LAST UPDATED MARCH 4, 2020

Your access to, and use of the BeNXT, Inc. (d/b/a BeNXTCare or BeNXT) ("BeNXT") services which include this website (BeNXTcare.com) and the information, products and services that we provide to you and other users through this web site, as well as any mobile applications ("BeNXT App(s)") provided by us in connection with our products and services (collectively, the "BeNXT Services") is subject to the BeNXT Services Terms of Service and this Privacy Policy

BeNXT has created this Privacy Policy to explain what information we gather from you when you use the BeNXT Services, how we may use this information, the security approaches we use to protect your information, and how you can access and request modification of certain information that we may store about you. Please note that this Privacy Policy applies only to information collected via the BeNXT Services - it does not apply to information you disclose to BeNXT through other means. This Privacy Policy is incorporated and made part of the BeNXT Services Terms of Service.

By accessing, viewing or otherwise using any BeNXT Service, you consent to the collection and use of your information by BeNXT in accordance with this Privacy Policy. If you do not agree to this Privacy Policy, you may not use any BeNXT Service. BeNXT reserves the right to change, modify, add or remove portions of this Privacy Policy at any time, without prior notice. Changes take effect on the date that change appears on the revised Privacy Policy. If you use any BeNXT Service following a change in this Privacy Policy, your use will be understood to signal that you accept and agree to be bound by the changes. Accordingly, we urge you to review this Privacy Policy frequently for changes.

We collect personally identifiable information ("Personal Information") and other non-individually identifiable information from you when you register on the BeNXT Services, respond to communication such as e-mail, or otherwise use the BeNXT Services in any manner.
To participate in certain features of the BeNXT Services, you will be required to provide certain Personal Information. For example, when registering as a user on any BeNXT Service, we may ask you for your name, e-mail address, birth date, mailing address, zip code, phone number, credit card information or other Personal Information. You may, however, visit portions of the BeNXT Services without providing any Personal Information.

We may collect and use mobile device identifiers, IP addresses and session identifiers to analyze trends, to administer the BeNXT Services, to track user activities, to infer user interests, and to otherwise induce, deduce, and gather information about individual users and market segments.
If necessary to perform the BeNXT Services, we may collect protected health information ("PHI"), as defined by the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"). Any use of PHI will be in accordance with applicable laws, including HIPAA.

Like many websites and certain mobile apps, we use and may allow third-party service providers to use "cookies", flash cookies, local shared objects, web beacons, pixels, single-pixel GIFs, clear GIFs, and/or other tracking technologies to enhance your experience and gather information about visitors and visits to the BeNXT Services, including how you use the BeNXT Services ("Usage Data"). Please refer to the "Do we use 'cookies'?" section below for information about cookies and how we use them.

We may also collect transactional information, customer services information, or any other legally permissible information.

We may also collect and store certain other personally non-identifiable information. This information is collected passively using various technologies, and cannot presently be used to specifically identify you.

Your information may be supplemented with additional information from other companies such as publicly available information, information about households and other information that we may append or match to your information.

We may use the Personal Information and other data we collect from you when you register, purchase services, respond to a survey or marketing communication, access or view the BeNXT Services, or use certain other BeNXT Service features in the following ways:

• To provide any legitimate business service or product.
• To personalize your BeNXT Service and to allow us to deliver the type of content and product offerings in which you are most interested (including to present offers to you on behalf of business partners and advertisers).
• To allow us to better service you in responding to your customer service requests.
• To contact you when necessary or requested.
• To quickly process your transactions.
• To verify and validate your identity.
• To administer a promotion, survey or other BeNXT Service features.
• To the extent you have not opted out of receiving marketing communications, to send you information about BeNXT or our products or the BeNXT Services, including by letter, email, text, telephone or other forms of communication.
• To the extent you have not opted out of receiving marketing communications, to provide you with information about third-party businesses, products and services, including by letter, email, text, telephone or other forms of communication.
• To show you advertisements, including interest-based or online behavioral advertising.
• To troubleshoot problems with the BeNXT Services, or any services, as requested.
• To enforce the Terms of Service, and to detect and protect against error, fraud and other unauthorized or illegal activities.
• To operate and improve the Services available through us.
• To fulfill your requests for tools, software, functionality, features and other products, and services;
• To communicate with you and respond to your inquiries.
• To conduct research about your use of our products; and
• To help offer you other products, features or services that may be of interest.

We reserve the right to make full use of Usage Data. For example, we may use Usage Data to provide better service to Service visitors or end-users, customize the Services based on your preferences, compile and analyze statistics and trends about the use of our Services and otherwise administer and improve our Services.

You understand and agree that if you are using any BeNXT Service from a country outside the United States and provide Personal Information to the BeNXT Service, you will be authorizing and consenting to the transfer of Personal Information about yourself to the United States. You understand that the privacy laws of the United States may be different from and not as comprehensive or protective as those in your country, and you agree that the transfer of your Personal Information to the United States occurs with your consent. Personal Information collected on the BeNXT Service may be stored and processed in the United States or abroad.

You understand and agree that we can disclose your Personal Information and other data to third parties, as follows:

• To our subsidiaries or affiliates, strategic partners and to third parties we engage to provide services, such as medical services, website hosting, credit card payment processing, order processing, analytics services etc.
• In the event of the sale or transfer of BeNXT, of one or more of our business units or of some or all of our assets, or in the context of some other business acquisition transaction.
• In response to lawful governmental requests or legal process (for example a subpoena, court order, or search warrant); to establish or exercise our legal rights, or to defend against claims; or to protect the safety or security of the public or of users of the BeNXT Services; or in other circumstances in which we have a good-faith belief that a crime has been or is being committed by a user of our Services, that an emergency exists that poses a threat to the safety of you or another person,
• When necessary to protect either our rights or our property or for us to render the service you have requested.
• We can disclose aggregate information and other non-individually identifiable information about users of the BeNXT Service to our service providers, partners, advertisers or others. For example, we may share information publicly to show trends about the general use of our websites and/or other products or services.

You can correct or update your Personal Information by re-registering or by contacting us by e-mail at privacy@BeNXT.co. It may take us up to 30 days to process your request.

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser or mobile device that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. Cookies help us in many ways to make your use of the BeNXT Services more enjoyable and meaningful, such as understanding usage patterns and improving functionality of the BeNXT Services. For instance, we use cookies to help us understand your preferences based on previous or current BeNXT Services activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about BeNXT Services traffic and BeNXT Services interaction so that we can offer better BeNXT Services experiences and tools in the future.

We may contract with third-party service providers to assist us in better understanding our BeNXT Service visitors. For example, we use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help us analyze how users use the BeNXT Services and enhance your experience when you use the BeNXT Services. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.

If you are using our website, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. If you are accessing our mobile app, you can choose to change your permissions and settings on your mobile device. Each browser and device is different, so look at your browser or devices Help or Settings menu to learn the correct way to modify them. If you turn cookies off or disable certain permissions, you won't have access to many features that make your BeNXT Service more efficient and some of our services will not function properly.

Our BeNXT Services currently do not respond to "Do Not Track" (DNT) signals and do not recognize browser-based "do-not-track" requests.

BeNXT follows generally accepted industry security standards to safeguard and help prevent unauthorized access and maintain data security of Personal Information. However, no commercial method of information transfer over the Internet or electronic data storage is known to be 100% secure. As a result, we cannot guarantee the absolute security of any Personal Information submitted to or otherwise collected during your use of any BeNXT Service. Accordingly, you understand and agree that you transmit all data, including Personal Information, to us at your own risk.

This Privacy Policy applies solely to information collected by the BeNXT Service through our web site located at BeNXT.co and the mobile application(s) we make available. In an attempt to provide you with increased value, we may include third party links on the BeNXT Services. This Privacy Policy does not apply to the third party sites and services that are accessible through these links and we suggest that you contact the operator of the third party service to obtain details about their privacy policies. We have no responsibility or liability for the content and activities of these linked sites or services. Nonetheless, we seek to protect the integrity of the BeNXT Services and welcome any feedback about these linked sites (including if a specific link does not work).

This Privacy Policy shall not apply to any unsolicited information you provide to us through the BeNXT Services or through any other means. This includes, but is not limited to, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, "Unsolicited Information"). All Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Only individuals 18 years of age or older are authorized to use the BeNXT Services, either for themselves or on behalf of their minor children. We do not knowingly collect information directly from children under the age of eighteen. If you have reason to believe that an individual under the age of 18 has provided Personal Information to us through a BeNXT Service, please contact us, and we will endeavor to delete that information from our databases.

We will store the Personal Information you provide for as long as we believe is necessary or appropriate (i) to carry out the purpose(s) for which we collected it, or (ii) to comply with applicable laws, contracts, or other rules or regulations.

We welcome your questions, comments, and concerns about the BeNXT Services. Please send us any and all feedback pertaining to the BeNXT Services to privacy@BeNXT.co.

The California Consumer Privacy Act (CCPA), effective January 1, 2020, gives California consumers enhanced rights with respect to their personal information that is collected by businesses. First, California consumers may opt-out of having their personal information sold to other persons or parties. Second, they have a right to know:

1. What specific pieces of information a business has about the consumer;
2. Categories of personal information it has collected about the consumer;
3. Categories of sources from which the personal information is collected;
4. Categories of personal information that the business sold or disclosed for a business purpose about the consumer;
5. Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
6. The business or commercial purpose for collecting or selling personal information.

In addition, California consumers can request that the personal information a business has collected about them be deleted from the business's systems and records.

Company may be considered a covered business under the CCPA as it collects and processes the personal information of California consumers. This Privacy Policy provides the required notices to California consumers. The CCPA also prohibits covered businesses from providing discriminatory treatment to California consumers if they exercise their rights under the Act.

We do not rent or sell your personally identifiable information (such as name, address, telephone number and credit card information) to unaffiliated third parties for their marketing purposes. We may share your information with third parties to provide products and services you have requested, when we have your consent, or as described in this Privacy Policy.

To make a "request to know" or request to delete your personal information, send us an e-mail at contact@BeNXT.co (Please put either "Request to Know" or "Request to Delete" in the subject heading of your email.) We will use commercially reasonable efforts to honor these requests whether or not you would qualify as a California consumer under the CCPA. If and to the extent we are considered a covered business under the CCPA: We will confirm receipt of your request within 10 days along with a description of what steps we will take to verify and respond. We must provide the requested information or delete your personal information within 45 days of receipt of your request but can use an additional 45 days, but we must let you know the additional time is needed.

When contacting us, we may ask you to provide certain, limited personal information, such as your name, email address and/or account login ID and/or password, to verify your request and to match with our records and systems. This is also to protect against fraud. We will not retain this personal information or use it for any other purpose. Also please be advised that we need to search our records and systems only for the preceding 12 months.

Residents of other states may also have similar rights to request information about or delete their personal information. To inquire about exercising these rights, please contact us at contact@BeNXT.co. Pursuant to California's "Shine The Light law (California Civil Code § 1798.983), California residents are entitled, once a year and free of charge, to request the disclosure of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year, if any. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt out of this type of sharing. You may request this information by contacting us at contact@BeNXT.co and indicate in the email subject line, "California Shine The Light Request." Please include your mailing address, state of residence and email address with your request.

We may update this Privacy Policy from time to time, and so you should review this Policy periodically. Your continued use of any Services constitutes your acceptance of any such changes.
Please send any questions or feedback pertaining to the Privacy Policy to BeNXT's Data Protection Officer at privacy@BeNXT.co.