Korean Privacy Notice

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Modern Health Privacy Notice

Effective Date: June 22, 2021.

Modern Life Inc. and its affiliates (“Modern Health”, “we”, “our”) respect your privacy. This Privacy Notice describes the types of information we collect about users (“you, your”) of our mental health and well-being products and services, including, without limitation, your use of www.modernhealth.com, any other Company websites and any mobile applications made available to you by the Company (“Modern Health Service” or “Service”), how we use the information, and with whom we share it. We also describe the rights you may have and how you can contact us about our privacy practices.

This Privacy Notice does not describe medical and treatment information collected by Providers during coaching or therapy sessions.

The Service may provide links to third-party websites or services that we think may be of interest to you. Any information you provide to those third-party websites are controlled by those third parties and are subject to their privacy policies. We encourage you to read their privacy policies carefully before giving them your information.

By accessing or using the Service, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Notice and our Terms of Use. Any capitalized terms that are not defined in this Privacy Notice are defined in the Terms of Use.

Information We Collect

Information you give us when you use the Service:

Creating an account and onboarding. When you create a user account we collect information that enables you to register and onboard to use our products and services, such as your name, company, date of birth, contact information (phone number, email address), location, preferred password, and primary language. To enable us to personalize your experience, provide recommended care options, and design new products and services, we also collect your answers to our well-being assessment as well as information about your preferred areas of focus.

Using the Service. When you use the Service, we collect additional information that you provide to us such as your preferences related to our Providers, your level of commitment to different types of services, your availability for matches to our Providers, your location, your communication preferences (e.g. language, phone number, email), information related to your match with Providers, and information related to scheduling and completing your visits with Providers, such as session date, time, status and attendance. In certain circumstances, we may collect payment information. We also may collect information about your progress in using the Service if you choose to provide such information to us.

Information about your dependents. We also may collect information about any dependents you invite to use the Service, such as your dependents’ names, dates of birth, primary language, email, location, your relationship to the dependents, the types of support requested for your dependents and how you want us to communicate with you about such dependents.

Customer Support, Product Research, and Feedback. When you reach out to us such as to obtain support, give us feedback about the Service and our Providers, or participate in optional satisfaction surveys, product research (including user testing), we may also collect information that you choose to share.

Information we get when you use the Service:

Device Information. We may collect device information such as Internet Protocol (“IP”) addresses, log information, error messages, device type, and unique device identifiers. For example, we collect IP addresses from you when you log into the Service as part of our log-in and security features.

Cookies and Other Technologies:

Modern Health and our service providers may collect data about your use of the Service through the use of cookies, HTML Web Storage, web beacons, and similar technologies. A cookie is a small file placed on your hard drive by some of our web pages. HTML5 local stored objects may store larger amounts of information on your browser. When you access the Service, either through our mobile applications or website, certain information (including computer and connection information, mobile application use, browser type and version, operating system and platform details, and the time of accessing the Service) is automatically collected. We, or third parties we do business with, may use cookies to help us analyze our web page flow, customize the Service, content and advertising, measure promotional effectiveness, and promote trust and safety. This information will be collected every time you access the Service and it will be used for the purposes outlined in this Privacy Notice. You can reduce the information cookies collected from your device by changing your browser settings to notify you when a cookie is being set or updated, or to block cookies altogether. Some browsers also allow you to control local stored objects through your browser settings. More information about how to do this may be found at www.allaboutcookies.org/manage-cookies.

Information We Get From Third Parties

We may also get information about you from other third parties where permitted by applicable law. We may collect information about you from our customers to enable us to validate your eligibility to use the Service, facilitate your use of the Service, provide support to our customers, or to assess outcomes from use of the Service. This information may include your name, work email address, date of birth, gender, race/ethnicity, employee ID number or code (if applicable), employment start and end dates, department, title, job code (if applicable), office location, performance information, health claims data, or survey information about your work satisfaction and related topics. We also may collect information about you from Providers where permitted by applicable law to enable us to match you with a different Provider or to facilitate your continuity of care. We may combine information that we collect from you through the Service with information that we obtain from such third parties and information derived from other products or services we provide.

How We Use the Information We Collect

We use the information that we collect:

To register and onboard you for the use of the Service and to further tailor our products and services for your use;

To provide the Service, including to communicate with you regarding any scheduled or available services or to connect you to a provider;

To maintain, manage and secure your access to the Service through our web and mobile apps;

To maintain records relating to your account;

To maintain records relating to our customers in order to administer our business;

To manage our relationship with you and with our customers and communicate with you and our customers about new features and services that we may offer;

To respond to inquiries and resolve disputes;

To conduct research such as case studies and academic research;

To carry out analytics, quality control, security processes and similar activities, in order to identify and develop potential improvements to the Service;

To measure your satisfaction with Modern Health Service through surveys, feedback and ratings;

To process payments from you in certain circumstances;

To prevent, detect, and prosecute illegal or fraudulent activity on the Service; and

To develop potential sales and other business opportunities related to our products and services.

How We Share the Information We Collect

We may share your information electronically for the following reasons:

With service providers that support the delivery of our products and services, such as cloud storage providers; CRM system providers; event tracking and logging providers, system monitoring providers; productivity/collaboration tool providers, data insights, validation and reporting providers; messaging and notification providers; database storage and analytics providers; help desk utility providers; engagement and analytics providers, customer survey providers; calendaring and scheduling providers; payment processors; and video functionality providers.

With third parties for research, actuarial or marketing purposes or to publish academic or policy-related materials consistent with applicable law, such as through aggregation or de-identification, or with your consent.

With Provider(s) when you are matched to Provider(s) for therapy or coaching support.

With other entities in the Modern Health group for the purposes described in this Privacy Notice.

Where you have registered with us for a sales initiative, promotion, or event, we may share your registration information with our event partners and presenters.

For any other purpose, at your direction or otherwise with your consent.

In addition, we may disclose information about you (i) if we are required or permitted to do so by law or legal process, (ii) when we believe disclosure is necessary or appropriate to prevent physical harm, financial loss or other material harm, (iii) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (iv) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation, or the negotiations or diligence regarding such transactions). In connection with such disclosure, we will notify you or obtain your consent, as and when required by applicable law.

Data Transfers

We may transfer the information that we collect about you to recipients in countries other than the country from which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries, we will comply with applicable legal requirements regarding providing appropriate safeguards for the transfer of personal information to recipients in countries for which the European Commission has not issued an adequacy decision.

Modern Health complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, Switzerland, and the United Kingdom to the United States. You can find our Privacy Shield Notice here.

How We Protect Information

Modern Health maintains technical, physical and organizational safeguards to ensure an appropriate level of security and confidentiality for your information, in accordance with our policies and applicable laws. However, no service or online platform is 100% secure. In addition, any unencrypted communications you send to us cannot be protected completely against unauthorized access, nor is Modern Health responsible for unauthorized access to your information when sent to your personal email address. You are responsible for maintaining the security of your devices and online accounts, including by not sharing your password or credentials for the Service with others.

Retention of Information

Information that we collect will be retained in a personally identifiable form for as long as necessary for the purposes described above, after which it will be deleted or maintained in a non-personally identifiable form. We may retain information in order to comply with our legal obligations (such as tax, accounting or health privacy purposes).

Control Over Your Information

How to control your communications preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. You may also have the right to access, modify or delete your information, or revoking your consent to our collection, use, and sharing of your information.

Information of Minors

The Service is not intended to be accessed by minors under the age of eighteen (18) except as authorized by their parents or legal guardian, and we do not knowingly collect any personal information directly from such minors and children without such authorization. If we discover that an individual under 18 has provided us with personal information, we will delete the personal information to the extent required by the Children’s Online Privacy Protection Act or other applicable law.

Users in the European Economic Area

Under the European Union General Data Protection Regulation and/or the United Kingdom Data Protection Act 2018, we are required to provide you certain additional information about our “processing” of “personal data,” as those terms are defined under applicable laws. Modern Life Inc. is considered the “data controller” of the personal data collected from you in accordance with this Privacy Notice, which means that we are responsible for how we collect, use, and disclose information collected by and through the Service.

Notice for California Consumers

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

Notice for Users in South Korea

We may transfer the information that we collect about you to recipients located overseas. Those countries may not have the same data protection laws as the country in which you initially provided the information.

Updates To Our Privacy Notice

This Privacy Notice may be updated periodically to reflect changes in our information practices.

How to Contact Us

If you have questions about how Modern Health handles your information or would like to exercise your rights, please reach out by emailing or writing to us at:

Modern Life Inc. (Legal Department) 450 Sansome Street, Fl. 12, San Francisco, CA 94111 Email: legal@modernhealth.com