Privacy Policy

Wellpointe Inc. Privacy Policy

LAST UPDATED: October 27, 2024

WELLPOINTE INC. VALUES YOUR PRIVACY

Wellpointe, Inc. and its subsidiaries and affiliates, which include: Xenhealth, Inc., Xencare, Inc., Xencare II, Inc., Xencare III, Inc., Cottages at The Colony, LLC, Colony Care of Sherman Oaks/Valley Glen, LLC, Irvine Cottages, LLC, Brightday, LLC and Doc2You, LLC (collectively, “Wellpointe,” “we,” “us,” or “our”) is committed to protecting your Personal Information (as defined below) and your right to privacy. This Privacy Policy ("Policy") describes our policies and practices with respect to our collection, use, disclosure, and protection of Personal Information. If you have any questions or concerns about our Policy or our practices with regards to your Personal Information, please submit a request via our Privacy Inquiry Webform.

Please carefully review the Policy before using Wellpointe's websites, communicating with us, and/or providing us with any Personal Information. From time to time, we may add to, delete, or otherwise revise the terms of this Policy. When such changes are made, we will post the updated Policy on our website, www.wellpointe.com. Any changes to the Policy are effective immediately upon posting of the Policy, and your use of Wellpointe's website constitutes your agreement with the terms of the Policy.

COLLECTION AND DISCLOSURE OF PERSONAL INFORMATION

Personal Information is that information which identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you, your household, or your communications device (computer, tablet, mobile phone, etc.).

Wellpointe does not sell your Personal Information. Wellpointe is committed to collecting Personal Information responsibly and safeguarding it according to commercially reasonable security standards.

We collect Personal Information about you when you directly provide it to us, including in responses to questionnaires or downloaded forms regarding the type of care and services which may be of interest to you, and from a variety of other sources, including but not limited to:

• Wellpointe's subsidiaries and affiliates; and
• From your browser or device, such as from information generated from your online browsing and activities.

For example, we may collect Personal Information from the following sources:

• From users of our websites and mobile sites;
• When you communicate with us regarding residing at a Wellpointe facility; and
• From Wellpointe's subsidiaries and affiliates when you inquire about a Wellpointe-affiliated facility.

Below we provide the categories, descriptions, and examples of the types of Personal Information we may have collected or may collect about you:

Category

Description and/or Example

Identifiers

Your name, alias, phone number, postal address, Internet Protocol (IP) address, email address, or other similar identifiers.

Protected Classification Characteristics

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Internet/Network Activity

Browsing history, search history, information on your interaction with our websites or an advertisement, your use of mobile applications, your internet connection, the equipment you use to access our Website, as well as usage details, such as your Internet Protocol (IP) address, computer operating system and browser type, type of mobile device, the unique device identifier, the address of a referring website (if any), cookies and other tracking technologies, and the pages you visit on our website. This may include hardware and browser information about your computer or device. It also may include mobile application usage data, such as the date and time mobile applications on your device access our servers, and what information and files have been downloaded or uploaded to the application.

Inferences drawn from other Personal Information

A summary we might make based on your apparent interests, personal preferences, characteristics, behavior, attitudes, and abilities. We might, for example, infer your race, ethnicity, or gender based on your name.

We retain Personal Information from the above categories for as long as necessary to achieve the purpose for which it was collected, to fulfill legal or contractual obligations, or for as long as permitted by applicable law. We may retain aggregated or deidentified information indefinitely.

HOW WE USE YOUR PERSONAL INFORMATION

We use Personal Information to understand your needs and to provide you with better services. By submitting Personal Information to Wellpointe, or providing it directly or indirectly to Wellpointe for the purposes of using Wellpointe's services or inquiring about residing at Wellpointe's facilities, you consent to Wellpointe's collection and use of your Personal Information for a variety of purposes permitted by law, including:

• To fulfill or meet the reason you provided the information, including providing you with information about services or facilities that may be of interest to you;
• To respond to inquiries made by you relating to our business, including finding Wellpointe facilities near you;
• To communicate with you, including through email;
• To operate, maintain, and provide to you the features and functionality of our website, including personalizing and improving your online experience;
• To help maintain the safety, security, and integrity of our services, technology assets, and business;
• To protect the health and safety of our personnel and visitors to our premises; and
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

DISCLOSURE OF PERSONAL INFORMATION

We do not sell your Personal Information under any circumstances, nor do  disclose your Personal Information to any third parties for their own marketing purposes. As permitted by applicable law, we may disclose your Personal Information to subsidiaries, affiliates, agents, or other entities that have a legitimate business need to know such Personal Information in the course of their duties, for the following purposes:

• To secure your residence at a Wellpointe facility, or another Wellpointe-affiliated facility that may be of interest to you;
• To improve our services and facilities;
• To comply with applicable legal requirements or to respond to requests from public and government authorities; and
• To protect our rights, privacy, safety or property, and/or that of our business partners, subsidiaries, affiliates, clients, agents, you, or others.

We may also disclose the following categories of Personal Information to the following categories of third parties:

Subsidiaries, Affiliates, and Agents

• Identifiers
• Protected classification characteristics
• Internet or other similar network activity
• Inferences drawn from other personal information

COOKIE POLICY

We use cookies, log files, web beacons, pixels, and other tracking technologies (collectively "cookies") to collect and store internet and electronic network activity about you and your interactions with Wellpointe's websites. A cookie is a piece of data stored by a user's browser that helps a website or service recognize that user's unique computer. We collect cookies to collect information about you so we can provide the experiences you request, recognize your visit, track your interactions, and improve your experiences.

You have control over some of the information we collect from cookies and how we use it. To remove or opt-out from our use of information from cookies and similar technologies, certain web browsers allow you to make and set privacy choices that are applicable and communicated from your web browser to the websites you visit. If you choose not to accept cookies from our Website, you may experience some reduced functionality or other inconveniences while accessing Wellpointe's websites.

Information about the process to enable or disable cookies across sites may be found on your internet browser provider's website. You may also visit www.allaboutcookies.org/manage-cookies/index.html for information on commonly used browsers.

CHILDREN UNDER AGE OF 16

Our websites are not intended for children under 16 years of age. No one under age 16 may provide any information to or through the  websites. We also do not collect Personal Information from any person that we know to be under age 16. If you are under the age of 16, do not use the websites or provide any information about yourself to us.

If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under the age of 16, please contact us via our Privacy Inquiry Webform or via telephone at 1(866)467-8688 Service Code 2052.

DATA SECURITY

Consistent with our legal and ethical obligations, we have implemented commercially reasonable organizational, technical, and administrative measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.

No security measure is failsafe, however, so we cannot guarantee the security of any Personal Information you provide to us.  Your own efforts to protect against unauthorized access play an important role in protecting the security of your Personal Information. Never share your passwords with others, and maintain your passwords in a secure location. If using a shared computer, you should take proper steps to fully sign off, clear cookies, and always log out of any site when providing Personal Information.

ADDITIONAL PRIVACY RIGHTS OF  CALIFORNIA RESIDENTS

This Privacy Notice for California residents supplements the information contained in this Policy and applies solely to residents of the State of California (“Consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 ("CPRA") (collectively, "CCPA") and to honor your Consumer Rights Requests, as more fully described below. Any terms defined in the CCPA have the same meaning when used in this Notice.

Your Privacy Rights Under the CCPA

• Right to know.
• Right to delete.
• Right to correct.
• Right to opt-out.
• Right to nondiscrimination.

For verified request to know, the CCPA allows you to request your information, at no cost, up to twice during a twelve (12) month period. We will provide our response in a readily usable format, which is usually electronic.

How to Submit a Consumer Rights Request

If you would like to exercise your CCPA rights and submit a Consumer Rights Request as described above, please submit a request to us  through any of the following:

• Calling us toll-free at 1 (866) 467-8688 Service Code 2052; or
• Submitting an Inquiry on via our Privacy Inquiry Webform; or
• Visiting our website for more information.

Verification of Your Identity.

To protect your privacy, if you make a request to exercise your CCPA rights as described above, we will need to verify your identity to a reasonable degree of certainty. A reasonable degree of certainty may include you providing us with pieces of information that are specific to you so that we can verify your identity.

You may make a request on your own behalf, or if you wish to designate an authorized agent to make a request on your behalf, please provide us with a signed declaration stating that your intent is to permit that individual to act on your behalf and include such individual's full name, address, email address, and phone number. In order to protect your Personal Information from unauthorized disclosure or deletion at the request of someone other than you or your authorized agent, Wellpointe requires identity verification before granting any of the requests described above.

Our Response Time to Your Consumer Rights Request

We will respond to verifiable Consumer Rights Requests within forty five (45) days of receipt. If you have a complex Consumer Rights Request which requires more time to respond, we will inform you of the reason and extension period in writing. The CCPA allows us up to ninety (90) days to respond to your request.

Right to Know About Personal Information Collected, Disclosed

You have the right to know what Personal Information we collect, use, disclose, and/or sell, the categories and specific pieces of Personal Information we collect and the sources, how we collect Personal Information, our business purpose for the collection and use of your Personal Information, the categories of third parties (excluding service providers) with whom we disclose your Personal Information, and whether we have sold any of your Personal Information.

You may request that we provide a description of the categories of Personal Information we have collected about you ("Categories Request") or a request for access to the specific pieces of Personal Information we have collected about you ("Specific Pieces Request").

Right to Request Deletion of Personal Information

You have the right to request that we delete any of the Personal Information that we have collected from you. Once we receive and confirm that your request is a verifiable Consumer Rights Request, we will inform you whether we have deleted (and directed our service providers to delete) your Personal Information, or whether we are declining to grant your request to delete due to an exception to the CCPA deletion requirements.

We are not obligated to comply with your request for deletion if we have a legal basis to retain your Personal Information, such as to complete a transaction for which we collected your Personal Information, to provide you with a service you requested, to detect security incidents, and to comply with a legal obligation.

Right to Request Correction of Personal Information

You have the right to request that we correct any inaccurate Personal Information that we have collected about you. Once we receive and confirm that your request is a verifiable Consumer Rights Request, we will inform you whether we have corrected your Personal Information (and directed our service providers to correct) your Personal Information, or whether we are declining to grant your request to correct due to an exception to the CCPA correction requirements.

Right to Non-Discrimination for Exercising Your CCPA Rights

If you choose to exercise any of your CCPA rights, we will not discriminate against you.

‍