Privacy Policy

Your Information. Your Rights. Our Responsibilities.

Last Revised: December 19, 2022

Wild Health values your trust, and protecting your information is a high priority. Wild Health is committed to
your privacy. This Privacy Policy explains what information Wild Health and its affiliates (collectively, “Wild
Health” or “we”) collect, how information that identifies or may reasonably identify you (“Personal
Information”) is collected, how we use that Personal Information, what Personal Information is shared with
whom, and how Wild Health protects your Personal Information when you use our non-clinical products and
services, including our website and certain uses of the Clarity platform, independent of receiving clinical
healthcare services (collectively, the “Services”).

When This Privacy Policy Applies

This Privacy Policy applies to our services, websites and mobile applications that are separate or independent of
any healthcare clinical services our partners provide to you, including through your purchase of Wild Health
Precision Care. For clarity, this Privacy Policy will apply to your purchase of the Wild Health Precision Medicine
Training Program and your general use of our website.

This Privacy Policy does not apply to: (1) our collection, use, or disclosure of HIPAA protected health information
from the Wild Health Precision Care service or any other healthcare clinical service, (2) other services that have
separate privacy policies that do not incorporate this Privacy Policy, and (3) to services offered by other companies
or individuals, including products or sites that may be displayed to you in search results, sites that may include
Services, or other sites linked from our Services.

Additionally, our Services is only intended for use within the United States. This includes your enrollment in the
Precision Medicine Training Program. Our Privacy Policy also does not cover the information practices of other
companies and organizations who advertise our Services, and who may use cookies, pixel tags and other
technologies to serve and offer relevant ads.

Once you register to receive clinical healthcare services with us, any individually-identifiable health information
will be governed by the healthcare providers’ Notice of Privacy Practices for protected health information or “PHI.”
If you are registered to receive such services, including through Wild Health Precision Care, you acknowledge that
you have read and understood the Notice of Privacy Practices.

By using our Services, you affirm that you have read this Privacy Policy and our Website Terms of Use and that you
understand, agree to be bound by, and acknowledge all the terms contained herein. If you do not agree to be
bound by the terms of this Privacy Policy, our Website Terms of Use, our affiliated providers’ Notice of Privacy
Practices, and the applicable Terms of Service, you should discontinue your use of the Services.

Protected Health Information (PHI) Under HIPAA

This Privacy Policy does not apply to our collection and use of your PHI.

For your information only, as part of providing certain healthcare services, we may collect certain PHI from
patients, which is governed by the Health Insurance Portability and Accountability Act or “HIPAA”. Specifically, we
may act as a business associate (as defined by HIPAA) when we (1) provide certain management services to a
healthcare provider, and the healthcare provider is a covered entity as defined by HIPAA, and (2) receive PHI about
a patient on behalf of a healthcare provider. The collection, use, and disclosure of such PHI is done in accordance
with the healthcare provider’s Notice of Privacy Practices. A copy of such notices for the healthcare providers that
we manage is available here.

However, this Privacy Policy applies to only certain Personal Information that we collect about you as a user when
we are not acting as a business associate under HIPAA. As described in more detail below, this might include
Personal Information such as your device ID or IP address, collected as a result of your use of the Services.

CHILDREN

Our Services are not directed at children, and we do not knowingly collect or solicit Personal Information online
from children under the age of 18 or knowingly allow such persons to use our Platform. If you are aware that a
child has provided us with Personal Information online, please contact us using the contact information below.

TYPES OF PERSONAL INFORMATION WE COLLECT FROM USERS

We collect the following Personal Information about you:

  • Information You Submit. When you fill out our online contact form to schedule a call about our Services,
    you provide to us your name and email address. You may also sign up to our email alerts by providing
    your email address. We also collect the visible Personal Information about you when you interact with
    our social media pages or participate in our promotion campaigns. If you have signed up for the Precision
    Medicine Training Program we may collect information you submit about yourself, including your
    enrollment information.
  • Information from Third Parties. We may receive personal information, including contact information,
    about you from third party partners such as fitness facilities or your employer, if you’ve signed up through
    your employer.
  • Geolocation. We automatically collect your geolocation when you use the Services. This is information
    that identifies your specific location.
  • Technological Information. We automatically collect your IP address, unique online identifier, device ID
    and/or hardware model, mobile operating system, and Wi-Fi or mobile network. We use this for a number
    of reasons, including tracking how you engage with our Services, including the Precision Medicine Training
    Program, and monitoring user traffic on our Services to ensure the security and integrity of our systems.
  • Internet Activity.  This includes browsing history, search history, and information regarding your
    interactions with other applications, advertisements, or websites (including the websites you came from
    before you visited our website and the website you visit when you leave our website). This information is
    collected via cookies and pixels. We use this information to serve you with tailored advertising content.
    For more information about our advertising practices, which includes targeted advertising, please see the
    sections below.

HOW WE USE YOUR INFORMATION

We use your Personal Information that we collect through the Services, including from the Precision Medicine
Program, in the following circumstances:

  • To Operate and Maintain the Services. This includes fulfilling your requests. For the Precision Medicine
    Training Program, this includes providing feedback and instruction.
  • To Communicate With You. We may communicate with you about your account or our relationship. We
    may also contact you about this Privacy Policy. This also includes responding to your feedback, requests
    for quotes, or requests for more information. For the Precision Medicine Training Program, this includes
    our general interaction with you on the program and your progress.
  • To Improve Our Services. We may use your Personal Information to make our Services better. We may
    also use your Personal Information to customize your experience with us.
  • To Understand Your Interests. For example, we may use your Personal Information to better understand
    what features in our Services interest you.
  • For Online Marketing Purposes, including Targeted Advertising. We might use your Personal Information
    to serve you ads, emails, or other content about our products and Services, including new features or
    Services that we develop in the future. These might be third party offers for tools, products, or services
    that we think you might find interesting. We and our partners may engage in interest-based advertising,
    or targeted advertising, using data and Personal Information gathered across multiple websites, devices,
    or other platforms. These practices may be considered a “sale” of Personal Information under some state
    laws. For more information about your choices related to these communications, see Choices Regarding
    Your Information below.
  • To Send Promotional Communications to You. This includes surveys, promotions, and marketing emails.
  • For Security Purposes. This includes protecting us and the consumers who use our Services. It may also
    include protecting our Services, including this website and the Precision Medicine Training Program
  • As Otherwise Permitted By Law or As We May Notify You.

HOW WE SHARE YOUR INFORMATION

We may share your Personal Information in the following ways:

  • On our Website, Platform or Social Media Pages. For example, we may display or repost Personal
    Information that you post in our social media forums.
  • With Our Service Providers. We may share your Personal Information with third parties who perform
    services on our behalf. For example, this may include payment processors and companies that send
    emails on our behalf or other operating systems or platforms that help us run our Services. For the
    Precision Medicine Training Program, this would include the platform you use to interact with us.
  • With Data Analytics Providers for Targeted Advertising. Third-party data analytics providers may collect
    Personal Information about users over time and across different websites, applications, and devices for
    the purposes of targeted advertising. Third-party data analytics providers may also collect Personal
    Information in this way on our website. These practices may be considered a “sale” of Personal
    Information under some state laws. For more information about your choices related to these
    communications, see Choices Regarding Your Information.
  • With Our Business Partners. For example, this may include a company that co-sponsors a promotion. For
    the Precision Medicine Training Program, this may include our accreditation agency.
  • With Any Successors to All or Part of Our Business or One of Our Brands. For example, if we assess or
    actually merge with, acquire or are acquired by, or sell a brand or part of its business to another business
    entity. This may include an asset sale, corporate reorganization, or other change of control, potentially
    involving the bankruptcy process. We may transfer our customer information, which may include your
    Personal Information, as part of such a transaction or as a stand-alone asset. You hereby consent to such
    transfers and we may assign and transfer all of the rights, benefits, duties, and obligations of this Privacy
    Policy, under the circumstances described in this paragraph.
  • To Comply with the Law or To Protect Ourselves. For example, this could include responding to a court
    order or subpoena. It could also include sharing Personal Information if requested by a government
    agency or investigatory body. We might share Personal Information within the context of protecting or
    assessing our own legal rights, such as with third-party accountants or outside legal counsel. We might
    share Personal Information in order to protect the rights, privacy, safety, or property of ourselves, our
    employees and personnel associated with us, our business partners, or you.

CHOICES REGARDING YOUR INFORMATION

You have certain choices about how we use your Personal Information. Certain choices you make are specific to
your browser and/or device.

Marketing Communications:

You can opt-out of receiving our marketing communications. Note that you will still receive transactional messages
from us, including information about your account and responses to your inquiries. To opt-out of receiving our
marketing communications, you can follow the instructions included with the communication.

Cookies & Other Tracking Technologies:

Cookies are small text files that websites place on your device as you are browsing, which are stored by your web
browser. By storing data, cookies serve crucial functions for websites. If you prefer not to share data, you can
disable them. If, however, you do not accept cookies, you may experience some inconvenience in your use of the
Services.

Your browser may give you the ability to control cookies or other tracking tools. How you do so depends on the
type of tool. If you do not want information, which may include Personal Information, collected through the use of
cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given
the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a
website. To learn more about cookies and how to manage them, you may find the following link
helpful: aboutcookies.org/how-to-control-cookies.

RIGHTS REGARDING PERSONAL INFORMATION

You may have the following rights (“Data Subject Rights”) in relation to the Personal Information that we collect or
process about you, including as it relates to your enrollment in the Precision Medicine Training Program. These
rights differ depending on where you live, but we will endeavor to respect these rights regardless of your country
or state of residence. Please note that we reserve the right to honor your Data Subject Rights as required by
applicable law.

  • Right to Access and Obtain a Copy: If you ask us, we may confirm whether we are processing your
    Personal Information and, if so, provide you with a copy of all Personal Information you are lawfully
    entitled to receive along with certain other details. In addition, you may request to know the types of
    third parties with whom we share your Personal Information, and the categories of Personal Information
    we share with them.
  • Right to Amend: If you believe your Personal Information is inaccurate or incomplete, you may request
    that we correct or complete it. If you ask us, and where possible and lawful to do so, we may tell you with
    whom we shared your Personal Information so you can contact them directly.
  • Right to Delete: You may request that we delete or remove your Personal Information. If we shared your
    Personal Information with others, we will tell them about the erasure as required by law.
  • Right to Restrict Processing: You may ask us to restrict or “block” the processing of your Personal
    Information in certain circumstances, such if we process Personal Information that is considered
    “sensitive” under applicable state laws or engage in automated decision-making.
  • Right to Opt Out of Targeted Advertising: Targeted advertising is the practice of serving you tailored
    advertisements based your Personal Information gathered across other businesses, websites,
    applications, or services. You may request that we opt out of this practice.
  • Right to Non-discrimination: We will not discriminate against you for exercising these rights, but we may
    charge a reasonable fee as permitted by law in fulfilling these rights, such as if you request multiple copies
    of your Personal Information.

If you or your authorized agent wish to exercise any of these Data Subject Rights, including for your enrollment in
the Precision Medicine Training Program, please contact us using the information provided in How To Contact Us.
Before responding to your request to exercise Data Subject Rights, we may require additional information
(potentially including Personal Information) from you to verify your identity or clarify your specific request. We will
try to comply with your request as soon as reasonably practicable and in compliance with applicable law. Where
appropriate, we will work with third parties in order to fulfill your request.

SECURITY AND RETENTION

We have enabled reasonable administrative, physical, and technical safeguards for the protection of the Personal
Information in our custody or control. Unfortunately, no data transmission or storage system is guaranteed to be
100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you
feel that the security of your account has been compromised), please immediately notify us in accordance with
How To Contact Us.

As our operations are conducted from the United States, all Personal Information that we collect is used and
stored in the US, is subject to US laws, and may be subject to disclosure to US governments, courts, law
enforcement, or regulatory agencies pursuant to those laws. If you are using our Services, including accessing this
website, from or in another country, please note that your Personal Information will be transmitted to our servers
in the US as necessary to provide you with the information that you requested, administer our Services to you, or
as otherwise disclosed in this Privacy Policy.

LINKS

This Privacy Policy does not address, and we are not responsible for, the privacy or other information practices of
any third parties, including any third party operating any site or service to which the Service links. The inclusion of
a link on the Service does not imply endorsement of the linked site or service by us. In addition, we are not
responsible for the information collection, use, disclosure, or security policies or practices of other organizations or
any other app developer, app provider, social media platform provider, operating system provider, wireless service
provider or device manufacturer, including with respect to any Personal Information you disclose to other
organizations through or in connection with the Services.

HOW TO CONTACT US

If you have any questions, comments, or concerns with respect to our privacy practices or this Policy, wish to
update your information, or would like to exercise your Data Subject Rights, please feel free to contact us at
[email protected] 

You may also write to us at the following address:

Wild Health, Inc.
535 Wellington Way, Suite 330
Lexington, KY 40503

with a copy to [email protected]

If you disagree with our determination regarding your Data Subject Rights, you may appeal the decision by
contacting us at [email protected]. Please include confirmation of your original decision in the email.

CHANGES IN POLICY

From time to time, we may change our Privacy Policy and your continued use of the Services indicates your
consent to the changes. In any case we will endeavor to notify you of any material changes to our Privacy Policy, as
required by law. This Privacy Policy is current as of the “last revised” date which appears at the top of this page.