AC Wellness Website and App Privacy Policy

The Privacy Policy was updated on January 29, 2025

Your privacy is important to AC Wellness. This Privacy Policy (“Policy”) covers how we collect, process, transfer, and safeguard your personal information. Personal information means any data that relates to an identified or identifiable individual or that is linked or linkable to them by AC Wellness, and that is recorded in any form on our systems (e.g., paper, electronic, video, audio). In this Policy, the use of (or variations of the words) “including,” “for example” or “such as” followed by specific examples should not be construed as an exhaustive list. Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

What Information We Collect and Maintain About You

When you interact with AC Wellness, such as to receive medical care and/or wellness services, participate in studies, or use our websites or apps, we may collect a variety of information, including:

• Identifiers. Information that identifies you, such as name, email address, physical address, phone number, date of birth, Apple badge ID (for Apple employees), social security number, and other identifiers.

• Health Information. Information about your physical or mental health or condition.

• Insurance Information. Information about your health insurance plan such as your medical, dental, and vision plans, including subscriber number and group ID.

• Engagement Data. Information about your use of our services such as your use of certain features (for example, medical chat), your sharing of health data, and chat usage metrics such as chat duration.

• Technical Data. In most cases, this data is non-personal information collected as part of your usage of the AC Wellness websites or apps. This may include data such as information about your app usage, such as your app version, date of first launch, error and crash data, performance and other diagnostic data, and technical data about your device, such as operating system, model, and iOS version. The apps do not respond to browser “Do-Not-Track” signals. You also have the option to share identifiable technical data with us for purposes of debugging technical issues with the websites or apps or for product improvement.

• Other Information You Provide to Us. Details such as the content of your communications with AC Wellness through email, surveys, chat, or other communication channels, as well as documents, images or other files you send to us.

You are not required to provide the personal information that we have requested. However, if you choose not to do so, in some cases we will not be able to provide you with our services or respond to requests you may have.

If you are receiving medical care and/or wellness services from us, we may collect and/or create protected health information about you that is subject to the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”) and our separate Notice of Privacy Practices. The Notice of Privacy Practices may contain additional provisions relating to the use and disclosure of your protected health information that go beyond the terms of this Policy.

Why We Collect Personal Data

We may use your personal information and non-personal information to provide services to you, conduct studies or surveys with your consent, for troubleshooting, to communicate with you, and to comply with law:

• Provide services to you. If you receive services from AC Wellness such as medical and/or wellness care and support, we may collect personal information in order to provide safe and tailored services to you and improve the quality of services delivered. We also maintain your personal information to keep a record of the care provided to you. Refer to our Notice of Privacy Practices to learn more about how we may use and disclose your protected health information.

• Conduct studies or surveys with your consent. You may be invited to participate in studies, surveys or other quality improvement efforts. If you provide consent to participate, we may collect personal information that would be used to improve our service offerings or for purposes outlined in the consent.

• Troubleshooting. You have the option to share personal information with us to assist with troubleshooting issues with our websites and apps.

• Communicate with you. We may use your personal information to respond to your questions or concerns. From time to time, we may use your personal data to send important notices or to communicate changes to our terms, conditions, and policies.

• Comply with law. We may use your personal information to comply with applicable laws, such as HIPAA.

Disclosure to Third Parties

Service Providers

AC Wellness shares your personal information with companies who provide services for us such as data backend and storage, electronic health record storage and functionality, and information processing. These companies are obligated to protect your information and may be located wherever AC Wellness operates.

Others

Your personal information may also be disclosed to the following third parties:

• Regulatory authorities, such as the U.S. Department of Health and Human Services and other federal or state government agencies.

• Law enforcement or other third parties pursuant to legal process such as a subpoena or court order.

• Others, as described in our Notice of Privacy Practices for protected health information, or if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, if at your direction or with your consent/authorization or in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

• Non-personal information may be shared with all of those listed above and with our service providers.

Protection of Your Information

AC Wellness takes the security of your information very seriously. We have in place security measures to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. The security measures are implemented and maintained in accordance with legal, organizational, and technological developments. Where personal information is shared with service providers, we will require that those service providers provide the appropriate security measures to protect personal information from unauthorized use or disclosure. Members of AC Wellness and our service providers have been made aware that personal information is subject to data protection laws and appropriate contractual arrangements and that it may only be used in accordance with AC Wellness’s instructions and this Policy.

Retention of Information

We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

Third‑Party Sites and Services

Our websites and apps may contain links to third-party websites, products, and services. Information collected by third parties is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

Access to Personal Information

For personal information we collect through the websites or apps and hold, we will provide you with access (including a copy) for any purpose including to request that we correct the data if it is inaccurate or delete the data if AC Wellness is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made by contacting privacy@acwellness.com, (877) 233-9721, or AC Wellness, Attn: Privacy Officer, 20730 Valley Green Drive, Cupertino, CA 95014.

Children

None of AC Wellness’s services are intended for children under the age of 13. If we learn that we have collected the personal information of a child under 13, we will take steps to delete the information as soon as possible.

Privacy Questions

If you have any questions or concerns about this privacy policy or data processing please contact us at privacy@acwellness.com.

AC Wellness may update this Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our websites and apps along with the updated Privacy Policy.

AC Wellness, 20730 Valley Green Drive, Cupertino, CA 95014 

California Privacy Disclosures

To help Californians make informed privacy decisions about their personal information, the State has created a common framework for businesses to talk about privacy. AC Wellness is using that framework here to describe, for each category of personal information regulated under the California framework, whether AC Wellness collects that personal information or discloses it for a business purpose related to services provided to you by AC Wellness (outside the context of AC Wellness processing personal information as an employer). For employment-related data processing, contact AC Wellness to review the Employee Privacy Notice.

Categories of Personal Information:

1. Identifiers. Information that identifies you, such as name, email address, physical address, phone number, date of birth, Apple badge ID (for Apple employees), social security number, and other identifiers.

2. Characteristics of protected classifications under California or federal law. California and federal laws provide protection against discrimination if you belong to a protected class. Under California law, certain Personal Data in this category may be considered sensitive. Protected classes include groupings based on race, ethnicity, or national origin; religious or philosophical beliefs; sexual orientation; genetic information; family status; age (such as the elderly); and whether you have a disability.

3. Commercial information. AC Wellness does not process commercial information.

4. Biometric information. AC Wellness does not process biometric information.

5. Internet or other electronic network activity information. AC Wellness does not process internet or other electronic network activity information.

6. Geolocation data. AC Wellness does not process geolocation data.

7. Audio, electronic, visual, thermal, or olfactory information. AC Wellness does not process this information.

8. Professional or employment-related information. For disclosures related to AC Wellness’s processing of professional or employment-related information, contact AC Wellness at privacy@acwellness.com.

9. Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act. AC Wellness does not process this information.

10. Inferences drawn from your personal information to create a profile about you. AC Wellness doesn’t make inferences from your personal information to create a profile about you.

11. Personal information described in CA Civil Code Section 1798.80(e). The California Consumer Privacy Act requires that we tell you whether we collect any personal information that is described in California Civil Code Section 1798.80(e). This includes a broad variety of categories of personal data such as name, address, telephone number, physical characteristics, employment information, and medical information.

The list below describes the sources from which we collect the categories of personal information about you listed above, our purposes for collection and disclosure of your personal information, and the categories of third parties to whom we disclose your personal information. We will retain your personal information for the period necessary to fulfill the purposes outlined below unless a longer retention period is required or permitted by law.

*May be considered Sensitive Personal Information

Your Rights

If you are in California, you have a right to knowledge, access, correction, and deletion of your personal information under the California Consumer Privacy Act. You also have a right to opt out of the sale or sharing of your personal information, a right to limit the use of your Sensitive Personal Information, and a right not to be discriminated or retaliated against for exercising one of your California privacy rights. AC Wellness does not sell or share personal information (as those terms are defined under California law), and does not discriminate or retaliate in response to privacy rights requests. AC Wellness does not use or disclose your Sensitive Personal Information for purposes that would allow you to exercise your right to limit under California law.

To exercise your rights, you or your authorized agent can make a request to AC Wellness by visiting http://www.acwellness.com, emailing privacy@acwellness.com,  or calling (877) 233-9721.

This Notice may be updated from time to time on https://www.acwellness.com/.