EvolveWell California Consumer Privacy Act Notice

Effective Date: 09/01/2024

EvolveWell respects your privacy and is committed to complying with the California Consumer Privacy Act (CCPA) regulations. While EvolveWell does not traditionally sell personal information in the conventional sense, certain uses of cookies and similar technologies for advertising purposes might be interpreted as a "sale" under the CCPA.

Categories of Personal Information Collected

We may collect the following categories of personal information:

• Identifiers: This includes your full name, email address, postal address, phone number, and other identifiers that you provide when registering, contacting us, or using our website.

• Internet Activity: We collect data about your interaction with our website, such as browsing history, pages visited, links clicked, and time spent on each page. We also collect your IP address, browser type, and operating system to improve website performance and diagnose issues.

• Geolocation Data: With your consent, we may collect data about your physical location derived from GPS or similar technologies to offer location-based services.

• Communication Information: When you communicate with us via email or contact forms on our website, we collect the information you provide to respond to inquiries and provide customer support.

• Cookies and Tracking Technologies: We use cookies, beacons, and other tracking technologies to collect information about your interactions with our website and third-party websites, including your browsing behavior, preferences, and engagement with advertisements.

Sources of Personal Information

We obtain personal information directly from you, through your device, and from third-party services that interact with us in connection with the services we provide.

Purposes for Collecting Personal Information

We use your personal information for several purposes:

• To provide Website functionalities and services

• To improve and personalize your user experience

• For security purposes, to protect our site against fraud and abuse

• For compliance with legal obligations

Sale and Sharing of Personal Information

At EvolveWell, we take your privacy seriously and adhere to strict guidelines when it comes to the sharing or sale of personal information as defined by the California Consumer Privacy Act (CCPA). Below, you can find details on the categories of personal information we may share or sell and the categories of third-party recipients involved in such transactions:

Category of Personal Information Sold or Shared

Category of Third-Party Recipient

Identifiers (such as full name, email address, postal address, and phone number)

Advertising networks, marketing partners, and analytics providers

Internet Activity (including browsing history, pages visited, links clicked, and interaction data)

Data analytics providers, digital advertising companies

Geolocation Data

Location-based service providers, marketing partners

Communication Information (information from emails or contact forms)

Customer service support providers, communication platform providers

Cookies and Tracking Technologies (data collected via cookies, beacons, and other tracking technologies)

Advertisers, advertising networks, and social media networks

Purpose for Sharing or Selling Personal Information

We share or sell this information to enhance the effectiveness of our advertising campaigns, to improve the functionality of our website, and to provide a personalized experience to our users. This helps us to better understand user preferences and to optimize our services accordingly.

Sale or Share of Personal Information of Consumers under 18 Years of Age

EvolveWell does not knowingly sell or share the personal information of consumers under the age of 18. We are committed to protecting the privacy of minors, and any engagement involving minors with our services adheres strictly to this policy. Parents and legal guardians are encouraged to monitor their children's Internet usage and to help enforce our policy by instructing their children never to provide personal information on our website without their permission.

If we learn that we have collected personal information from a minor under 18 without verification of parental consent, we will take steps to remove that information from our servers as quickly as possible.

Disclosing Personal Information for Business Purposes

During the 12-month period prior to the Last Updated date of this notice, EvolveWell may have disclosed certain personal information to third parties for business purposes. The categories of personal information disclosed are aligned with the categories outlined in our table of personal information shared or sold, and include identifiers, internet activity, geolocation data, communication information, and data collected through cookies and tracking technologies.

Here are the categories of third parties to whom we have disclosed personal information for business purposes:

• Service Providers: Entities that provide services on our behalf, including customer service, marketing, IT support, hosting, and other services.

• Business Partners: Companies with whom we partner to offer joint promotional activities or co-branded services.

• Legal and Regulatory Authorities: When required by law or as necessary to protect our rights, we may disclose information to government authorities or others in response to legal process.

The purpose of these disclosures is to perform the services you have requested, comply with our legal obligations, resolve disputes, and enforce our agreements.

By maintaining transparency about our practices regarding the disclosure of personal information for business purposes, EvolveWell ensures compliance with applicable laws and regulations while continuing to prioritize and protect your privacy rights.

How Long Do We Retain Your Personal Information?

EvolveWell retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. The specific retention period depends on the nature of the information and the reasons for which it is processed. The criteria we use to determine retention periods include:

• The duration of our business relationship with you, including any requests you make for our services or any warranty and support related to purchases.

• Legal compliance obligations, such as mandatory retention periods for tax, corporate, and data protection laws.

• Security and fraud prevention needs, where information needs to be retained to protect your interests or those of another natural person from security threats or fraud.

• Statute of limitations under applicable law(s), which define the period during which parties can take legal action related to a contract.

Once the retention period expires, personal information is securely deleted or anonymized, so it can no longer be associated with an individual. If deletion or anonymization is not possible (for example, because personal information has been stored in backup archives), then the information is securely stored and isolated from further processing until deletion can be achieved.

What Are Your California Privacy Rights?

As a California resident, the California Consumer Privacy Act (CCPA) provides you with rights regarding the personal information that businesses hold about you. These rights include:

• Right to Know and Access: You can request information about how we have collected, used, and shared your personal information during the past 12 months. You can also request a copy of the personal information we have collected about you.

• Right to Delete: You can ask us to delete the personal information we have collected from you, with certain exceptions.

• Right to Non-Discrimination: You are entitled to exercise your CCPA rights without being subject to discrimination.

• Right to Opt-Out of Sale: You have the right to opt-out of the sale of your personal information. At EvolveWell, we do not sell personal information as traditionally understood, but for CCPA purposes, some data sharing activities might be considered a sale.

• Right to Limit Use and Disclosure of Sensitive Personal Information: In certain situations, you can request that we limit the use and disclosure of your sensitive personal information.

To exercise any of these rights, you may contact us at privacy@evolvewell.com, or via our postal address provided earlier in this notice. Additionally, you can directly manage your preferences through the "Cookie Preference Center" found at the footer of our website.

For requests to delete personal information or cease the sale of personal information, we will confirm your identity to ensure the security of your data. Once verified, we will comply with your request in accordance with applicable law.

If you are using an authorized agent to exercise your rights, we require that you provide the agent with written authorization to do so and that the agent verifies their identity directly with us.

EvolveWell is committed to respecting your privacy rights and will ensure that all personal information is handled in compliance with applicable privacy legislation.

Request to Access My Personal Information

As a California resident, you have the right under the California Consumer Privacy Act (CCPA) to request access to the personal information that EvolveWell collects about you. This includes the right to request the specific pieces of personal information we have collected over the past 12 months, the categories of sources from which the personal information was collected, the business or commercial purpose for collecting or selling the personal information, and the categories of third parties with whom we share personal information.

To make an access request, you may contact us via email at privacy@evolvewell.com or send a letter to our postal address provided in our contact section. When making your request, please provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. We may also ask you to provide additional details to verify your identity before processing the request.

Upon verifying the authenticity of the request, EvolveWell will respond within 45 days. If we need more time (up to 90 days), we will inform you of the reason and extension period in writing.

Delete My Personal Information

You also have the right to request the deletion of your personal information that we have collected from you. EvolveWell respects your right to privacy and provides you the option to have your personal information deleted from our records and direct any service providers to delete your information from their records as well.

To request the deletion of your personal information, please submit a request via our designated methods: either email us at privacy@evolvewell.com or use the contact details provided in our contact section. Please specify that your request pertains to the deletion of your personal information. As with access requests, we will need to verify your identity to process the deletion request securely.

Once your identity has been verified and your request processed, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. For example, we may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

• Comply with a legal obligation.

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

EvolveWell will inform you if any exceptions apply to your deletion request within the period stipulated by law.

Stop Selling or Sharing My Personal Information

Under the California Consumer Privacy Act (CCPA), California residents have the right to opt-out of the sale or sharing of their personal information by EvolveWell. Although EvolveWell does not engage in the traditional selling of personal information, certain types of sharing with third-party advertising partners might be categorized as "selling" under the CCPA.

To access the opt-out:

• Navigate to the "Cookie Preference Center" at the footer of our website or within the settings of our app.

• Follow the links: "Do Not Sell or Share My Personal Information” and “Targeted Advertising Opt Out" form.

Upon submission, we will process your request promptly and confirm once your personal information has been excluded from any sales or sharing activities related to advertising.

Correct My Personal Information

As a California resident, you have the right to request corrections to any inaccurate personal information that EvolveWell holds about you. Accurate information is essential for us to provide you with relevant and timely services.

To request a correction of your personal information:

• Email us at privacy@evolvewell.com with the subject line "Correct My Personal Information."

• Clearly describe the specific information that is incorrect and provide the corrected data.

• Include enough identifying details to allow us to verify your identity and locate your information in our systems.

Upon receiving your correction request, we will verify your identity, assess the accuracy of the new information provided, and implement the necessary corrections to your personal data in our records. We will also communicate any corrections to third parties or service providers who have received your personal data, as required by law.

We will notify you once the corrections have been made. If we are unable to process your request due to issues such as inability to verify identity or data unavailability, we will inform you promptly.

If you have questions about how to exercise your rights or need assistance with the process, please contact us at the provided email address. EvolveWell is committed to honoring your rights under the CCPA and ensuring your personal information is managed responsibly.

How to Appeal a Decision

If EvolveWell is unable to comply with your request to exercise any of your data access rights, you have the right to appeal our decision. To initiate an appeal, please send an email to privacy@evolvewell.com with the subject line “Data Access Request Appeal.”

Limit the Use and Disclosure of Sensitive Personal Information (SPI)

EvolveWell recognizes the importance of protecting Sensitive Personal Information (SPI) under the California Consumer Privacy Act (CCPA). As part of our commitment to safeguard your privacy, you have the right to request that we limit the use and disclosure of your SPI to certain necessary functions.

To request that EvolveWell limit the use and disclosure of your SPI:

• You can also contact us directly via email at privacy@evolvewell.com with the subject line "Limit Use of SPI."

We will review your request and respond within the timeframe mandated by the CCPA, ensuring that your SPI is used only for the explicitly allowed purposes under the law.

How Do We Verify Your Identity to Complete Your Access, Correction, and Deletion Requests

At EvolveWell, the security and confidentiality of your information are paramount. To ensure that personal information is not disclosed to unauthorized individuals, we employ a rigorous identity verification process for all requests related to accessing, correcting, or deleting personal information.

Here’s how we verify your identity:

1. Online Requests: When you make a request online via email, you will be required to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. This may include requesting specific details about previous interactions with us.

2. Offline Requests: If you make your request via mail or over the phone, you may need to provide us with government-issued identification, or answer verification questions based on the information we already have about you.

3. Third-Party Identity Verification Services: We may use trusted third-party services to assist in verifying your identity. This step is taken to further ensure the security of your personal information.

4. Authorized Agents: If you are using an authorized agent to exercise your rights on your behalf, we will require that the agent provide proof of your written permission for them to act on your behalf, and we may also require you to verify your own identity directly with us.

We aim to complete the verification process promptly to ensure that your requests are handled efficiently and securely. Once your identity has been verified, we will proceed with processing your request and will inform you of any actions taken or if additional information is needed to proceed.

What If You Can’t Verify My Identity?

If EvolveWell is unable to verify your identity or authority to make the request, we will not be able to process your request to access, correct, or delete your personal information. We take this precaution to protect your information and ensure it does not fall into the wrong hands. If we cannot verify your identity, we will notify you promptly.

We are committed to assisting you in safeguarding your privacy and will guide you through the necessary steps to verify your identity effectively.

How Do I Submit a Request Using an Authorized Agent?

California residents may use an authorized agent to submit requests on their behalf to access, correct, or delete personal information or to opt-out of the sale or sharing of personal information. To use an authorized agent:

1. Provide your authorized agent with signed permission to act on your behalf.

2. Your agent must submit proof of this authorization when making a request. This can include a power of attorney or a signed authorization form.

3. Both you and your agent may also be required to verify your identities separately to protect your security and privacy.

Authorized agents can submit requests by contacting us at privacy@evolvewell.com with the necessary documentation and a clear statement of the request being made on your behalf.

Shine the Light

Under California’s "Shine the Light" law, California residents may annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. To request this information, please send an email to privacy@evolvewell.com or write to us at the address provided, specifying that you seek your "California Customer Choice Privacy Notice." Please include your mailing address so we can provide you with our notice detailing the categories of personal information we shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year.

Notice of Financial Incentive

If EvolveWell offers a financial incentive, we will ensure you are fully informed about the details of the incentive, including its relation to your personal data, prior to your participation. This transparency allows you to make an informed decision regarding your involvement. Should you choose to engage with a financial incentive, you retain the right to withdraw at any time. If you decide to withdraw, we will guide you through the process, providing clear instructions on how to opt-out effectively.

Contact Us

For any questions or concerns regarding this notice or your privacy rights under the CCPA, please contact us at:

• Email: privacy@evolvewell.com