Privacy Notice for California Residents

OVERVIEW

The Sharecare Privacy Notice for California Residents (or "Privacy Notice") explains what types of personal information, also referred to as personal data, we may collect about our users, visitors, and/or employees or contractors who reside in the State of California.

While this Privacy Notice is intended to describe the broadest range of our information processing activities globally, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular country may limit the types of personal information we can collect or the manner in which we process that information. In those instances, we adjust our internal policies and practices to reflect the requirements of local law.

This Privacy Notice complies with the California Consumer Privacy Act of 2018 ("CCPA") and other applicable privacy laws. If you have questions or do not fully understand this notice, please contact Sharecare’s Privacy and Data Protection Officer by phone at 1-800-619-8949 or by email at privacy@sharecare.com.

WHAT INFORMATION DO WE COLLECT

"Personal information" means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include data where the identity has been removed (deidentified data). If applicable to your use of our services, we may collect, store, and use the following categories of personal information about you as listed below.

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	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).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

Note: Personal information does not include:

• Publicly available information from government records
• Deidentified or aggregated consumer information
• Information excluded from the CCPA's scope, like:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

HOW WE COLLECT INFORMATION ABOUT YOU

We obtain the categories of personal information listed above from the sources listed under “How We Collect Information” in our Privacy Policy. Also, if you are an applicant, employee, or contractor of Sharecare, we collect information you provide to us and information provided by third-party vendors who support our background checks.

HOW WE USE YOUR INFORMATION

We may use or disclose the personal information we collect for one or more of the following business and commercial purposes:

• To fulfill or meet the reason for which the information is provided.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To administer our employment or contract relationship with you with respect to services you provide on our behalf.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
• In connection with a select few of our products (e.g. QualityHealth / Healthtrak), but never in connection with a Sharecare enterprise program, for third-party advertising by our clients. Because the information provided by you in the course of using such products could be deemed sensitive health information, this use is a use you may specifically opt out of using the “Limit the Use of My Sensitive Information” button in the privacy webform.

Note: We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

DISCLOSURE OF PERSONAL INFORMATION

Sharecare may disclose your personal information in the following circumstances:

• We may disclose any data about you when, in our opinion, such disclosure is necessary to prevent fraud or to comply with any statute, law, rule or regulation of any governmental authority or any order of any court of competent jurisdiction.
• We may, from time to time, outsource some or all of the operations of our business to third-party service providers. In such cases, it may be necessary for us to disclose your data to those service providers. In some cases, the service providers may collect data directly from you on our behalf. We restrict how such service providers may access, use and disclose your data.
• We employ other companies and individuals to perform functions on our behalf. Examples include processing compensation, providing employee benefits, and performing legal and other professional services. These agents may have access to your data as needed to perform their functions, but they are not permitted to use it for other purposes.
• As we continue to develop our business, we might sell or buy companies, subsidiaries, or business units. In such transactions, data generally is one of the transferred business assets but remains subject to the promises made in any pre-existing privacy statement (unless, of course, the person consents otherwise). Also, in the unlikely event that Sharecare or all of its assets is acquired, your data may be one of the transferred assets.
• We release data when we believe release is appropriate to comply with the law; enforce or apply our policies and other agreements; or protect the rights, property, or safety of Sharecare, employees, or others. Obviously, however, this does not include selling, renting, sharing or otherwise disclosing personally identifiable data from employees for commercial purposes in violation of the commitments set forth in this Privacy Statement.
• Please be advised that Sharecare does not sell, and has not sold personal information in the last twelve (12) months. For purposes of this policy, sold means the disclosure of Personal Information to a third-party for monetary or other valuable consideration. Likewise, Sharecare does not have any future plans to sell personal information. As described in our Privacy Policy, Sharecare has advertising arrangements with respect to some its products (e.g. QualityHealth / Healhtrak) that only apply to certain (non-enterprise) users, but these advertising arrangements do not involve personal data being sold to or shared with advertisers. Under these arrangements, Sharecare administers the ad-targeting through our own service providers without selling or sharing personal information with our clients or other third parties. Nonetheless, we offer the ability to opt out of sharing or selling personal information (see “REQUESTS TO EXERCISE YOUR RIGHTS UNDER CCPA” below) for users who want to opt out of these arrangements, to the extent they are applicable.
• Sharecare does not share personal information with “third parties” as such term is defined under CCPA. To the extent third-party advertisers placing cookies on Sharecare’s websites through a third-party ad network is deemed “sharing” our visitors’ personal information with such third parties under CCPA, Sharecare has shared such information in the last twelve (12) months where visitors to our websites have affirmatively opted into cookies. The only information available to such third parties is comprised of anonymized identifiers used by such third parties to track the visitor. Sharecare does not contract with the third-party advertisers described here.
• We do not knowingly collect or solicit personal information from minors under the age of 16. 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 16, please contact us at privacy@sharecare.com.

ACCESS TO PERSONAL INFORMATION WE COLLECT

You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please go to our request form or submit a request via email to privacy@sharecare.com.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. If you hold an account with us, you may be asked to reauthenticate to before receiving a copy of your personal information. If you do not hold an account with us, you may be asked to provide a driver’s license and/or a signed declaration before receiving a copy of your personal information. You may designate an authorized agent to request information on your behalf, provided that the authorized agent complies with our verification procedures to ensure your permission has been obtained.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous. In the event that we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

CORRECTION OF COLLECTED PERSONAL INFORMATION

We endeavor to ensure that personal information in our possession is accurate, current and complete. If an individual believes that the personal information about him or her is incorrect, incomplete or outdated, he or she may request the revision or correction of that information. We reserve the right not to change any personal information we consider is accurate.

If it is determined that personal information is inaccurate, incomplete or outdated, we will use reasonable efforts to revise it and, if necessary, use reasonable efforts to inform agents, service providers or other third parties, which were provided with inaccurate information, so records in their possession may be corrected or updated.

RETENTION AND DELETION OF COLLECTED INFORMATION

Except as otherwise permitted or required by applicable law or regulatory requirements, we will retain your personal information only for as long as we believe it is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting requirements or obligations).

You may request that we delete the personal information about you that we hold. There are instances where applicable law or regulatory requirements allow or require us to refuse to delete this personal information. If we cannot delete your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. We may require that you verify your identity, either through reentering your username and password (if applicable, for self-service features) or through email confirmation, before we delete your personal information.

REQUESTS TO EXERCISE YOUR RIGHTS UNDER CCPA

Please submit requests to access, delete, or correct your personal information, to limit the use of your sensitive information, or to opt out of any potential sales or sharing of your personal information, using our privacy webform. Any request by you to us to delete your personal information may not result in deletion of any information submitted by you to a third-party provider. If you require the third-party to delete any of your personal information, you must contact the third party directly to request such deletion.

In certain circumstances you may have provided express consent in connection with your providing certain personal information to us of for a specific use of your personal information. Please submit requests to withdraw your consent to privacy@sharecare.com.

If you use an opt-our preference signal through your browser or operating system, and you are visiting our websites, we will receive that signal and treat it as a valid request to opt out of the sale or sharing of your personal information, to the extent the signal conveys sufficient information for us to treat it as such.

RESOLVING CONCERNS

If you have questions or concerns regarding the handling of your personal information, or want to report concerns or complaints, including information about potential data breaches involving personal information to the Legal Department, please contact privacy@sharecare.com.

CHANGES TO PRIVACY NOTICE

This Privacy Notice is reviewed periodically to ensure it accurately captures all types of data collected or any additional or different processing of such data. We may, therefore, change this Privacy Notice at any time. The effective date of each version of this Privacy Notice is listed below.

NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

SECURITY OF COLLECTED INFORMATION

We are committed to protecting the security of the personal information collected, and we take reasonable physical, electronic, and administrative safeguards to help protect the information from unauthorized or inappropriate access or use.

Effective Date: 01/01/2023