Privacy Policy – IMA

Privacy Policy

Last Revised: May 2, 2022

Recode Health, LLC (“Recode Health”, “us”, and “we”) is committed to protecting your privacy. We operate the Your Benefits App powered by Strive website at onestrive.com (“Strive Site. Collectively, the foregoing websites and any other websites and services owned or controlled by Recode Health that link to this Agreement are referred to as the “Site.” We also provide certain mobile application(s) associated with the Site (“Mobile App”). Together, the Site and the Mobile App are referred to in this Agreement as the “Services.” We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our Services.

1. User Consent. By submitting Personal Data through our Services or by agreeing to our Terms of Use, you expressly consent to the collection, use, and disclosure of your Personal Data in accordance with this Privacy Policy.
2. A Note About Children. We do not intentionally gather Personal Data from visitors who are under the age of 13. If you are under age 13, please do not attempt to create a user account or provide any personal information about yourself to us. If you are between the ages of 13 and 18, your parent or legal guardian may access the Services on your behalf.
3. Types of Data We Collect. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, directly or indirectly, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
   • Information You Provide to Us.

• When you create a user account (“Account”) to access certain features of the Services, we may collect Personal Data from you, such as your username, email and password. In some cases we may ask for additional information for security reasons or to provide specific services to you. We may ask that you create an Account for each applicable Site or App.
• When you download our Mobile App and enable certain features, we or our third party service providers will collect and store your geographic location and other GPS information if your device transmits it.
• If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
• When you participate in one of our surveys, we may collect additional profile information.
• We may also collect Personal Data, such as at other points in our Services that state that Personal Data is being collected.

• Information Collected via Technology.

• To make our Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you when you use our Services, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
• We may use web beacons, cookies, and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. This information is used for many purposes, including, for example, to provide useful features to simplify your experience when you return to our Services; deliver relevant content based on your preferences, usage patterns, and location; monitor and evaluate the use and operation of our Services; and analyze traffic on our Services and on the sites of third parties. “Web beacons” are small pieces of data that are embedded in images on the pages of the Site. Web beacons may involve the transmission of information directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. “Cookies” are small pieces of information that a website sends to your computer, mobile phone, or other device while you are viewing a web site. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. Persistent cookies can be removed by following Internet browser help file directions. If you choose to disable cookies, some areas or features of our Service may not work properly.
• We may use third party services for delivering advertisements on the Services such as NetShelter and Google Adsense. Such third party services may use cookies, web beacons, Flash cookies, and other technologies to collect information on how you use and interact with our Services, such as the pages you visited, your IP address, a date/time stamp for your visit, and which site referred you to our Site. Flash cookies are different from browser cookies because of the amount of, type of, and way that data is stored. Cookie management tools provided by your browser will not remove Flash cookies. You can learn about Flash Cookies and how to disable them by clicking here.  If you disable Flash cookies, you may not have access to certain features that make your experience more efficient and some of our services may not function properly. You may choose not to receive targeted advertising from many ad networks, data exchanges, marketing analytics and other service providers by clicking here. We adhere to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising.
• If you use our Mobile App, we may collect information about the device on which the Mobile App is installed, including for example information such as an equipment identifier (e.g., IMEI or UDID), subscriber identifier, mobile phone number, device name, type and manufacturer, operating system type and version, wireless carrier, network type, country of origin, and IP address. We may also collect location data directly from the GPS on your device if it is required to provide the needed functionality of the product or service, and use third-party service providers to translate that information into usable location information (where we are permitted by law to process this information).

4. Use of Your Personal Data
   • General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:

• to facilitate the creation of and secure your Account on our network;
• to identify you as a user in our system;
• to optimize or improve our Services and products;
• to provide the Services and products you request;
• to improve the quality of experience when you interact with our Services;
• to send you a welcome email to verify ownership of the email address provided when your Account was created;
• to send you administrative email notifications, such as security or support and maintenance advisories;
• to respond to your inquiries related to employment opportunities or other requests;
• to detect, investigate, and prevent activities that may violate our policies or be illegal
• to make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback;
• to provide you with advertising based on your activity on our Services and on third party sites and applications (if permitted by local law and choices and controls that may be available to you);
• to send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Recode Health.

• Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. Recode Health reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in its sole discretion.

5. Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.
   • Emergency Responders. If you have authorized us to share your Emergency Contact information in a medical emergency and a medical emergency occurs, then we may share your Emergency Contact information with responders in order for them to secure and provide emergency medical care.
   • Third Party Service Providers. We may share your Personal Data with third party service providers, for purposes such as providing services you have requested or payment processing services for the Services. These third party service providers are required not to use your Personal Data other than to provide the services requested by Recode Health.
   • Affiliates and Acquisitions. We may share some or all of your Personal Data with our subsidiaries, joint ventures, or other companies under common control with us (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy. If another company acquires our company, business, or our assets, including through bankruptcy, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
   • Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Recode Health may disclose Personal Data if it believes in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on Recode Health; (iii) to protect or defend the rights or property of Recode Health or users of the Services; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or the Terms of Use for our Services.
6. Third Party Websites. When you click on a link to any other website or location, you will leave our Site or Mobile App and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.
7. Your Choices Regarding Your Personal Data
   • We offer you choices regarding the collection, use, and sharing of your Personal Data.
     • We will periodically send you free communications such as emails that directly promote the use of our Services. When you receive communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly (please see contact information below). As we add features and functionality to the Recode Health Services that require the collection, use or disclosure of data other than as set forth in this Privacy Policy, we will offer you the option to opt in or out of those services.
     • Despite your indicated email preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.
   • Changes to Personal Data. You may change any of your Personal Data in your Account by editing your profile within your Account. You may request deletion of your Personal Data by us, but please note that we may be required to keep this information and not delete it. When we delete any information, it will be deleted from the active database, but may remain in our archives. We may retain your information for fraud prevention or similar purposes.
8. Security of Your Personal Data. Recode Health is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Recode Health uses reasonable efforts to protect your Personal Data, Recode Health cannot guarantee its absolute security.
9. Health Connect Data
   • Collection and Usage of Health Data: We value the privacy and security of our users. Our mobile application requests access to health-related permissions, specifically the ability to read steps and distance information. This data is collected for the sole purpose of enhancing the user experience and providing features related to health and fitness.
   • Purpose of Health Data Access: Our app utilizes health-related permissions to track daily steps, and distance. This data is processed locally on the user’s device and is not shared with any third parties.
   • User Consent: By using our app, you explicitly consent to the collection and usage of health-related data for the purposes outlined in this privacy policy. You have the option to grant or deny these permissions within the app settings.
   • Security Measures: We implement robust security measures to protect the confidentiality and integrity of health-related data. This includes encryption and secure storage.
   • Data Retention: We retain health-related data only for as long as necessary to fulfill the purposes outlined in this privacy policy. Users can request the deletion of their data by clicking on Delete Account button from the application.
   • Third-Party Services: Our app does not share health-related data with any third-party services, advertisers, or external entities. We do not engage in the sale or exchange of user data.
10. Contact Information. Recode Health welcomes your comments or questions regarding this Privacy Policy. Please email us at clientsuccess@strivebenefits.com or contact us at the following address or phone number:

Recode Health, LLC

Recode Health, LLC

2000 S Colorado Blvd

BLDG 1 – 2000 – #82

Denver, CO 80222

UNITED STATES

10. Changes to This Privacy Policy. This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an email to the last email address you provided to us and/or by prominently posting notice of the changes on our Site. Any changes to this Privacy Policy will be effective upon the earlier of 30 calendar days following our email notice to you or 30 calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Service. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current email address. In the event that the last email address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the email containing the notice will nonetheless constitute effective notice of the changes described in the notice. In any event, changes to this Privacy Policy may affect our use of Personal Data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us. Continued use of our Services, following notice of changes will indicate your acknowledgement of the changes and agreement to be bound by the terms and conditions of the changes.
11. Additional Policies. Certain services provided by or through Recode Health may be subject to additional privacy policies or privacy disclosures (collectively “Additional Policies”). In the event of any direct conflict between any Additional Policies and this policy, the Additional Policies will control.