Asset Health: Your Health Is Your Most Valuable Asset

Asset Health ("Us," "We," or "Our") created this Privacy Policy ("Privacy Policy") to ensure the confidence of users ("you" or "your") of our Asset Health software program and website (collectively, the "Product"), and to demonstrate our commitment to fair information practices and the protection of privacy.

1. Types of Information Collected.

a. Traffic Data Collected. We automatically track and collect the following information when you use our Product, including your: (i) IP address; (ii) domain server; (iii) type of computer; (iv) type of web browser; and (v) information on your usage of the Product, including Courses completed or not completed and your performance on our Assessments (collectively, "Traffic Data"). Traffic Data is anonymous information associated with you that identifies you and is helpful for reporting purposes or for improving your experience with the Product.

b. Personal Information Collected. In order for you to access the Products, we require you to provide us with information that personally identifies you ("Personal Information"). Personal Information may include: (i) Contact Data (such as your name and email addresses); and (ii) Demographic Data (such as your ZIP code). If you communicate with us by email, post messages to any of our chat groups, or otherwise complete online forms or surveys, any information provided in such communication may be collected as Personal Information.

2. Uses of Information Collected.

We use Contact Data to contact you if necessary.

3. Confidentiality and Security of Personal Information.

Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce our Terms of Use Agreement. Your Personal Information is stored on secure servers that are not accessible by third parties. We will never disclose the entries to your personal online "Journal" to any third parties. Only you and the Asset Health staff will have access to these entries. The Asset Health staff has access to these entries solely for the purpose of properly administering the Product.

4. Lost or Stolen Information.

You must promptly notify us if your user name or password is lost, stolen or used without permission. In such an event, we will cancel that user name or password, issue you a new user name and password, and update our records accordingly.

5. Other Limits to Your Privacy.

The Product contains links to other websites. We are not responsible for the privacy practices or the content of such websites. We may also make chat rooms, news and other services available to you. Understand that any Information you disclose in these areas becomes public information. We have no control over its use, and you should exercise caution when deciding to disclose your Personal Information.

6. Updates and Changes to Privacy Policy.

We reserve the right, at any time and without notice, to add, change, update or modify this Privacy Policy simply by posting such change, update or modification on our website. Any such change, update or modification will be effective immediately upon posting on our website.

IMPORTANT: THIS ASSET HEALTH (“ASSET HEALTH”) TERMS OF USE (“AGREEMENT”) IS A LEGAL AGREEMENT BETWEEN YOU AND ASSET HEALTH THAT PROVIDES THE TERMS AND CONDITIONS FOR YOUR USE OF ASSET HEALTH’S ONLINE APPLICATION (“APPLICATION”), COURSES, THE AFFILIATED WEBSITE (“USER SITE”) AND ANY RELATED SOFTWARE, MATERIALS AND/OR DOCUMENTATION (COLLECTIVELY, THE “SERVICE”). BY ACCEPTING THIS AGREEMENT, YOU ARE CONFIRMING YOUR ACCEPTANCE OF THE AGREEMENT AND AGREE TO BECOME BOUND BY THIS AGREEMENT. IF YOU DO NOT AGREE TO BE BOUND BY THIS AGREEMENT, THEN DO NOT ACCEPT THIS AGREEMENT AND YOU WILL NOT RECEIVE ACCESS TO THE SERVICE.

1. The Service.

1.1 Asset Health grants you a non-transferrable right to use the Service subject to the terms of the agreement between Asset Health and your employer. By clicking on “I Agree”, you agree to be bound by any and all license agreements that your employer has entered into with Asset Health.

1.2 To provide you with the most current version of the Service, Asset Health reserves the right to update, upgrade, or otherwise change the Service and any Applications at any time. By clicking on “I Agree”, you signify that you understand and agree that such updates, upgrades or other changes may occur from time to time during your use of the Service and Applications without prior notice to you.

2. Access to the Service and Security.

2.1 Asset Health will create an account, with an associated password, through which you may access the Service based on the actual Services purchased by your employer. The date you are provided with such password shall be the Service Activation Date. You may access the Site either through a web browser or, as applicable, through certain other Applications.

2.2 Other than distribution of the initial password for access to the Service, Asset Health will have no obligation or responsibility with regard to the use, distribution or management of such passwords. You agree to notify Asset Health immediately if you suspect any unauthorized use of the Service, User Site or related passwords.

2.3 You acknowledge and agree that there is a strict limit of one user per account on any and all Asset Health Applications. In addition, you may not share or disclose your username or password.

2.4 Children under the age of 13 are not permitted to use the Service and we do not intentionally collect or maintain Personal Information from those who are under 13 years old. Protecting the privacy of children is very important to us. Thus, if we obtain actual knowledge that a user is under 13, we will take steps to remove that user's Personal Information from our databases. We recommend that children between the ages of 13 and 18 obtain their parent's permission before submitting information over the internet. By using the Service, you are representing that you are at least 18 years old, or that you are at least 13 years old and have your parents' permission to use the Service.

3. Restrictions and Prohibited Acts. As a condition of your use of the Service, you will not use the Service for any purpose that is unlawful or prohibited by this Agreement. You may not use the Service in any manner that could damage, disable, overburden, or impair any Asset Health server, or the network(s) connected to any Asset Health server, or interfere with any other party's use and enjoyment of the Service. You may not attempt to gain unauthorized access to services, materials, other accounts, computer systems or networks connected to any Asset Health server or to the website, through hacking, password mining or any other means. You may not obtain or attempt to obtain any materials or information through any means not intentionally made available through the Service. You may not use the Service, including any Application, on a timeshare or service bureau basis. In addition, you may not access or use the Service or distribute or display Content in any manner that:

3.1 Violates any laws or regulations or is not for a legitimate business purpose;

3.2 Introduces a virus, worm, Trojan horse or other harmful software code;

3.3 Consumes excessive CPU time, bandwidth, memory storage space, or any other system or network resources;

3.4 Engages in any systematic extraction of data or data fields, including without limitation email addresses;

3.5 Exposes Asset Health to adverse publicity;

3.6 Infringes or violates the copyright, patent, trademark, service mark, trade name, trade secret or other intellectual property rights of any third party or Asset Health;

3.7 Discloses or collects personally identifying information or private information about any third party without that party's consent (or parental consent in the case of a minor);

3.8 Transmits, promotes, solicits or comprises harassing, abusive, threatening, obscene, vulgar, libelous, pornographic or otherwise objectionable or unlawful content or activity;

3.9 Attempts to mislead others about your identity or the origin of a message or other communication, or impersonates or otherwise misrepresents your affiliation with any other person or entity;

3.10 Transmits junk mail, spam, chain letters, or other unsolicited email or duplicative messages;

3.11 Sells, leases, or rents access to or use of the Service;

3.12 Advocates, promotes, incites, instructs, informs, assists or otherwise encourages violence or any high-risk activity where damage or injury to persons, property, environment or business may result;

3.13 Designs, develops, or creates a competitive product or service to Asset Health's products and services;

3.14 Links to content that promotes any of the above; or

3.15 Asset Health, using commercially reasonable judgment, finds objectionable.

4. Privacy. Asset Health's privacy policy, available on our website is hereby incorporated into the Agreement by reference.

5. Term/Termination.

5.1 Term. This Agreement shall become effective when you electronically register your acceptance of this Agreement by either clicking “I Agree” or by registering for and using the Service. The Term of this Agreement shall commence on the Service Activation Date and will continue in effect until the Service Term expires.

5.2 Termination by Asset Health. Asset Health may at any time terminate the Service and this Agreement, or suspend or restrict your access to the Service in whole or in part, if:

5.2.1 Asset Health determines in its sole and exclusive judgment that terminating your Service is advisable for security reasons, to protect Asset Health from liability, or for the continued normal and efficient operation of the Service.

5.3 Upon termination of Service, all rights granted to you under this Agreement and any Application License Agreement will terminate immediately. Asset Health reserves the right to delete any data files associated with your use of the Service upon termination of the Service.

6. Proprietary Rights.

6.1 You acknowledge and agree that Asset Health and its licensors own all right, title, and interest in: (a) the Service; (b) the Applications; (c) the User Site; (d) and any other Asset Health software. In addition, you acknowledge that the Service, the Applications, the User Site and any other Asset Health software are protected by United States and international copyrights, trademarks, patents and other proprietary rights and laws. You may not decompile, reverse engineer, decode or otherwise examine the internal functioning of the Service, the Applications, the User Site or any Asset Health software, including the embedded Asset Health Flash Player in Application-generated converted files, and may not make, use, sell, copy, reproduce, distribute, transmit, or create derivative works from the Service, the Application and any other Asset Health software without Asset Health's prior written consent.

6.2 You are welcome to send suggestions on improving the Service, but in doing so, you acknowledge and agree that such suggestions will become the property of Asset Health without obligation to compensate you.

6.3 You agree and authorize Asset Health to disclose any non-identifiable health or other information that you provide to Asset Health to third parties who may use such information only for purposes of research.

7. Websites Links. Asset Health may provide links to other websites or resources as part of the Service only as a convenience to you. Asset Health is not responsible for the contents, products or services on any third party site and the inclusion of any link does not imply that Asset Health endorses the content on such third party sites. You are visiting such third party sites solely at your own risk.

8. Warranty Disclaimers.

8.1 EXCEPT FOR THE LIMITED WARRANTY SET FORTH IN SECTION 8 (“SERVICE LEVEL AGREEMENT”), THE SERVICE AND THE APPLICATIONS ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. TO THE FULL EXTENT PERMITTED BY LAW, ASSET HEALTH, ITS AFFILIATES, CONTRACTORS, SERVICE PROVIDERS, EMPLOYEES, AGENTS, LICENSORS, AND ANY OTHER PARTY INVOLVED IN CREATING, PRODUCING OR DELIVERING THE SERVICE AND THE APPLICATIONS DISCLAIM ALL WARRANTIES AND REPRESENTATIONS OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING ALL WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT. WITHOUT LIMITING THE FOREGOING, ASSET HEALTH DOES NOT WARRANT OR REPRESENT THAT THE SERVICE WILL BE CONTINUOUS, ACCESSIBLE, UNINTERRUPTED OR ERROR-FREE, OR THAT OUR SERVERS AND SOFTWARE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS, OR THAT ASSET HEALTH'S SECURITY PROCEDURES AND MECHANISMS WILL PREVENT THE LOSS OR ALTERATION OF OR IMPROPER ACCESS TO USER INFORMATION BY THIRD PARTIES.

8.2 THE SECURITY MECHANISMS INCORPORATED IN THE SERVICE HAVE INHERENT LIMITATIONS AND YOU MUST DETERMINE THAT THE SERVICE ADEQUATELY MEETS YOUR REQUIREMENTS. YOU ACKNOWLEDGE AND AGREE THAT ANY MATERIAL AND/OR DATA DOWNLOADED OR OTHERWISE OBTAINED THROUGH THE USE OF THE SERVICE IS DONE AT YOUR OWN DISCRETION AND RISK AND THAT YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGES TO YOUR COMPUTER SYSTEM OR LOSS OF DATA THAT RESULTS FROM YOUR USE OF THE SERVICE. NO ORAL OR WRITTEN INFORMATION OR ADVICE GIVEN BY ASSET HEALTH, ITS DEALERS, DISTRIBUTORS, AGENTS OR EMPLOYEES SHALL CREATE A WARRANTY OR IN ANY WAY INCREASE THE SCOPE OF ANY WARRANTY PROVIDED HEREIN.

8.3 SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES, SO THE ABOVE EXCLUSION MAY NOT APPLY TO YOU. THIS WARRANTY GIVES YOU SPECIFIC LEGAL RIGHTS AND YOU MAY ALSO HAVE OTHER LEGAL RIGHTS THAT VARY FROM STATE TO STATE.

9. Limitation of Liability.

9.1 NEITHER ASSET HEALTH NOR ITS SUPPLIERS SHALL BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, PUNITIVE, COVER OR CONSEQUENTIAL DAMAGES (INCLUDING, BUT NOT LIMITED TO, DAMAGES FOR THE INABILITY TO USE THE SERVICE OR ACCESS DATA, LOSS OF BUSINESS, LOSS OF PROFITS, BUSINESS INTERRUPTION OR THE LIKE), ARISING OUT OF THE USE OF, OR INABILITY TO USE, THE SERVICE OR ANY APPLICATION AND BASED ON ANY THEORY OF LIABILITY INCLUDING STATUTE, BREACH OF CONTRACT, BREACH OF WARRANTY, TORT (INCLUDING NEGLIGENCE), PRODUCT LIABILITY OR OTHERWISE, EVEN IF ASSET HEALTH OR ITS REPRESENTATIVES HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES AND EVEN IF A REMEDY SET FORTH HEREIN IS FOUND TO HAVE FAILED OF ITS ESSENTIAL PURPOSE.

9.2 THE LIMITATIONS ON LIABILITY IN THIS SECTION ARE INTENDED TO APPLY TO THE WARRANTIES AND DISCLAIMERS ABOVE AND ALL OTHER ASPECTS OF THIS AGREEMENT. SOME JURISDICTIONS DO NOT ALLOW THE LIMITATION OR EXCLUSION OF LIABILITY FOR INCIDENTAL OF CONSEQUENTIAL DAMAGES, SO THE ABOVE LIMITATION OR EXCLUSION MAY NOT APPLY TO YOU AND YOU MAY ALSO HAVE OTHER LEGAL RIGHTS THAT VARY FROM STATE TO STATE.

9.3 THE CONTENT CONTAINED IN THE SERVICE, APPLICATIONS, USER SITE AND ANY OTHER ASSET HEALTH SOFTWARE, INCLUDING BUT NOT LIMITED TO TEXT, GRAPHICS, IMAGES, AUDIO, VIDEO, ANIMATIONS, ETC. (“CONTENT”) ARE FOR INFORMATIONAL PURPOSES ONLY. THE CONTENT IS NOT INTENDED TO BE A SUBSTITUTE FOR PROFESSIONAL MEDICAL ADVICE, DIAGNOSIS OR TREATMENT; NOR IS IT A REPLACEMENT FOR FINANCIAL OR BENEFITS ADVICE THAT YOU MAY RECEIVE FROM YOUR HUMAN RESOURCES DEPARTMENT OR PERSONAL FINANCIAL ADVISOR. THE INDIVIDUALS THAT APPEAR IN THE COURSE VIDEOS ARE ACTORS AND NOT MEDICAL PROFESSIONALS. YOU SHOULD ALWAYS SEEK THE ADVICE OF YOUR PHYSICIAN OR OTHER QUALIFIED HEALTH PROVIDER WITH ANY QUESTIONS YOU MAY HAVE REGARDING A MEDICAL CONDITION; YOU SHOULD ALWAYS SEEK THE ADVICE OF YOUR HUMAN RESOURCES DEPARTMENT OR PERSONAL FINANCIAL ADVISOR WITH ANY QUESTION YOU MAY HAVE REGARDING HEALTH CARE BENEFITS OR FINANCIAL-RELATED HEALTH CARE ISSUES. ASSET HEALTH IS NOT IN THE BUSINESS OF PROVIDING MEDICAL, HEALTH CARE, OR FINANCIAL ADVICE. RELIANCE ON ANY CONTENT IS SOLELY AT YOUR OWN RISK.

10. Miscellaneous. This Agreement is governed by and construed in accordance with the laws of the State of Michigan, excluding conflict of law provisions. You agree to submit to the exclusive jurisdiction of the courts of the State of Michigan and the United States federal district court located in Wayne County, Michigan. You are solely responsible for your familiarity and compliance with any laws that may prohibit your participation in or use of any part of the Service. This Agreement constitutes the entire agreement between you and Asset Health and supersedes all prior agreements, representations and understandings between the parties regarding the subject matter contained herein. If any provision of this Agreement is held to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties, and all other provisions will remain in full force and effect. Asset Health's failure to exercise or enforce any right or provision of this Agreement shall not constitute a waiver of such right or provision unless acknowledged and agreed to by Asset Health in writing. From time to time, Asset Health may be required to update or modify this Agreement and shall provide you notice of such modifications; provided, however, your use of the Service after such notice shall constitute acceptance of the new Agreement. Your rights hereunder may not be assigned or transferred to any third party without the written consent of Asset Health. Each party will provide the other with written notice under this Agreement by sending the other party notice as follows: for you, notice will be sent to the address and contact person for your account and for Asset Health, notice will be sent to Asset Health, 2250 Butterfield Dr., Ste. 100, Troy, MI 48084 Attention: General Counsel.

NOTICE REGARDING SouthernLifeStyle

SouthernLifeStyle is a voluntary wellness program available to eligible employees. ⁱ The program is administered according to federal rules permitting employer-sponsored wellness programs that seek to improve employee health or prevent disease, including the Americans with Disabilities Act of 1990, the Genetic Information Nondiscrimination Act of 2008, and the Health Insurance Portability and Accountability Act, as applicable, among others. If you choose to participate in the wellness program, you will be given the opportunity to report that you completed a medical examination (a physical) and, depending on your employing company, to complete a biometric screening (a lab screening), which will include a blood test for blood cell count (an indicator of anemia and infection), glucose level, total cholesterol, HDL, LDL and triglycerides.

You are not required to participate in the lab screening or receive a physical examination. However, employees who choose to participate in the wellness program by recording the completion of the physical and lab screening (depending on your employing company) in your SouthernLifeStyle Rewards account by the end of the year, will receive either a premium credit or premium holiday the following year, as follows:

Incentive		Wellness Activity
APC / SCS-AL	Premium holiday (2 months if employee only & 1 month if family coverage)	Physical
GPC/ SCS-GA / SPC / So LINC	$240 premium credit	Physical & Lab Screening
GAS	Premium credit ($130 employee or spouse/DP; $260 employee and spouse/DP)	Physical & Biometric Health Screening
MPC / SCS-MS	$240 premium credit	Physical
SNC (AL)	Lump sum credit ($140 employee or spouse/DP; $250 employee & spouse/DP)	Physical
SNC (GA)	$240 premium credit	Physical

Although you are not required to participate in the lab screening or receive a physical examination, only employees who do so will receive the incentives described above.

The information from your lab screening will be used to provide you with information to help you understand your current health and potential risks, and may also be used to offer you services through the wellness program, such as the opportunity to discuss your results with a nurse (depending on your employing company) and to receive health-management services through the wellness program. You also are encouraged to share your results or concerns with your own doctor.

Additional incentives may be available for employees who participate in certain health-related activities (e.g., report your physical activity, health screenings, weight and waist circumference) or achieve certain health outcomes (e.g., reduce your cholesterol or blood pressure). If you enroll in a Southern Company-sponsored medical benefit option, you can earn dollars in a Health Reimbursement Account or a Health Savings Account for completing health-related activities. The maximum incentive is $520 per year for employees and $270 per year for your spouse or domestic partner who completes health-related activities. If you do not enroll in a Southern Company-sponsored medical benefit option but are eligible to participate in the Health Care Flexible Spending Account (FSA), you can receive up to $270 per year in a FSA for completing health-related activities.

If you are unable to participate in any of the health-related activities or achieve any of the health outcomes required to earn an incentive, you may be entitled to a reasonable accommodation or an alternative standard. You may request a reasonable accommodation or an alternative standard by contacting the Wellness Coordinator at your employing company.

Protections from Disclosure of Medical Information
We are required by law to maintain the privacy and security of your personally identifiable health information. Although the wellness program and Southern Company may use aggregate information it collects to design a program based on identified health risks in the workplace, SouthernLifeStyle will never disclose any of your personal information either publicly or to your employer, except as necessary to respond to a request from you for a reasonable accommodation needed to participate in the wellness program, or as expressly permitted by law. Medical information that personally identifies you that is provided in connection with the wellness program will not be provided to your supervisors or managers and may never be used to make decisions regarding your employment.

Your health information will not be sold, exchanged, transferred, or otherwise disclosed except to the extent permitted by law to carry out specific activities related to the wellness program, and you will not be asked or required to waive the confidentiality of your health information as a condition of participating in the wellness program or receiving an incentive. Anyone who receives your information for purposes of providing you services as part of the wellness program will abide by the same confidentiality requirements. The only individuals who will receive your personally identifiable health information are your health care providers and Asset Health, Inc. (the company that administers the wellness program) in order to provide you with services under the wellness program.

In addition, all medical information obtained through the wellness program will be maintained separate from your personnel records, information stored electronically will be encrypted, and no information you provide as part of the wellness program will be used in making any employment decision. Appropriate precautions will be taken to avoid any data breach, and in the event of a data breach involving information you provide in connection with the wellness program, we will notify you promptly.

You may not be discriminated against in employment because of the medical information you provide as part of participating in the wellness program, nor may you be subjected to retaliation if you choose not to participate.

If you have questions or concerns regarding this notice, or about protections against discrimination and retaliation, please contact HR Direct at 1-888-678-6787.

ⁱ You are eligible for the SouthernLifeStyle wellness program if you are employed as a regular full-time, regular part-time employee, or co-op employee of Alabama Power Company, Georgia Power Company, Gulf Power Company, Mississippi Power Company, Southern Communications Services, Southern Company Services, Southern Nuclear Operating Company, or Southern Power Company.

THIS NOTICE DESCRIBES HOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW THIS NOTICE CAREFULLY.

Notice of Privacy Practices, updated and effective July 1, 2025.

This Notice has been drafted to comply with the “HIPAA Privacy Rules,” under federal law. Any terms that are not defined in this Notice have the meaning specified in the HIPAA Privacy Rules.

Please provide this Notice to your family.

ATTENTION: If you speak a language other than English, language assistance services that are free of charge are available to you. Contact your employer’s Human Resources department to request these services. Asset Health’s Customer Support also can assist in connecting you to your Wellness Plan sponsor’s translation service.

How We Protect Your Privacy

We are required by law to protect the privacy of your protected health information (PHI) and to provide you with this notice of our privacy practices. We will not disclose confidential information without your authorization unless it is necessary to provide your health benefits and administer the Plan(s), or as otherwise required or permitted by law. When we need to disclose individually identifiable information, we will follow the policies described in this Notice to protect your confidentiality.

We maintain confidential information and have procedures for accessing and storing confidential records. We restrict internal access to your confidential information to employees who need that information to provide your benefits. We train those individuals on policies and procedures designed to protect your privacy. Our Privacy Officer monitors how we follow those policies and procedures, and educates our organization on this important topic.

How We May Use and Disclose Your Protected Health Information

We will not use your confidential information or disclose it to others without your written authorization, except for the purposes, listed in this section. When required by law, we will restrict disclosures to the Limited Data Set, or otherwise as necessary, to the minimum necessary information to accomplish the intended purpose.

Treatment. We may disclose your PHI to your health care provider for the provision, coordination or management of your health care and related services. For example, we may disclose your PHI to a health care provider when the provider needs that information to provide treatment to you.

Disclosures to the Plan Sponsor. We may only disclose aggregate summary health information to the Plan Sponsor, but not personally identifiable information.

Disclosures to Business Associates. We contract with individuals and entities (“business associates”) to perform various functions on our behalf or provide certain types of services. To perform these functions or provide these services, our business associates will receive, create, maintain, use or disclose PHI. We require the business associates to agree in writing to contract terms to safeguard your information, consistent with federal law.

Disclosures to Family Members or Others. Unless you object, we may provide relevant portions of your PHI to a family member, friend or other person you indicate is involved in your health care. If you are not capable of agreeing or objecting to these disclosures because of, for example, an emergency situation, we will disclose limited PHI, only to resolve the emergency. After the emergency, we will give you the opportunity to object to future disclosures to family and friends.

Other Uses and Disclosures. The law allows us to disclose PHI without your prior authorization in the following circumstances:

Required by law. We may use and disclose your PHI to comply with the law.

Public health activities. We will disclose PHI when we report to a public health authority for purposes such as public health surveillance, public health investigations or suspected child abuse.

Reports about victims of abuse, neglect or domestic violence. We will disclose your PHI in these reports only if we are required or authorized by law to do so, or if you otherwise agree.

To health oversight agencies. We will provide PHI as requested to government agencies that have the authority to audit or investigate our operations.

Lawsuits and disputes. If you are involved in a lawsuit or dispute, we may disclose your PHI in response to a subpoena or other lawful request, but only if efforts have been made to tell you about the request or obtain a court order that protects the PHI requested.

Law enforcement. We may release PHI if asked to do so by a law enforcement official in the following circumstances: (a) to respond to a court order, subpoena, warrant, summons or similar process; (b) to identify or locate a suspect, fugitive, material witness or missing person; (c) to assist the victim of a crime if, under certain limited circumstances, we are unable to obtain the person's agreement; (d) to investigate a death we believe may be due to criminal conduct; (e) to investigate criminal conduct; and (f) to report a crime, its location, or victims, or the identity, description or location of the person who committed the crime (in emergency circumstances).

Medical research. We may disclose PHI for medical research projects, subject to strict legal restrictions.

Serious threat to health or safety. We may disclose your PHI to someone who can help prevent a serious threat to your health and safety or the health and safety of another person or the general public.

Uses and Disclosures With Your Written Authorization

We will not use or disclose your confidential information for any purpose other than the purposes described in this Notice, without your written authorization. For example, we will not 1) supply confidential information to another company for its marketing purposes, 2) sell your confidential information, or 3) provide your confidential information to a potential employer with whom you are seeking employment, without your signed authorization. You may revoke an authorization that you previously have given by sending a written request to our Privacy Officer, but not with respect to any actions we already have taken.

Your Individual Rights
You have the following rights:

Right to inspect and copy your protected health information. Except for limited circumstances, you may review and copy your PHI. Your request must be addressed to the Privacy Officer. In certain situations we may deny your request, but if we do, we will tell you in writing of the reasons for the denial and explain your rights with regard to having the denial reviewed. If the information you request is in an electronic health record, you may request that these records be transmitted electronically to yourself or a designated individual.

If you request copies of your PHI, we may charge you a reasonable fee to cover the cost. Alternately, we may provide you with a summary or explanation of your PHI, upon your request, if you agree to the rules and cost (if any) in advance.

In the event your employer, as sponsor of its wellness plan, terminates the services of Asset Health, pursuant to our contractual requirements and the governing HIPAA and HITECH regulations, Asset Health is required to proceed with deidentification of and ultimate destruction of your PHI securely stored by Asset Health.

Right to correct or update your protected health information. If you believe that the PHI we have is incomplete or incorrect, you may ask us to amend it. Your request must be made in writing and must be addressed to the Privacy Officer. To process your request, you must use the form we provide and explain why you think the amendment is appropriate. We will inform you in writing whether the amendment will be made or denied. If we agree to make the amendment, we will make reasonable efforts to notify other parties of your amendment. If we agree to make the amendment, we will also ask you to identify others you would like us to notify.

We may deny your request if you ask us to amend information that:

Was not created by us, unless the person who created the information is no longer available to make the amendment;
Is not part of the PHI we keep about you;
Is not part of the PHI that you would be allowed to see or copy; or
Is determined by us to be accurate and complete.

If we deny the requested amendment, we will notify you in writing how to submit a statement of disagreement or complaint, or request inclusion of your original amendment request as part of your PHI.

Right to obtain a list of the disclosures. You have the right to get a list of PHI disclosures, which also is referred to as an accounting. You must make a written request to the Privacy Officer to obtain this information.

The list will not include disclosures we have made as authorized by law. For example, the accounting will not include disclosures made for treatment, payment and health care operations purposes (except as noted in the following paragraph). Also, no accounting will be made for disclosures made directly to you or under an authorization that you provided or those made to your family or friends. The list will not include other disclosures, including incidental disclosures, disclosures we have made for national security purposes, disclosures to law enforcement personnel, or disclosures made before April 14, 2003. The list we provide will include disclosures made within the last six years unless you specify a shorter period.

You may also request and receive an accounting of disclosures of electronic health records made for payment, treatment or health care operations during the prior three years for disclosures made on or after 1) January 1, 2014, for electronic health records acquired before January 1, 2009, or 2) January 1, 2011, for electronic health records acquired on or after January 1, 2009.

The first list you request within a 12-month period will be free. You may be charged for any additional lists within a 12-month period.

Right to choose how we communicate with you. You have the right to ask that we send information to you at a specific address (for example, at work rather than home) or in a specific manner (for example, by email rather than regular mail). We must agree to your request if you state that disclosure of the information may put you in danger.

Right to request additional restrictions on health information. You may request restrictions on our use and disclosure of your confidential information for the treatment, payment and health care operations purposes explained in this Notice. While we will consider all requests for restrictions carefully, we are not required to agree to a requested restriction. However, we must comply with your request to restrict a disclosure of your confidential information for payment or health care operations if you paid for these services in full, out of pocket.

Questions and Complaints

If you believe your privacy rights have been violated, you may file a complaint with us or the U.S. Department of Health and Human Services. To file a complaint with us, put your complaint in writing and address it to the Privacy Officer listed below. The Plan(s) will not retaliate against you for filing a complaint. You may also contact the Privacy Officer if you have questions or comments about our privacy practices.

Future Changes to Our Practices and This Notice

We are required to follow the terms of the privacy notice currently in effect. However, we reserve the right to change our privacy practices and make any such change applicable to the PHI we obtained about you before the change. If a change in our practices is material, we will revise this Notice to reflect the change. We will send or provide a copy of the revised Notice. You may also obtain a copy of any revised Notice by contacting the Privacy Officer.

Contact Information

John J. Wilson
General Counsel
Asset Health
2250 Butterfield Drive, Suite 210
Troy, MI 48084
(248) 822-7441
jwilson@assethealth.com

Notice Regarding Your Wellness Program

If you choose to participate in the wellness program, you may be asked to complete a voluntary Health Assessment (HA) — also referred to as a Health Risk Assessment (HRA), Health Risk Questionnaire (HRQ), Wellness Assessment (WA), Personal Health Assessment (PHA), or Health Behavior Questionnaire (HBQ) — that asks a series of questions about your health-related activities and behaviors and whether you have or had certain medical conditions (e.g., cancer, diabetes, heart disease). You may also be asked to complete a biometric screening (which will include a blood test) for various biometric measurements, e.g., BMI, blood pressure, glucose, etc. You are not required to complete the HA, biometric screening or other medical examinations.

However, eligible individuals who choose to participate in the wellness program may receive an incentive for completing the HA and/or participating in the biometric screening. Although you are not required to complete the HA or biometric screening, only eligible individuals who do so will receive any available incentives.

Additional incentives may be available for individuals who participate in certain health-related activities or achieve certain health outcomes, e.g., weight loss, smoking cessation, lower blood pressure, etc. If you are unable to participate in any of the health-related activities, or achieve any of the health outcomes required to earn an incentive, you are entitled to a reasonable accommodation or an alternative standard. You may request a reasonable accommodation or an alternative standard by contacting your wellness program administrator or Human Resources department.

The information from your HA and biometric screening will help you understand your current health and potential risks, and may also be used to offer you services through the wellness program, such as coaching, iKnowledge (online wellness) courses, etc. You also are encouraged to share your results or concerns with your personal health care provider.

Protections from Disclosure of Medical Information

We are required by law to maintain the privacy and security of your personally identifiable health information. Although the wellness program and your employer may use aggregate information they collect to design a program based on identified health risks in the workplace, the wellness program will never disclose any personal information publicly or to the employer, except as necessary to respond to a request from you for a reasonable accommodation needed to participate in the wellness program, or as expressly permitted by law. Medical information that personally identifies you, provided in connection with the wellness program, will not be provided to your supervisors or managers and may never be used to make decisions regarding your employment.

Your health information will not be sold, exchanged, transferred or otherwise disclosed except to the extent permitted by law to carry out specific activities related to the wellness program. You will not be asked or required to waive the confidentiality of your health information as a condition of participating in the wellness program or receiving an incentive. Anyone who receives your information for purposes of providing you services as part of the wellness program must abide by the same confidentiality requirements. The only individuals who will receive your personally identifiable health information are those determined to be necessary - such as a “qualified health professional,” “wellness program administrator” or “health coach" - to provide you with services under the wellness program.

Additionally, all medical information obtained through the wellness program will be maintained separate from your personnel records. Information stored electronically will be encrypted, and no information you provide as part of the wellness program will be used in making any employment decision. Appropriate precautions will be taken to avoid any data breach. In the event a data breach occurs involving information you provide in connection with the wellness program, we will notify you immediately.

You may not be discriminated against in employment because of the medical information you provide through participation in the wellness program, nor may you be subjected to retaliation if you choose not to participate.

If you have questions or concerns regarding this notice, or about protections against discrimination and retaliation, please contact your wellness program administrator or Human Resources department.

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