Corewell Health Urgent Care by WellStreet (“we”, “us”, or “our”) respects your privacy. This privacy policy (as amended from time to time as posted on our website at www.corewellhealthurgentcarese.com) (“Privacy Policy”) describes the types of information we collect from you or that you may provide when you visit or use our https://www.corewellhealthurgentcarese.com/ website (“Website”) or use our services (“Services”), and our practices for collecting, using, maintaining, protecting, disclosing, retaining, and transferring that information. We also describe measures we take to protect the security of the information and how you can contact us about our privacy practices.

This Policy applies to Personal Information collected through our Website.

HIPAA

This Privacy Policy does not apply to Protected Health Information (as defined under the Health Insurance Portability and Accountability Act (“HIPAA”). Users who become patients will be presented with our separate Notice of Privacy Practices.

Acknowledgement and Consent

By visiting our Website or using our Services in any manner, you acknowledge that you accept the terms, practices and policies described in this Privacy Policy (and as updated from time to time), and you hereby consent that we may collect, use, and share your information as described herein. If you do not agree with our policies and practices, your choice is not to use our Website or our Services. Your use of the Website and our Services is at all times subject to our Terms of Use (available at https://www.corewellhealthurgentcarese.com/resources/terms-of-use and as updated from time to time (the “Terms”)), which is incorporated by reference herein. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.

What Information Does This Privacy Policy Cover?

This Privacy Policy covers our treatment of personally identifiable information. “Personal Information” means any unencrypted or non-deidentified information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular person such as, but not limited to, your name, mailing address, email address, telephone number, etc. Please see additional information below on the particular information we may collect.

Personal Information does not include your Personal Information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).

We may also collect Personal Information from you through means other than our Website. This may include offline collection, such as if you submit a paper application, make a payment by check, or call or visit our office. It may also include emails, text messages, or other electronic communications that you send to us separate from our Website or by way of our Service Providers (as defined herein). However, if we combine the Personal Information we collect from you outside of our Website with Personal Information that is collected through our Website or by another means as described above, the Privacy Policy will apply to the combined information, unless specifically disclosed otherwise.

By using our Website, you consent to understanding and accepting the terms set forth in this Privacy Policy.

Changes to Our Privacy Policy

We are constantly working to improve our Website and Services, and we may need to change this Privacy Policy from time to time as well. Our current Privacy Policy will always be on our Website and any updates will be effective upon posting. You are responsible for periodically checking our Website for updates. Under certain circumstances, we may also elect to notify registered Users of changes or updates to this Privacy Policy by additional means, such as posting a notice on the Website or by sending you an email, but you should not rely on receiving such additional notice. If you use the Website, purchase Products, or use our Services after any changes to the Privacy Policy have been posted, you agree to the new Privacy Policy. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, OR TO ANY CHANGES WE MAY SUBSEQUENTLY MAKE, IMMEDIATELY STOP ACCESSING OR USING OUR WEBSITE.

Individuals under the Age of 16

We do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 16 or knowingly allow such persons to register for or use our Services. If you are under 16, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. In the event that we learn that we have collected Personal Information from a child under age 16 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us if you have any concerns.

We maintain reasonable administrative, technical, and physical safeguards designed to protect the information that you provide on this website in compliance with applicable laws and regulations. However, no system is impenetrable, and we are not liable for the acts of third parties. We expressly disclaim any liability for any special, incidental, or consequential damages, including, without limitation, lost revenues or lost profits resulting from the use or misuse of the information contained in the Website or our social networks. By using our website or our social media networks, you assume all risks associated with their use, including any risk of your computer, software, or data being damaged by a virus, software, or any other files that might be transmitted or activated via our Website or our social networks. Our online Services are directed at an adult audience and are not intended or designed to attract children under the age of 16. With the exception of certain information in our patient portals as authorized by law, we do not knowingly collect, maintain, or use personal information from children under 16 years of age.

Information We Obtain

The types of Personal Information we may obtain include:

Contact information, such as name, telephone number, postal address, and email address;
Identifying information such as date of birth;
Payment information, such as name, billing address, and payment card details (including card number, expiration date and security code);
Social media information, such as social media handles, content and other data shared with us through social media pages (such as our social media pages or other pages accessible to us);
Geolocation information;
Information you provide in the course of applying for a job with us, such as details about your education, work and military history, legal work eligibility status, and background check information; and
Other information you choose to provide, such as through our "Contact Us" feature, such as emails or other customer support tools.

Personal Information We Collect

We collect several categories of Personal Information from and about you as summarized in Table 1 below:

Category	Specific Items of Personal Information
Identifiers	first and last name email address postal address unique personal identifier, e.g., customer/account name or number, phone number, or mobile device identifier
Demographic	birth date
Internet or other electronic network activity; device information	type and manufacturer of device and its ID/UDID or similar device-specific code operating system and platform screen resolution Internet service provider or mobile carrier's name, connection speed, and connection type browsing, session, interaction, and search history related to our Website Internet Protocol (or IP) address, protocol, and sequence information cookies pixel tags browser type, language, and version domain name system requests mobile device advertising identifier material and pages viewed time and date of access to the Website number of bytes transferred number of clicks per visit IP address date stamp and URL of the last webpage visited before visiting our Website, and URL of the first page visited after leaving our Website pages viewed, time spent on a page, click-through and clickstream data, queries made, search results selected, comments made type of service requested hypertext transfer protocol headers, application client and server banners, and operating system fingerprinting data keystroke and cursor tracking
Geolocation	physical location at a given point in time or movements
Sensory information	voice recording
Professional or employment information (only of job applicants)	email address that identifies you (e.g., jane.r.smith@website.com versus jrs@website.com) employer, employment history, information from professional references, work experience
Other information	signatures; physical characteristics or descriptions; insurance policy numbers; health insurance information

How We Collect Personal Information and from What Sources

Information You Provide Us. The Personal Information we collect through our Website, or from our business partners and service providers may include the following:

Information that you provide by filling in webforms on our Website. This includes information provided when creating an online account, purchasing our Products or Services, subscribing to our e-newsletters or other communications, requesting information from us, submitting or posting material (where permitted) on our forums, or interacting with customer support or service, report a problem with our Website, Products, or Services, or otherwise communicating with us.
Records and copies of your correspondence (including email addresses), if you contact us
Registering for an event
Your responses to surveys that we or our service providers might ask you to complete for research purposes
Your search queries on the Website
In clinics
When communicating with customer service/support
Third party websites and mobile applications (e.g., websites that share information with us or advertising partners regarding online activities)
Data suppliers (e.g., companies that provide demographics and other information regarding consumers)
Joint marketing partners
Online advertising companies
Fulfillment and delivery service providers
Social media companies
Other service providers
Responding to employment opportunities

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including the following:

Details of your visits to our Website, including, but not limited to, traffic data, geolocation data, logs, and other communication data and the resources that you access and use on the Website.
Information about your computer, mobile device, and internet connection, including your IP address, operating system, browser type, clickstream patterns, the URL of the most recent website you visited before coming to our Website, the amount of time you spent on our Website, and the pages you viewed while on our Website.

Behavioral Tracking. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services, or associate Personal Information with other information collected in this manner.

Keystrokes. We or our service providers may keep track of and/or collect the keystrokes and cursor movements of Website visitors before purchase of a Product or Service from our Website (and before we have any email address or other information about you (other than IP address) which would specifically identify you), but, this information is anonymous and, at the time of collection, we do not directly associate or attempt to associate this information with you as an identifiable individual. If you sign up to receive our emails (e.g., through the popup box that appears) we then do have the ability going forward to associate the keystroke and cursor information with the email address you provide. We use this information solely for the purpose of improving our Website to improve our customers’ user experience (e.g., improving navigation, readability, etc.).

The information we collect automatically is statistical data and may include Personal Information, and we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver better and more personalized Products and Services, including, but not limited to, by enabling us to: estimate our audience/visitor size and usage patterns, store information about your preferences, allowing us to customize and improve our Website, speed up your searches, and/or, recognize you when you return to our Website.

Our Careers Website portal (available here) has information about employment opportunities with us, and contains a link which directs you to a third party’s website (but which contains our brands) through which you can submit an application for employment. This application will request certain Personal Information of you. That third party’s website has its own terms of use and privacy policy which you should review prior to submitting any Personal Information through that website. We may be provided your application, including some or all of the Personal Information (and other information) you submit.

Cookie Notice and Policy

The technologies we use for this automatic data collection may include cookies, local storage cookies, web beacons, pixel tracking, GIF, IP address, and other technologies. Each of these is discussed below.

Browser Cookies

Browser cookies are small files placed on the hard drive of your computer or mobile device. They may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Browser cookies are managed by the web browser (Internet Explorer, Firefox, Safari, Google Chrome, etc.) on your computer or mobile device. Different types of cookies which have different purposes are used on our Website.

Essential Cookies

Essential cookies are essential to allow you to browse our Website and use its functions. Without them, services such as shopping baskets and electronic invoicing would not be able to work.

Performance Cookies

Performance cookies collect information on the use of our Website, such as which pages are consulted most often. This information enables us to optimize our Website and simplify browsing. Performance cookies also enable our affiliates and partners to find out whether you have accessed one of our Website pages from their site and whether your visit has led to the use or purchase of a Product or Service from our Website, including the references for the Product or Service purchased. These cookies do not collect any information which could be used to identify you. All the information collected is aggregated, and therefore anonymous.

Functionality Cookies

Functionality cookies enable our Website to remember the choices you have made when browsing. For example, we can store your geographical location in a cookie so that the Website corresponding to your area is shown. We can also remember your preferences, such as the text size, font and other customizable aspects of the Website. Functionality cookies may also be able to keep track of the products or videos consulted to avoid repetition. The information collected by these cookies cannot be used to identify you and cannot monitor your browsing activity on sites which do not belong to us.

It is possible that you will come across third-party cookies on some pages of sites that are not under our control.

We also use cookies such as functionality cookies to implement tracking technology on our Website. This allows us to display advertising that is tailored to you on our Website, to understand which parts of our content interest you the most, and which Product or Service categories you request. This tracking uses De-Identified Personal Information data. Some of our service providers are allowed to place cookies on our Website. Those companies may also provide you with the option of preventing the use of cookies in the future. For more information, contact the relevant third-party provider.

At any time, you can prevent the use of cookies in the future. You may activate the appropriate setting in your browser to refuse to accept browser cookies. However, if you do, your experience on our Website may be affected; e.g., you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Local Storage Cookies

Certain features of our Website may use local stored objects (to collect and store information about your preferences and navigation to, from and on our Website. Local storage cookies are not managed by the same browser settings as are used for browser cookies.

Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Pixel Tracking. In addition to using cookies, the Website may employ “pixel tracking”, a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our products, services, and offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing, research, and other activities.

GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.

P Address. Our servers (or those of our service providers) automatically record certain log file information reported from your browser when you access the Website. These server logs may include information such as which pages of the Website you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Website. These log files are generally deleted periodically.

Artificial Intelligence. We use artificial intelligence (AI) to enhance the functionality of our services. Our AI models help improve services and deliver relevant content. If you would prefer not to have your data processed in certain ways, you can adjust the settings in your browser.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers and application providers. First-party or third-party cookies may be used alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. A first-party cookie is a cookie set by the domain name that appears in the browser address bar. A third-party cookie is a cookie set by (and on) a domain name that is not the domain name that appears in the browser address bar. It might be set as part of a side resource load (image, JS, iframe, etc., from a different hostname) or an AJAX HTTP request to a third-party server. The information that first-party and third-party cookies collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services (i.e., tracking such activities). They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. More information on how to opt-out of third-party advertiser tracking mechanisms here.

Google Tools. We use tools provided by Google as described below.

Google Analytics. We use, and some of our third-party service providers may use, Google Analytics (click for link to Google’s website) or other analytics service to help us understand the use of our Website and Services. Google Analytics is a web analysis service provided by Google. Google utilizes data it collects to track and examine the use of our Website to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. The Personal Information collected and processed may include cookies, usage data, and other internet information. Such service providers may place their own cookies in your browser. This Privacy Policy covers use of cookies by us only and not the use of cookies by third parties.

Google AdSense Advertising. We use Google AdSense Advertising (or other search engine or display network advertising) on our website. Google’s advertising requirements and principles are available here. They are put in place to provide a positive experience for users. We have implemented the following: (a) Remarketing with Google AdSense and (b) Google Display Network Impression Reporting.

Google Maps/Google Earth. We also use Google Maps (including the Google Maps API(s)) and/or Google Earth, which may, among other things, request access to your geolocation, and both of which are subject to their own terms of use and privacy policy.

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add-on.

Tracking Pixels. We incorporate “pixels” provided by one or more companies, e.g., Meta Platforms, Inc. (Facebook), X (formerly Twitter), Google, Yelp, etc., on our Website. This enables us to track user behavior after a user clicks on an ad (e.g., one from Facebook) and is redirected to our Website. By doing so, we can assess the effectiveness of the ads for statistical and market research purposes and sometimes retarget certain users. Please note that the data collected through this process remains anonymous to us, meaning we do not have access to personal data of individual users. However, that pixel provider stores and processes this data. Therefore, we are providing you with this information based on our current understanding. It is important to be aware that the pixel provider may associate this information with your account with that pixel provider and utilize it for its own promotional activities, in accordance with its data usage policy. You have the option to authorize the pixel provider and its partners to display advertisements on and off that company’s website pages. Additionally, a cookie may be stored on your computer for these purposes.

We may use these automated technologies on our Website to collect information about your equipment, browsing actions, and usage patterns. These technologies help us (1) remember your information so you do not have to re-enter it; (2) track and understand how you use and interact with our Website; (3) tailor the Website around your preferences; (4) measure the usability of our Website and the effectiveness of our communications; and, (5) otherwise manage and enhance our Services, and help ensure they are working properly.

In addition, as indicated above, we may collect your device’s geolocation information. With your permission, we may receive the precise geolocation and other location information of your device through GPS, Bluetooth and Wi-Fi signals, and other technologies. We use your geolocation to identify the nearest urgent care facility to your then-current location. Your device may provide you with a notification when the Website attempts to collect your precise geolocation. Please note that if you decline to allow the Website to collect your precise geolocation, you may not be able to use all the Website’s features or the offers available through the Digital Website.

How We Use the Information We Obtain

We may use the Personal Information we obtain to:

Present our Website and its contents to you;
Provide our Services;
Process and fulfill transactions in connection with our services;
Provide you with information and respond to your questions on Products or Services that you request from us and information on new products and services, discounts, special promotions or upcoming events, and features or offers that we believe will be of interest to you;
Communicate with you (including providing you with offers and other communications about our services), respond to inquiries and offer customer support;
Verify your identity;
Personalize your experience on our Digital Properties;
Advertise and market our services;
Administer participation in surveys, promotions, or other programs;
Process transaction payments, including, but not limited to, Product and/or Service fees, subscription fees, professional fees, membership dues, registration fees, and payments, refunds and reimbursements for any products or services that you choose to purchase from us (though we do not receive your credit or debit card number);
Respond to your requests and inquiries and provide customer support;
Provide you with notices about your account, including expiration and renewal notices;
Process Personal Information or other information that you submit through to us;
Operate, evaluate and improve our business (including developing new services; enhancing, improving and analyzing our services; managing our communications; analyzing our user base and Website; performing data analytics and market research; and performing accounting, auditing and other internal functions);
Contact you about our own and third-parties’ products and services that may be of interest to you;
For internal purposes, such as Website or Service and system operation, administration, maintenance, internal audits and reviews, diagnosing technical problems, and maintaining security;
Maintain and enhance the safety and security of our Website and services and prevent misuse;
Exercise our rights and remedies and defend against legal claims;
Notify you of data privacy incidents or provide you with legally required information; and,
Protect against, identify, and prevent fraud and other criminal activity, claims and other liabilities.

We also may use the information in other ways for which we provide specific notice at the time of collection.

We use cookies, clear gifs, and log file information to: (a) monitor the effectiveness of our Services; (b) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns; and/or (c) diagnose or fix technology problems reported by our users or engineers that are associated with certain IP addresses.

We may use your Personal Information you provide us and which we obtain from other sources to better understand your interests so we can try to predict what other products, services and information you might be most interested in. This practice involves making automated decisions about you based on this information in order to better enable us to tailor our interactions with you to make them more relevant and interesting. You may object to our doing this at any time by contacting us (see Contact Information/User Rights below).

Consent to Receive Text Messages.

You consent to our sending you Short Message Service (“SMS”) messages as described in this paragraph. We typically may deliver up to three SMS messages per day to your cellphone or other wireless device (unless you communicate further with us and we need to or can respond), but, depending on appointment and visit frequency, message frequency may vary. SMS messages and frequency are driven by appointment reminders, confirmations, and patient-initiated check-in services. Additionally, we may also contact you by SMS messages with billing and payment reminders, surveys, informational and service-related communications, including important security updates, as well as for marketing and awareness purposes (e.g., to make an appointment with us for flu and RSV testing and treatment). You may request us to stop sending SMS messages by replying “STOP” to the SMS message you received. After you send the SMS message “STOP” to us, we will send you a SMS message to confirm that you have been unsubscribed. Alternatively, you may submit your request by email (or by any other reasonable means) to us, including the email address and phone number you sent to us. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again. For help, please reply to a text with HELP. Message and data rates may apply, depending on your cell phone plan. Carriers are not liable for delayed or undelivered messages. We will not be liable in the event that you or anyone else inappropriately uses your device or accesses your text data You acknowledge and agree that we and our service providers will not be liable for improper disclosure of your health information that is not caused by our intentional misconduct.

Interest-Based Advertising

We may obtain information about your online activities to provide you with advertising about services that may be tailored to your interests.

You may see our ads on other websites because we use third-party ad services. Through these ad services, we can target our messaging to users considering demographic data, users’ inferred interests and browsing context. These services track your online activities over time and across multiple websites and apps by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other similar technologies. The ad services use this information to show you ads that may be tailored to your individual interests. The information ad services may collect include data about your visits to websites that serve our advertisements, such as the pages or ads you view and the actions you take on the websites or apps. This data collection takes place on our Website .and helps us track the effectiveness of our marketing efforts.

How We Share Your Personal Information

We may or do disclose your Personal Information, in whole or in part, to the following types of third parties, and for one or more of the following purposes:

Data storage or hosting providers for the secure storage and transmission of your data
Database and software service providers for the management and tracking of your data
Technology providers who assist in the development and management of our Website
Legal and compliance consultants, such as external counsel, external auditors, or tax consultants
Payment solution providers for the secure processing of payments you provide to us
Survey and research providers who perform surveys or studies on our behalf

Disclosures to Service Providers. We may share your Personal Information with third parties for the purpose of providing or improving the Services to you. We may share your Personal Information with third party service providers which perform services on our behalf (“Service Providers”). This includes, without limitation, Service Providers which provide services relating to: outbound and/or inbound communications, data analysis, credit checks, screening checks, collection services, marketing assistance, managing customer information, creating, hosting, and/or providing customer or support services on our behalf, fulfilling orders, sending postal mail and email, removing repetitive information from customer lists, providing search results and links (including paid listings and links), processing credit card payments, or managing our conferences and other events. These Service Providers may have access to your Personal Information in order to provide these services to us or on our behalf. If we engage Service Providers for any of the foregoing, use of your Personal Information will be bound by obligations of confidentiality, and their use of Personal Information will be restricted to providing their services to us. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting Service Providers).

Required Disclosures. Except as otherwise described in this Privacy Policy, we will not disclose your Personal Information to any third party unless required to do so by law, court order, legal process, or subpoena, including, but not limited to, in order to respond to any government, regulatory, or licensing request, or if we believe that such action is necessary to: (a) comply with the law, comply with legal process served on us or our affiliates, subsidiaries, contracted vendors, or affinity partners, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) enforce our Terms or customer agreement (including for billing and collection purposes); (c) take precautions against liability; (d) investigate and defend ourselves against any third-party claims or allegations; (e) assist government enforcement agencies or to meet national security requirements; (f) to protect the security or integrity of our Website or Services; or, (g) exercise or protect the rights, property, or personal safety of us, our users or others.

We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Website, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.

It is likely that the identity and categories of such third parties will change during the life of your account. We require that our third-party service providers only use your Personal Information as necessary to provide the requested services to us and each service provider is subject to a set of terms consistent with the applicable portions of this Privacy Policy.

Disclosure of De-Identified Personal Information. We may share De-Identified Personal Information with third parties for any purpose. De-Identified Personal Information or non-Personal Information may be aggregated for system administration and to monitor usage of the Website. It may be utilized to measure the number of visits to our Website, average time spent, number of pages viewed and to monitor various other Website statistics. This monitoring helps us evaluate how visitors use and navigate our Website so we can improve the content. We may share De-Identified Personal Information or anonymous information (including, but not limited to, anonymous usage data, referring/exit pages and URLs, IP address, platform types, number of clicks, etc.) with interested third parties in any way we choose and for any purpose.

Your Consent to Disclosure/Transfer/Sale of Your Personal Information. You consent to our disclosure of your Personal Information, De-Identified Personal Information, and other information you provide to us (collectively, “Transferred Information”) to a potential or actual buyer or acquirer of our company or other successor for the purpose of considering or undergoing a merger, divestiture, restructuring, reorganization, dissolution, change in control, or sale or transfer of some or all of our assets (each of the foregoing referred to as a “Transfer”), whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger or operation of law) as part of a Transfer, of any or all of our rights, in whole or in part, in or to Transferred Information and your consents, with or without notice to you and without your further consent. We cannot make any representations regarding the use or transfer of Transferred Information that we may have in the event of our bankruptcy, reorganization, insolvency, receivership, or an assignment for the benefit of creditors. By providing any Personal Information, you expressly agree and consent to the use and/or transfer of Transferred Information or other information in connection with a Transfer. Furthermore, except as required by law, we are not and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the Transferred Information that is disclosed to us.

Links to Third-Party Services and Features

For your convenience and information, our Digital Properties may provide links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently from us. The privacy practices of the relevant third parties, including details on the information they may collect about you, are subject to the privacy statements of these parties, which we strongly suggest you review. To the extent any linked online services or third-party features are not owned or controlled by us, we are not responsible for these third parties’ information practices.

Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. Your Personal Information is contained behind secured networks and a firewall and is only accessible by our personnel and by a limited number of Service Providers who have special access rights to our systems, and who are required to keep the information confidential. Our Website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our Website safe. All of your Personal Information is encrypted in transit and at-rest.

Any payment transactions will be performed using our third-party payment processors or gateways, who will use appropriate security procedures designed to protect your information. We do not collect or store full credit card numbers.

Our agents, contractors, service providers, and partners who require access to your Personal Information in order to provide services to us or to you on our behalf are also required to keep the information confidential in a manner consistent with this Privacy Policy and are not permitted to disclose the information to third parties or use the information for any purpose other than to carry out the services they are performing for us, or as permitted pursuant to our agreement with them.

Data Retention

The time period for which we retain your Personal Information depend on the purposes for which we use it. We will retain your Personal Information for as long as your account is active, or as long as you are a user of our Services or for as long as we have another business purpose to do so (such as, but not limited to, for business, tax, or legal purposes), or as required by law, and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.

Following termination or deactivation of your user account, we may retain your profile information and all information posted to public areas of the Website. Following termination or deactivation of your user account, we may retain your Personal Information and other data, but will maintain it as confidential according to the Terms, this Privacy Policy, and as required by applicable law. We have the right to delete all of your Personal Information and other data after termination of your user account without notice to you.

We may retain De-Identified Personal Information for as long as we deem appropriate.

What Information You Can Access, Change, or Delete

Through your user account settings page, you may access and, in some cases, edit, or delete certain information you have provided to us, such as name and password, email address, address, user profile information, etc. The information that you can view, update, and delete may change as the Products, Website, Services or our practices change. If you have any questions about viewing or updating information we have on file about you, please contact us.

Notices; Opting Out

By providing us with your email address (including by “following”, “liking”, linking your account to our Website or Service or other services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices by email, including any notices required by law (e.g., notice of data privacy or security incidents), in lieu of communication by postal mail. You also agree that we may send you notifications of activity regarding our Products, Services, the Website, your Personal Information, or any aspect of our relationship, to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails. Please note that if you have opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them.

You can add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us. It is your responsibility to maintain your current email address with us.

Where We Process and Store Personal Information

We have our headquarters in the United States. The Personal Information we or our service providers collect may be stored and processed in servers within or outside of the United States and wherever we and our service providers have facilities around the globe, and certain information may be accessible by persons or companies outside of the United States who provide services for us. You consent to our and our service providers’ transmission and/or transfer of your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.

Privacy Notice for California Residents and Residents of Certain Other States

California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act of 2020 (together, “CPRA”, available here). If you are a California resident (occasionally referred to below as “Consumer”), California law provides Consumers with additional rights regarding our use of your Personal Information. Certain I other states in the U.S., including Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia (as of the effective date of this Privacy Policy) provide (now or in the future) their state residents with rights related to their Personal Information. Although some of these rights apply generally, certain rights will only apply to limited individuals or circumstances. To the extent that these laws apply, you may exercise the following rights, as applicable:

Right to Know and Access Information - Note that much of the information you are entitled to know or access is disclosed in this Privacy Policy. With this said, you have the right to know about our information practices. You also have the right to access the categories of Personal Information we collect, with whom we share or sell that information, and, in some cases, what specific Personal Information we associate with you or your account.
Right to Data Portability - If you request a copy of your specific information then we will provide it in an easily accessible format.
Right to Deletion - You may request that we delete the information we have collected about you. Depending on the applicable law, in some cases we are required or permitted to retain your information, even if you validly requested we delete or erase it. Upon receipt of a verifiable request to delete, we will delete Personal Information from our records and notify our service providers to delete the same Personal Information from their records. Please note, we may delete some information and de-identify some information. In cases where we de-identify information, we implement technical safeguards and business processes. We may not be able to comply with a deletion request if it is necessary for us to keep information in order to, among other things, provide goods or services requested, maintain an ongoing business relationship, comply with legal obligations, protect against fraudulent or illegal activity, or perform other necessary activities as permitted under applicable law.
Right to Correct Information - You may request we correct or rectify inaccurate information we have collected about you.
Right to Opt out of Targeting Advertising, Sales, or Profiling - You may opt-out of our use of your Personal Information for targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects.

We have not sold or shared (as those terms are defined under CPRA) your Personal Information for monetary or other valuable consideration; however, our use of cookies and other website tracking technologies may be considered a sale or sharing of Personal Information under the CPRA, in which case the categories of Personal Information that we have sold or shared under the CPRA include identifiers (e.g., IP addresses) and internet or other similar network activity. Categories of third parties to whom Personal Information is sold or shared under the CPRA include data analytics providers and advertising and marketing providers.

How to Exercise Rights under State Privacy Laws

U.S. residents wishing to exercise any rights under this Section should submit a request to us by emailing us at compliancews@wellstreet.com, or calling the toll-free number 1-800-338-3971

Please include the following information in your request:

Whether you want to exercise the right to access or delete Personal Information.
Information we may already maintain such as first and last name, the email address you use to interact with us, your zip code, etc.
Whether you are making the request for yourself or for someone for whom you are authorized to act as a designated agent. If you are making the request on behalf of someone else, provide proof of such authorization.

We will use the information above, and any information it already maintains to verify identity to make sure we do not provide or delete Personal Information in response to a fraudulent request. We may request additional information to help identify an individual or verify that you want your information deleted. If we are unable to confirm that the individual making the request is the same person about whom we have collected Personal Information, we will not be able to complete the request.

We will attempt to provide the requested information or confirm completion of a request to delete Personal Information within the time period required by law. We will notify you within that time period if we will need additional time to process your request.

We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

If we deny your rights request, you may have the right to request an appeal of our decision. To initiate an appeal, follow the instructions provided in the communication denying your request, or contact us at the information provided in this Privacy Policy.

You have the right to not experience discrimination from us for exercising the rights listed in this Section. What we mean by discrimination is denying you access to our services or limiting the quality of our services. However, limiting use of, or deleting, your Personal Information may restrict the purposes or uses that rely on that information.

California Online Privacy Protection Act (“CalOPPA”; also known as the “Shine the Light” law) Calif. Bus. & Prof. Code § 22575-22578, available here) CalOPPA applies only to companies which collect Personal Information of California residents.

How We Respond to Do Not Track Signals. CalOPPA requires us to let you know how we respond to web browser Do Not Track (“DNT”) signals. DNT is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on DNT, see here. Because there currently isn’t an industry or legal standard recognizing or honoring DNT signals, we don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take. You can visit our Website anonymously by adjusting the settings in your browser.

Third-Party Behavioral Tracking. We allow third-party behavioral tracking of Personal Information, though we may use De-Identified Personal Information to track users’ click and/or browsing patterns.

Contact Information

If you have any questions about this Privacy Policy or our privacy practices, please contact us by email at compliancews@wellstreet.com.

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