Privacy Policy

Fortuna Health, Inc. ("Fortuna," "us" or "we") takes your privacy very seriously. We created this Privacy Policy to provide you with important information about the privacy practices applicable to the services provided by us through the Fortuna website at https://www.fortunahealth.com/ (the "Website") and access Fortuna's services (the "Services"). This Privacy Policy describes how we collect, protect, use, disclose and store the information collected through the Services.

BY DOWNLOADING, ACCESSING, OR USING THE WEBSITE OR SERVICES, AND/OR BY REGISTERING WITH US OR PROVIDING INFORMATION TO US IN CONNECTION WITH THE SERVICES, YOU ACCEPT THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY, AND YOU HEREBY CONSENT THAT WE WILL COLLECT, USE, AND SHARE YOUR INFORMATION AS SET FORTH IN THIS PRIVACY POLICY. IF YOU ARE REGISTERING AN ACCOUNT OR USING THE SERVICES ON BEHALF OF AN INDIVIDUAL OTHER THAN YOURSELF, YOU REPRESENT THAT YOU ARE AUTHORIZED TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL'S BEHALF.

Your use of the Services is also subject to our Terms of Service, which are available here.

COLLECTION, USE, AND DISCLOSURE OF INFORMATION

What is Personal Information?

Personal Information is any information relating to a natural person who is, or can be, identified either directly or indirectly from such information and includes information such as a user's name, address, telephone number, email address, Internet activity (such as browsing history), or other information directly linked to that person. Personal Information that we collect also includes the personal medical information which users provide to us through the Services. You are not legally required to provide Personal Information to us, but if you refuse to provide such information, we may not be able to register you to use the Services.

Information that We Collect

Fortuna collects Personal Information from users when such users (or such users' legal guardians) register for and use the Services. You don't have to use the Website and Services, but if you do, you acknowledge that Fortuna collects and uses your Personal Information for the legitimate interests and purposes described in this Privacy Policy. Fortuna collects the following types of Personal Information which you provide to us:

• Basic registration information related to users, including name, contact information, and language preference;
• Financial-related information, including income;
• Demographic information, such as your citizenship status and household information;
• Records and copies of your correspondence (including email addresses), if you contact us; and
• Details of transactions you carry out through our Website.

In addition, from time to time, we may use or augment the Personal Information we have about you with information obtained from other sources, such as your treating providers, your health plan, and other third parties.

In addition to collecting Personal Information that you provide to us, we may automatically collect certain Personal Information when you access the Website, such as IP address, information about your browser, device or operating system or similar information. IP addresses are ID numbers for the location of your computer or network on the internet. Log files are recordings of the traffic to and from a server. Fortuna servers log IP addresses for systems administration and troubleshooting. We track page hits in the aggregate to track the popularity of pages that people visit. With that information we can improve the quality of our Website. We may also use or allow third parties to use web beacons on our Website to monitor the effectiveness of survey qualification. Web beacons are small, graphic images on web pages, web-based documents, or in email messages that allow us or third parties to monitor who is visiting our Website or if an email has been read. Web beacons collect the IP address of the device where the web beacon is sent, the URL of the page where the web beacon originates, and the time it was viewed. Web beacons may be linked to your Personal Information. We may also use third-party devices, services, links, or electronic mail to deliver surveys to you, which may use cookies, web beacons, or other technology to collect information about your visits to our Website in order to present surveys that may be of interest to you.

How We May Use Personal Information

We and our third-party service providers may use Personal Information to:

• respond to your inquiries and fulfill the purposes for which the Personal Information was provided;
• communicate with your health plan, the state Medicaid agency, or your health care providers regarding the status of your Medicaid eligibility and/or enrollment;
• send to you administrative information, including information regarding the Services, and changes to our terms, conditions and policies;
• send to you marketing communications that we believe may be of interest to you;
• personalize your experience on the Website;
• further our business purposes, such as quality assessment, data analysis, audits, developing new products, enhancing the Website, improving our Services, identifying usage trends to inform members of the Fortuna community which aspects of the Services might be useful to them, and determining the effectiveness of our promotional campaigns; and
• act as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public or government authorities; (d) to enforce our Terms of Service; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; (g) at our discretion under emergency circumstances, to notify emergency services or your family members, personal representative or other individuals involved in your care of your location and condition; or (h) to allow us to pursue available remedies or limit the damages that we may sustain.

Our use of your Personal Information may also be subject to certain restrictions set forth in an agreement between us and your Provider.

We may also use aggregate or de-identified data that is not personally identifiable for any legally permissible purposes without restriction.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed to:

• our third-party service providers that provide services such as hosting of the Website, data analysis, IT services and infrastructure, customer service, e-mail delivery, auditing and other similar services;
• our affiliates, for the purposes described for Personal Information in this Privacy Policy, including marketing purposes relating to their products and services;
• third parties, to permit them to send marketing communications to you regarding our Services;
• for other treatment, payment or health care purposes of your health care provider or health plan;
• a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, liquidation or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding); and
• a third party as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public or government authorities; (d) to enforce the Terms of Service; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; (g) at our discretion under emergency circumstances, to notify emergency services or your family members, personal representative or other individuals involved in your care of your location and condition; or (h) to allow us to pursue available remedies or limit the damages that we may sustain.

Fortuna does not sell or rent Personal Information that we have collected or retained about you to any other third-party for any purpose. Accordingly, we do not offer individuals the ability to "opt-out" of the selling or renting of Personal Information because we do not engage in those practices.

We may also disclose to third parties aggregate or de-identified data that is not personally identifiable for any legally permissible purposes.

COOKIES

A cookie is a small piece of information that a website can store on a computer and sometimes later use to recognize a user. The purpose of cookies is to enhance your ability to receive the information you want. In the future, we may use cookies to enhance the experience of users. A "session" cookie expires when the user closes the browser in which the website was viewed. A "persistent" cookie may be used to help save your settings and customizations. As with all cookies, you can personalize you web browser settings to reject session cookies. Though some cookies, that are strictly necessary for site operation, cannot be toggled off.

Some of our business partners with whom we contract to carry out the Services may use their cookies on our Website. Although we may not have direct access to or control over such cookies, this Privacy Policy governs the use of cookies by us and such business partners on our Website.

THIRD PARTIES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including the manufacturer of your computer or mobile device, or any other third party mobile application or website to which the Website may contain a link. We encourage you to review the Notice of Privacy Practices of each health plan and/or health care provider who provides you with services and the privacy policies of each website and application you visit and use.

HIPAA

Fortuna may contract with health plans and health care providers to provide Fortuna's Services. In such cases, Fortuna is regulated as a "business associate" under the Health Insurance Portability and Accountability Act ("HIPAA"). Our uses and disclosures of any protected health information ("PHI") we collect pursuant to these relationships will be governed by HIPAA and our agreements with such health plans and/or health care providers, as applicable.

Fortuna may require certain PHI about you in order to provide you with the Services. Please note that, as part of Fortuna's Services, you and Fortuna will need to transmit PHI to one another. You acknowledge and agree that Fortuna may send Personal Information constituting PHI to you via email or text, which are not secure methods of communication. Please notify Fortuna if you do not wish to transmit or receive PHI through these methods, and Fortuna will arrange for an alternative secure method of communication. You may also send PHI to Fortuna via the secure chatbox functionality on our Website.

CHILDREN'S PRIVACY

Fortuna is concerned about the safety and privacy of children online. Because of this, we will make all efforts to comply with the Children's Online Privacy Protection Act of 1998 ("COPPA"). COPPA and its accompanying FTC regulations establish United States federal law that protects the privacy of children using the internet. Further, our Website is not intended for minors. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will use commercially reasonable efforts to delete that information. If you want to notify us of our unauthorized receipt of information by minors, including children under 13, please email info@fortunahealth.com.

SECURITY

We seek to use reasonable physical, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system is 100% secure, and therefore we cannot guarantee against all potential security breaches. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the "Contacting Us" section below.

STORAGE OF DATA

We will only store Personal Information for as long as it is needed to fulfill the purposes for which it was collected, subject to applicable data retention periods imposed upon us by applicable law. This may mean that your Personal Information is stored by us for a number of years, depending on the purpose and need for that data to be processed.

UPDATES TO THIS PRIVACY POLICY

We may occasionally update this Privacy Policy at any time. Any changes to this Privacy Policy will become effective when we make the revised Privacy Policy available through the Website. We will update the "Effective Date" date at the top of this Privacy Policy if we make any such changes to this Privacy Policy. Your use of the Website or the submission of any information in connection with the Website following any change means that you accept the revised Privacy Policy. We encourage you to periodically review this Privacy Policy to stay informed about how we collect, use, and disclose personally identifiable information.

CONTACTING US

If you have any questions or comments about this Privacy Policy, please contact us by e-mail at info@fortunahealth.com.