions: E.g. through collection of your medical history as part of the treatment services you seek on or through WELL.
• Health-related surgeries or procedures: E.g. through collection of health-related surgeries or procedures within your medical history as part of the treatment services you seek on or through WELL.
• Use or purchase of prescribed medication: E.g. through your purchase of medication through WELL or through the medical history you provide to us.
• Bodily functions, vital signs, symptoms, or measurements of health information: E.g. as part of you seeking healthcare services or medications from WELL.
• Diagnoses or diagnostic testing, treatment, or medication: E.g. as part of the medical history collected by WELL, or when you otherwise seek healthcare services or medications from WELL.
• Gender-affirming care information: E.g. as part of the medical history collected by WELL, or when you otherwise seek healthcare services or medications from WELL.
• Reproductive or sexual health information: E.g. as part of the medical history collected by WELL, or when you otherwise seek healthcare services or medications from WELL.
• Genetic data: E.g. where such information is included in medical history collected by WELL.
• Data that identifies a consumer seeking health care services: E.g. as part of the medical history collected by WELL, or when you otherwise seek healthcare services or medications from WELL.
• Other information that may be used to infer, derive, or extrapolate data related to the above or other health information.

Sources of CHD

As described further in our Privacy Policy, we collect information, which may include CHD from the following sources:

1. Directly from you;
2. Automatically through your use of the Services;
3. Social media and other content platforms; and
4. Other third-party sources.

Purposes for Collection of CHD

We describe the purposes for collection and use of CHD in the "How We Use Your Information" section of our Privacy Policy. As further described there and subject to applicable law, we may collect and use CHD as directed by you or with your consent, or:

1. To provide and manage the Services;
2. To analyze and improve the Services;
3. For advertising and marketing; and
4. For legal purposes, such as to comply with laws or to establish, exercise, or defend our legal rights.

How and Why We Share CHD

We may share each of the categories of CHD described above for business purposes to the categories of entities described in the "How We Share Your Information" section of our Privacy Policy. As further described in our Privacy Policy and subject to applicable law, we may share the categories of CHD:

• To deliver products and services to you, including to complete any transactions initiated by you;
• To ensure a consistent level of service across our products and services;
• To enhance our products, services, and your customer experience;
• With your consent, such as disclosures for certain advertising or promotional efforts, including allowing third parties to collect CHD across our Services;
• To protect WELL and others, including to enforce our Terms of Service, Privacy Policy, or other contracts with you, and for fraud prevention;
• To comply with our legal obligations; and
• In connection with any negotiation or completed acquisition, merger, or purchase involving our business assets.

As described in our Privacy Policy, we reserve the right to create aggregate/de-identified data from the information we collect through the Services and our disclosure of such aggregate/de-identified data is in our discretion.

As further described in our Privacy Policy, and subject to applicable law (e.g. subject to your consent in certain situations), we may share CHD with the following categories of third parties and affiliates:

• Health Care Providers and Services;
• Service Providers;
• Advertising Networks;
• Joint Product/Marketing Partners;
• For the Protection of WELL and Others (e.g. to governmental or regulatory agencies);
• For Legal Purposes (e.g. to governmental entities in response to legal process);
• As Necessary for Business Transfers;
• At Your Direction or With Your Consent (such as sharing with other users/public if you post in public forums or interact with other users).

WELL does not sell your CHD.

How to Exercise your MHMDA, Nevada CHD Law, or CTDPA Rights

If you are a resident of Washington, Nevada, Connecticut, or another state with consumer health data privacy laws, you may have the right to confirm, access, delete, correct, withdraw consent to the collection, use, or disclosure of, and receive a portable copy of your CHD. Additional information regarding these rights, including how to exercise them, is available in our Privacy Policy. To exercise any of these rights, please contact us at privacy@well.inc.

State-Specific Provisions

Washington residents: We do not sell your consumer health data. We do not use geofencing to identify, track, or collect consumer health data from individuals.

Nevada residents: We do not sell your consumer health data. If this changes, we will provide a clear opt-out mechanism.

Connecticut residents: We do not sell or share your consumer health data for targeted advertising purposes.

California residents: Additional rights information is available in our Privacy Policy.

Updates to this CHD Policy

We may update this CHD Policy from time to time. If we make material changes, we will notify you by posting the updated Policy on our website with a new "Last Updated" date. Material changes will be effective 30 days after notice is provided. Your continued use of our Services after the effective date constitutes acceptance of the updated Policy.

Contact Us

If you have questions about this Consumer Health Data Privacy Policy or wish to exercise your rights, please contact us: