PRIVACY NOTICE

Updated: August 1, 2022

This Privacy Notice describes the information Wellness Coaches USA, LLC d/b/a Ramp Health ("Ramp Health", "we", "our", or "us") collects, how we use this information, with whom we share it, and the choices you have in connection with this. This Privacy Notice applies to Ramp Health-related websites and services accessible on or by a domain owned by Ramp Health (each, a "Site" and collectively the "Sites") and any other electronic or digital products made available by Ramp Health that link to this Notice (collectively, our "Services"). You can access our HIPAA Notice of Privacy Practices, related to the use and disclosure of protected health information here https://portal.ramphealth.com/en/hipaa.html. As used in this Privacy Notice, "personal information" includes "Personal Data" as such term is defined under the General Data Protection Regulation (Regulation (EU) 2016/679) ("GDPR").

HIPAA

For residents of the United States, if you interact with the Services as a recipient of Ramp Health health care services, Ramp Health may collect and store your Protected Health Information (“PHI”) (as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”)) as a Covered Entity under HIPAA in our capacity as health care provider. For information on how we collect, use, and share your PHI, please refer to Ramp Health's Notice of Privacy Practices. Alternatively, when we receive personal information about you from your health care provider (who is not an employee of Ramp Health) or create, receive, maintain, or transmit PHI on behalf of your health care provider, we are acting as a Business Associate (as defined by HIPAA) to your health care provider. Therefore, we must do so in compliance with HIPAA and our agreement with your health care provider. For information on how we handle your PHI on behalf of your third party health care provider, please refer to your health care provider's Notice of Privacy Practices.

OUR ROLE IN DATA PROCESSING

The entity responsible for the collection and use (processing) of your personal information is Ramp Health. You can contact Ramp Health by email at support@RampHealth.com, or mail at 725 Skippack Pike STE 300, Blue Bell, PA 19422. Ramp Health is a controller under the UK General Data Protection Regulation and/or EU General Data Protection Regulation (collectively, "GDPR" or "EU data protection law").

INFORMATION COLLECTION AND USE

Through your use of the Services, we will collect personal information, which is information that identifies you or relates to you as an identifiable individual. We collect personal information directly and automatically as outlined below.

A. Information Collected Directly From You

When you engage with certain Services, we will collect your personal information. Except as otherwise indicated, the personal information we collect is such that we need to carry out the requested action. If you do not provide us with your personal information, we would not be able to do so. We collect personal information when you:

1. Interact with the Website

2. Interact with the Web Portal or Mobile Application.

3. Generally interact with Ramp Health.

4. Participate in a Business to Business Relationship with Us.

Ramp Health may also use the personal information collected for the above purposes to comply with the law and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.

B. Information Collected From Third Party Sources

C. Information Collected Automatically

In addition to the personal information you provide, we also collect information automatically via cookies as you use the Services. This information includes the following internet and other electronic network activity information:

Particular cookies to note on the Services include:

For EU residents, the legal basis for the processing of your personal data is consent. To control the information collected about you using cookies and other technologies see our Cookie Notice https://portal.ramphealth.com/en/cookie.html. In general, to disable cookies and limit the collection and use of information through them, you can set your browser to refuse cookies or indicate when a cookie is being sent. When you opt-out an opt-out cookie will be placed on your device. The opt-out cookie is browser and device specific and will only last until cookies are cleared from your browser or device.

HOW WE SHARE YOUR PERSONAL INFORMATION

Ramp Health may share the personal information identified in this Privacy Notice in the following instances:

Ramp Health may also share anonymized and aggregated data ("De-Identified Information") in public reports about exercise and activity, or to Ramp Health Partners under agreement with us. Ramp Health may also disclose De-Identified Information for general research purposes and in research collaborations with third parties, such as universities, hospitals or other laboratories to determine the prevalence of particular conditions among users or to determine whether a user might be suitable for research or clinical trials. Ramp Health may also use De-Identified Information for commercial collaborations with private companies for purposes such as product design or enhancement of programs we provide.

Sharing in the Last Twelve (12) Months

For a Business Purpose. In the preceding twelve (12) months, Ramp Health has disclosed the following categories of personal information for a business purpose to the following categories of third parties:

For a Sale.

CALIFORNIA RESIDENTS

The California Consumer Privacy Act (CCPA) entitles California residents to certain rights. To the extent that the CCPA applies to our processing of your personal information, you would be entitled to the following rights:

To exercise your right to access or delete your personal information, you may submit a request via email at support@RampHealth.com or via telephone by calling 877-236-6828. To opt out of the sale of your personal information via cookies or for marketing purposes, please visit Do Not Sell My Personal Information https://RampHealth.com/do-not-sell/.

For requests submitted via email and telephone, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. The interactive webform contains the information that we need to verify your identity and review your request.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

RIGHTS OF INDIVIDUALS IN THE EUROPEAN UNION

Individuals in the European Union are entitled to certain rights under the General Data Protection Regulation (GDPR). If our processing of your personal information is subject to the GDPR, you may be entitled to the following rights:

To exercise these rights, please contact us at support@RampHealth.com.

NEVADA RESIDENTS

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales by contacting us at support@RampHealth.com. Please include "Opt-Out Request Under Nevada Law" in the subject line of your message.

YOUR INFORMATION CHOICES

RETENTION OF PERSONAL INFORMATION

The criteria used to determine our retention periods are: (i) the length of time we have an ongoing relationship with you; (ii) whether there is any legal obligation to which we are subject; and (iii) whether there is a need in order to perform a contract to which you are party. The personal data processed by Ramp Health will be retained for the period deemed strictly necessary to fulfil the purposes for which it was provided, including to allow you to utilize the Platform. However, Ramp Health may continue to store personal data for a longer period, as may be necessary to protect Ramp Health's interests related to potential liability related to our Services. Ramp Health will keep personal data for the purposes of marketing and profiling for ten (10) years from the provision of your personal data for marketing and profiling purposes unless you withdraw your consent. Once your consent is withdrawn, personal data may no longer be processed for marketing or profiling purposes but may still be retained for the purpose of handling any disputes and/or litigation. Information collected via cookies will be kept for periods as indicated in our Cookie Notice.

INTERNATIONAL TRANSFERS

We may transfer your personal information to recipients in countries outside of the European Economic Area that may have differing data protection laws. This includes countries which the EU Commission does not consider to have an adequate level of protection for personal data. If this occurs, we will ensure there is a legal ground for the transfer in accordance with applicable data protection legislation. You will also be informed about the legal ground, what safeguards were implemented, and where you can obtain a copy of information on these safeguards.

DO NOT TRACK

We do not support Do Not Track (DNT). Do Not Track is a preference you can set to inform websites and applications that you do not want to be tracked.

INFORMATION SECURITY

We implement and maintain reasonable security measures, such as access controls and encryption, to protect the personal information we collect and maintain. However, no security measure or modality of data transmission over the Internet is 100% secure and we are unable to guarantee the absolute security of the information we have collected from you.

AGE RESTRICTION

The Services are not intended for individuals under the age of sixteen (16). If we learn that we have collected or received personal information from a child under the age of sixteen (16), we will delete that information. If you believe we might have information from or about a child under the age of sixteen (16), please contact us at support@RampHealth.com.

CHANGES TO THIS PRIVACY NOTICE

We may change this Privacy Notice from time to time. We will post the changes to this page and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you with a prominent post on our Services and obtain your consent, if required.

CONTACT

Data Controller and Contact Information

The data controller of this Platform is Ramp Health. You can contact us at:

725 Skippack Pike STE 300
Blue Bell, PA 19422
Data Protection Officer

For questions about your PII, or to lodge a complaint, contact:

Tony Costanzo, Privacy Officer
Phone: 877-236-6828
E-mail: privacy@RampHealth.com

If you have any specific questions about this Privacy Statement, you can contact us via email or phone or by writing to us at the address below:

Ramp Health
725 Skippack Pike STE 300, Blue Bell, PA 19422
support@RampHealth.com
877-236-6828

This Privacy Notice was last updated on August 1st, 2022