PRIVACY POLICY

EFFECTIVE DATE: February 9, 2022

HEALTHY ACCESS MEDICARE UPDATE SUPPORTS YOUR DATA PRIVACY

Healthy Access ("HA") , a service of Andrews Wharton Inc. (“AWI”) supports an open dialogue between organizations and their customers, prospects, and visitors when it comes to data, its collection and usage. To that end, we have created the following Privacy Policy solely as it relates to information collected and used on healthy-access.com. This Privacy Policy explains how and why HA collects and uses information provided by users of this website.

The website is intended for use by residents of the United States (“US”) or non-residents that agree to use the website in accordance with US laws and this Privacy Policy. By using or accessing the website, you signify your agreement to be bound by our Privacy Policy. If you do not agree to this Privacy Policy, please do not access, or otherwise use the website.

INFORMATION COLLECTION

We collect Personal Information when you voluntarily submit that information to us such as through our contact pages, by email, when you chat with us, by seeking employment with us, or through some other means. “Personal Information” may include your name, the company you work for, postal address, email address, telephone number, and other personally identifiable information you provide.

When you visit or use the website, we also automatically collect certain additional information about you, such as your internet protocol (IP) address, cookie IDs, the type of browser or device operating system you use, the domain name of the website from which you linked to us, the amount of time you spend on the website, the pages on the website that you view and similar data. We may also aggregate information collected from our users (such as the number of users in a particular region or having particular characteristics).

INFORMATION USAGE & DISCLOSURE
- We will use and disclose your Personal Information as described herein, unless you have specifically consented to another type of use, either at the time the Personal Information is collected from you or through some other form of consent from you or notification to you:
- We will use Personal Information to operate and improve the website and to provide you with any specific services that you have requested.
- We may use your Personal Information to respond to your direct inquires.
- We will use your Personal Information to add you to our mailing lists, to send you emails from time to time, and to inform you of services and product updates, new products, and other related information from AWI and our affiliates.
- We may permit our vendors and service providers (such as our payment processors, email service provider, host providers, personnel management service providers) to access your Personal Information in connection with performing services for us.
- We may disclose Personal Information as required by law or legal process.
- We may disclose Personal Information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the policies for the website.
- We may transfer your Personal Information in connection with a bankruptcy proceeding or the sale, merger or change of control of AWI or the division responsible for the services with which your Personal Information is associated.

Please note that if you specifically consent to additional uses or disclosures of your Personal Information, we may use and disclose your Personal Information in a manner consistent with that consent. Aggregate information may be shared with any number of parties, provided that such information shall not specifically identify you. AWI does not sell, rent, loan, trade or lease any Personal Information collected from the website without having first provided you with notice and the opportunity to opt-out of such use. All AWI affiliates are committed to protecting your privacy and will uphold the commitments made in this Privacy Policy.

COOKIES USAGE & SIMILAR TECHNOLOGIES

AWI uses cookies and similar technologies (such as clear gifs, web beacons, tags, and similar technologies) to collect data related to usage of the website and for the purpose of facilitating and enhancing your communication and interaction with the website. We may use this data to understand which parts of our websites are visited most often, to understand the traffic patterns on the website pages, to improve or tailor our website, and for the purposes described in this Privacy Policy. We may also use cookies to tailor web content and advertising to match your browsing interests.

We may also use and place cookies on your device from our third-party service providers in connection with the website, such as an analytics provider that helps us manage and analyze website usage. An example of such third-party is Google Analytics, which we use to collect and analyze demographic and other information, and through which Google will collect certain information to be used according to Google’s privacy practices. To opt-out of the use of Google Analytics, click
here.

You can set your Internet browser to notify you when you receive a cookie, giving you the chance to decide whether or not to accept it. If you reject a cookie or flush it, noting that cookies may already be on your device, you may still use this website, but you may be limited in the functionality of some areas. You can refer to your web browser settings to adjust your cookie preferences. Further information on cookies is available at
allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our website or some of its functionality may be affected. Please be advised that certain third parties that are beyond the scope of this Privacy Policy may collect information in connection with the website. We are not responsible for the acts or omissions of such third parties.

INTEREST-BASED ADVERTISING

We may engage third parties to collect information about you on this website in order to deliver targeted advertising to you when you visit other websites. Cookies, described above, may be used in this process. For example, if you are searching for information on a particular product or service, our vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising is called “behavioral advertising” or “interest-based advertising.” We believe that such advertising is helpful because you will see ads that are relevant to your interests. We comply with the self-regulatory principles for online behavioral advertising set forth by the Digital Advertising Alliance (“DAA”). You can opt-out of behavioral advertising from certain providers at
aboutads.info/consumers.

DO NOT TRACK

Please note that we do not respond to or honor “do not track” (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers.

WHAT OPT-OUT RIGHTS & CHOICES DO I HAVE?

Healthy Access or other affiliates of AWI may periodically send you email or postal alerts. You can request to be removed from our email list by clicking the unsubscribe link within the footer of any email received from us, or from our postal list by contacting us at
privacy@andrewswharton.com. We will process your request within a reasonable time after receipt.In the event that you provide consent or engage with an offer from a partner or affiliated company associated with this website, please note that you must follow opt-out instructions provided in that company’s communications in order to be removed from their use of your information.

CAN I ACCESS & CORRECT MY PERSONAL INFORMATION?

California Residents may request access or to delete the information we have about you, please follow the instructions below. For all other inquiries, please send a request via email to
privacy@andrewswharton.com with specific information about your privacy-related request, and AWI will respond within 45 days.

CALIFORNIA CONSUMER DISCLOSURE

The California Consumer Privacy Act (CCPA) provides California residents with the additional rights listed below.

Definitions
The terms “Business Purpose(s)”, “Personal Information”, “Sell” (or “Sale”), “Service Provider(s)” and “Third Parties” have the meanings given in the California Consumer Privacy Act of 2018 (CCPA). These term references and disclosures are limited to this section of the Privacy Policy and designated exclusively for California Consumers.

Categories of Personal Information Collected

- Personal identifiers including name, postal address, email address, and phone number.
- Digital identifiers include IP address, cookie ID, and other device attributes.
- Demographic information including gender, age, ethnicity, income.
- Behavioral or transactional activity such as purchases, subscriptions, or web pages visited.
- Employment Information
- Education Information
- Inferences related to preferences or potential interests.

Purposes for Collection and Use of Personal Information
We collect personal information to provide marketing services to corporate customers, including direct marketing, data hygiene, analytics, and market research.

Categories of Sources from which Personal Information is Collected
- Owned and operated websites.
- Inbound communications.
- Public record and publicly available information.
- Website directories.
- Data resellers.
- Surveys

Categories of Personal Information We Sell
- Personal identifiers including name, postal address, email address, and phone number.
- Demographic information including gender, age, ethnicity, income.
- Behavioral or transactional activity such as purchases, subscriptions, or web pages visited.
- Employment Information
- Education Information
- Inferences related to preferences or potential interests.

Purposes for Selling Personal Information

We sell personal information to provide marketing services to corporate customers, including direct marketing and market research.

Categories of Third Parties to whom Personal Information is Sold
- Advertising Networks
- Advertising/Marketing Companies
- Apparel & Accessory Companies
- Automotive Companies
- Business Service/Agencies
- Business to Business Companies
- Communication Services Companies
- Consumer Data Resellers
- Consumer Packaged Goods Companies
- Consumer Services Companies
- Data Analytics Providers
- Educational Institutions & Companies
- Electronics Companies
- Energy & Utility Companies
- Financial Services Companies
- Food & Beverage Companies
- Gift Product Companies
- Health & Wellness Product & Service Companies
- Lifestyle & Interest Product Companies
- Manufacturing Companies
- Marketing Data Companies
- Not for Profit Organizations
- Operating Systems & Platforms
- Parenting Product Companies
- Public or Government Entities
- Publishing Product Companies
- Social Networks
- Technology/Computer Software Companies
- Telecommunications Companies
- Travel, Leisure, & Entertainment Companies

Categories of Third Parties to whom Personal Information was Shared for a Business Purpose
- Advertising
- Cloud Computing
- Consultants
- Data Hygiene
- IT Support
- Marketing Analytics

CALIFORNIA CONSUMER RIGHTS & OPTIONS

Access or Delete Your Personal Information
Complete the form below, or alternatively you may email us at
privacy@andrewswharton.com or call us at 1-866-628-1150.

Please include your full name, email address, phone number, street address, city, and state of residence, along with the right you wish to exercise, so that we can process your request in an efficient manner.

If you are a third-party agent requesting information on behalf of an individual, please note that we reserve the right to receive direct authorization from the individual prior to completing such a request.

Opt Out of Sales or Exercise Your “Do Not Sell My Personal Information” Right Under CCPA

Complete the form below, or alternatively you may email us at
privacy@andrewswharton.com or call us at 1-866-628-1150.

Please include your full name, email address, phone number, street address, city, and state of residence, along with the right you wish to exercise, so that we can process your request in an efficient manner.

If you are a third-party agent requesting to opt-out on behalf of an individual, please note that we reserve the right to receive direct authorization from the individual prior to completing such a request.

Response Timing

We aim to respond to a consumer request for access or deletion within 45 days. If we require more time, we will inform you of the reason and extension period in writing.
Do Not Sell My Personal Information

By submitting a Do Not Sell My Personal Information Request, the personal information that you provide will be used to determine what data, if any, is maintained within our systems.

HOW IS MY INFORMATION KEPT SECURE?

We protect information we collect about you by maintaining physical, electronic, and procedural safeguards designed to prevent unauthorized access to user data retained in our servers, however, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online. We take reasonable precautions to protect your information both online and offline. The servers on which we store data are kept in a secure environment.

HOW LONG IS MY INFORMATION RETAINED?

We will retain your information for as long as needed to provide you with the website or any requested services, and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your Personal Information, we may continue to retain and use aggregate or anonymous data previously collected and/or anonymize or aggregate your Personal Information. Please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third parties).

THIRD-PARTY LINKS

As a convenience to you, we may provide links to third-party websites or services from within the website. We are not responsible for the privacy practices or content of these third-party websites or services, and by providing a link we are not endorsing or promoting such third-party websites or services. When you link away from our website, you do so at your own risk. We encourage you to read the policies and terms of every website or service you visit.

SOCIAL NETWORKING SERVICES

The website may integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our website, we are doing so merely as an accommodation and, like you, are relying upon those third-party services to operate properly and fairly.

INFORMATION RELATING TO MINORS

Our online services are not intended for minors. Our website does not knowingly solicit or collect personal information from anyone under the age of 18. If we are made aware that we have received such information, or any information in violation of our Privacy Policy, we will use reasonable efforts to locate and remove that information from our records.

HOW WILL I KNOW ABOUT CHANGES TO THIS POLICY?

AWI may revise this Policy from time to time. If we decide to change our Privacy Policy, we will post those changes to this Privacy Policy and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material changes to this policy, we will notify you here, or by means of a notice on our home page.

QUESTIONS?
To ask questions about HA's Privacy Policy, please email us at
privacy@andrewswharton.com.
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TERMS AND CONDITIONS

EFFECTIVE DATE: February 9, 2022

INTRODUCTION
Welcome to
https://healthy-access.com (the “Website”). This Website is maintained and operated by Andrews Wharton Inc. (“Company”, “we”, “our” or “us”) dba Healthy Access. YOUR ACCESS AND USE OF THE WEBSITE IS SUBJECT TO THE FOLLOWING TERMS AND CONDITIONS (THE "TERMS AND CONDITIONS") AND ALL APPLICABLE LAWS. BY ACCESSING OR USING ANY PART OF THE WEBSITE, YOU ACCEPT, WITHOUT LIMITATION OR QUALIFICATION, THESE TERMS AND CONDITIONS. IF YOU DO NOT AGREE WITH ALL OF THE TERMS AND CONDITIONS SET FORTH BELOW, YOU MAY NOT USE ANY PORTION OF THE WEBSITE.

ACCESSIBILITY

If you are having any trouble accessing these Terms and Conditions or the Website, please contact us at
privacy@andrewswharton.com. Our hours of operations are: 9:00am ET – 5:00pm ET.

SEEK PROFESSIONAL ADVICE

The information contained in or made available through this Website cannot replace or be a substitute for the services of trained medical, healthcare, insurance, or finance professionals. In particular, you should regularly consult a doctor in all matters relating to physical or mental health, particularly concerning any symptoms that may require diagnosis or medical attention. You should also consult with a financial advisor. We and our licensors or suppliers make no representations or warranties concerning any treatment, action, or application of medication or preparation by any person following the information offered or provided within or through the Website.

AUTHORIZED USE OF WEBSITE

This Website is provided for your personal and non-commercial use and for informational purposes only. Any other use of the Website requires the prior written consent of Company.

UNAUTHORIZED USE OF WEBSITE

You may not use spiders, robots, data mining techniques, or other automated devices or programs to catalog, download or otherwise reproduce, store, or distribute content available on the Website. Further, you may not use any such automated means to manipulate the Website, such as automating what are otherwise manual or one-off procedures. You may not take any action to interfere with, or disrupt, the Website or any other user's use of the Website, including, without limitation, via means of overloading, “flooding”, “mailbombing” or “crashing” the Website, circumventing security or user authentication measures or attempting to exceed the limited authorization and access granted to you under these Terms and Conditions. You may not frame portions of the Website within another Website. You may not resell use of, or access to, the Website to any third-party without our prior written consent.

PROPRIETARY RIGHTS

Company is the owner of or otherwise licensed to use all parts of the Website, including all copy, software, graphics, designs and all copyrights, trademarks, service marks, trade names, logos, and other intellectual property or proprietary rights contained therein. Some materials on the Website belong to third parties who have authorized Company to display the materials, such as certain third-party licensors. By using the Website, you agree not to copy, distribute, modify, or make derivative works of any materials without the prior written consent of the owner of such materials. Except as expressly set forth in these Terms and Conditions, no license is granted to you and no rights are conveyed by virtue of accessing or using the Website. All rights not granted under these Terms and Conditions are reserved by Company.

THIRD-PARTY LINKS

This Website may contain links to other Websites not maintained by us. Other Websites may also reference or link to our Website. We encourage you to be aware when you leave our Website and to read the terms and conditions and privacy statements of each and every Website that you visit. We are not responsible for the practices or the content of such other Websites.

NO WARRANTIESWHILE COMPANY USES REASONABLE EFFORTS TO INCLUDE UP-TO-DATE INFORMATION ON THE WEBSITE, EXCEPT FOR THE EXPRESS WARRANTIES STATED ON OUR WEBSITE, COMPANY MAKES NO WARRANTIES OR REPRESENTATIONS AS TO THE ACCURACY OR COMPLETENESS OF INFORMATION ON THE WEBSITE. TO THE FULLEST EXTENT PERMITTED BY LAW, YOUR USE OF THE WEBSITE IS AT YOUR OWN RISK. THE WEBSITE, INCLUDING ALL CONTENT MADE AVAILABLE ON OR ACCESSED THROUGH THE WEBSITE, IS PROVIDED "AS IS" AND COMPANY MAKES NO REPRESENTATIONS OR WARRANTIES OF ANY KIND WHATSOEVER FOR THE CONTENT ON THE WEBSITE. FURTHER, TO THE FULLEST EXTENT PERMISSIBLE BY LAW, COMPANY DISCLAIMS ANY EXPRESS OR IMPLIED WARRANTIES, INCLUDING, WITHOUT LIMITATION, NON-INFRINGEMENT, TITLE, MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. COMPANY DOES NOT WARRANT THAT THE FUNCTIONS CONTAINED IN THE WEBSITE OR ANY MATERIALS OR CONTENT CONTAINED THEREIN WILL BE UNINTERRUPTED OR ERROR FREE, THAT DEFECTS WILL BE CORRECTED, OR THAT THE WEBSITE OR THE SERVER THAT MAKES IT AVAILABLE IS FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. TO THE FULLEST EXTENT PERMITTED BY LAW, COMPANY SHALL NOT BE LIABLE FOR THE USE OF THE WEBSITE, INCLUDING, WITHOUT LIMITATION, THE CONTENT AND ANY ERRORS CONTAINED THEREIN.IN NO EVENT WILL COMPANY BE LIABLE UNDER ANY THEORY OF TORT, CONTRACT, STRICT LIABILITY OR OTHER LEGAL OR EQUITABLE THEORY FOR ANY LOST PROFITS, LOST DATA, LOST OPPORTUNITIES, COSTS OF COVER, EXEMPLARY, PUNITIVE, PERSONAL INJURY/WRONGFUL DEATH, SPECIAL, INCIDENTAL, INDIRECT OR OTHER CONSEQUENTIAL DAMAGES. FURTHER, TO THE FULLEST EXTENT PERMITTED BY LAW, IN NO EVENT WILL COMPANY BE LIABLE FOR ANY DIRECT DAMAGES EXCEEDING THE GREATER OF THE FEES YOU PAID DIRECTLY TO COMPANY ON THIS WEBSITE FOR PRODUCTS AND SERVICES IN THE TWELVE MONTHS PRECEDING THE CLAIM OR ONE HUNDRED UNITED STATES DOLLARS ($100).

CHANGES

All information posted on the Website is subject to change without notice. In addition, these Terms and Conditions may be changed at any time without prior notice. We will make such changes by posting them on the Website. You should check the Website for such changes frequently. Your continued access of the Website after such changes conclusively demonstrates your acceptance of those changes.

INDEMNIFICATION

You agree to indemnify, defend and hold harmless Company, its employees, directors, officers, agents, business partners, affiliates, contractors, distribution partners and representatives from and against any and all claims, demands, liabilities, costs or expenses, including attorney’s fees and costs, arising from, or related to (i) your use of the Website, (ii) any breach by you of any of these Terms and Conditions, (iii) any violation of applicable law or (iv) disputes between you and a third-party product or service you have accessed or been connected to through the Website.

SEVERABILITY

If any part of these Terms and Conditions shall be held or declared to be invalid or unenforceable for any reason by any court of competent jurisdiction, such provision shall be ineffective but shall not affect any other part of these Terms and Conditions, and in such event, such provision shall be changed and interpreted so as to best accomplish the objectives of such unenforceable or invalid provision within the limits of applicable law or applicable court decisions.

WAIVER, REMEDIES

The failure of Company to partially or fully exercise any rights or the waiver of Company of any breach of these Terms and Conditions by you shall not prevent a subsequent exercise of such right by Company or be deemed a waiver by Company of any subsequent breach by you of the same or any other term of these Terms and Conditions. The rights and remedies of Company under these Terms and Conditions and any other applicable agreement between you and Company shall be cumulative, and the exercise of any such right or remedy shall not limit Company's right to exercise any other right or remedy.

GOVERNING LAW; DISPUTE RESOLUTION; ARBITRATION

The laws of the State of New York shall govern these Terms and Conditions. While we will make reasonable efforts to resolve any disagreements you may have with Company, if these efforts fail you agree that all claims, disputes or controversies against Company arising out of these Terms and Conditions, or the purchase of any products or services ("Claims") are subject to fixed and binding arbitration (except for matters that may be taken to small claims court), no matter what legal theory they are based on or what remedy (damages, or injunctive or declaratory relief) they seek. This includes Claims based on contract, tort (including intentional tort), fraud, agency, your or our negligence, statutory or regulatory provisions, or any other sources of law; Claims made as counterclaims, cross-claims, third- party claims, interpleaders or otherwise; and Claims made independently or with other claims. The party filing an arbitration must submit Claims to the American Arbitration Association and follow its rules and procedures for initiating and pursuing an arbitration. Any arbitration hearing that you attend will be held at a place chosen by the American Arbitration Association in the same city as the U.S. District Court closest to your then current residential address, or at some other place to which you and Company agree in writing, and the arbitrator shall apply New York law consistent with the Federal Arbitration Act. You shall not be entitled to join or consolidate Claims in arbitration by or against other users or to arbitrate any Claim as a representative or member of a class or in a private attorney general capacity. You may obtain copies of the current rules, and forms and instructions for initiating an arbitration by contacting the American Arbitration Association at using the contact information noted below.

American Arbitration Association

800-778-7879 (toll-free)

Website:
https://www.adr.org/

A single, neutral arbitrator will resolve Claims. The arbitrator will be either a lawyer with at least ten (10) years’ experience or a retired or former judge, selected in accordance with the rules of the American Arbitration Association. The arbitration will follow the procedures and rules of the American Arbitration Association which are in effect on the date the arbitration is filed unless those procedures and rules are inconsistent with these Terms and Conditions, in which case these Terms and Conditions will prevail. Those procedures and rules may limit the discovery available to you or us. The arbitrator will take reasonable steps to protect your customer account information and other confidential information if requested to do so by you or us. Each party to the arbitration will bear the expense of that party's attorneys, experts, and witnesses, and other expenses, regardless of which party prevails, but a party may recover any or all expenses from another party if the arbitrator, applying applicable law, so determines. The arbitrator's award is final and binding on the parties unless we or you appeal it in writing to the arbitration firm within fifteen (15) days of notice of the award. The appeal must request a new arbitration before a panel of three neutral arbitrators designated by the American Arbitration Association. An award by a panel is final and binding on the parties after fifteen (15) days has passed. Any Claim you have must be commenced within one (1) year after the date the Claim arises. As noted above, you and Company hereby voluntarily and knowingly waive any right either may have to a jury trial.

We will not choose to arbitrate any Claim you bring in small claims court. However, if such a Claim is transferred, removed, or appealed to a different court, we may then choose to arbitrate.

In the event this arbitration clause is not enforceable by the specified arbitration organization, the parties will mutually agree upon another arbitration organization that will enforce this clause.

CLASS ACTION WAIVER

YOU AGREE THAT, BY ENTERING INTO THIS AGREEMENT, YOU AND COMPANY ARE EACH WAIVING THE RIGHT TO A TRIAL BY JURY OR TO PARTICIPATE IN A CLASS ACTION, COLLECTIVE ACTION, PRIVATE ATTORNEY GENERAL ACTION, OR OTHER REPRESENTATIVE PROCEEDING OF ANY KIND. CLAIMS AND REMEDIES SOUGHT AS PART OF A CLASS ACTION, PRIVATE ATTORNEY GENERAL OR OTHER REPRESENTATIVE ACTION ARE SUBJECT TO ARBITRATION ONLY ON AN INDIVIDUAL (NON-CLASS, NON-REPRESENTATIVE) BASIS, AND THE ARBITRATOR MAY AWARD RELIEF ONLY ON AN INDIVIDUAL (NON-CLASS, NON-REPRESENTATIVE) BASIS.

PRIVACY POLICY
Use of the Website is also governed by our Privacy Policy, which is incorporated herein by reference.
QUESTIONS?

Should you have any questions regarding these Terms and Conditions you may contact us at
privacy@andrewswharton.com.