PRIVACY POLICY CLAUSE 

Scope; Status; Acceptance; Definitions.

This Website Privacy Policy (this “Policy”) governs the Company’s information practices for this public-facing Website. The Company may act as a HIPAA Business Associate in limited circumstances when it creates, receives, maintains, or transmits Protected Health Information (“PHI”) on behalf of a covered entity through specific, clearly designated Website features. To the extent information collected through the Website constitutes PHI, this Policy and applicable HIPAA requirements govern notwithstanding any conflicting provisions in the Terms of Service.  By accessing or using the Website you acknowledge that you have read and agree to this Policy.

“HIPAA” means the Health Insurance Portability and Accountability Act of 1996, as amended, and its implementing regulations, including 45 C.F.R. Parts 160 and 164, and the HITECH Act; (b)

“Business Associate” has the meaning set forth under HIPAA and, for clarity, the Company acts as a business associate when it creates, receives, maintains, or transmits Protected Health Information on behalf of a covered entity;

“Protected Health Information” or “PHI” has the meaning set forth under HIPAA;

“ePHI” means PHI maintained or transmitted in electronic form;

“Personal Information” means information collected through the Website that identifies or can reasonably be linked to an individual;

Information Collected Through the Website.

The Company may collect:

Information you submit through the Website (including contact details and any information you choose to provide);

Information collected automatically when you use the Website (including device and browser information, IP address, pages viewed, and approximate location derived from IP address);

Information received from service providers supporting the Website. You agree not to submit PHI through general Website contact forms or other free-text fields unless the Website expressly indicates the submission method is intended for PHI and is secured for that purpose. Do not submit health or medical information through general contact forms or free-text fields.

Information collected through general Website use, including cookies, analytics, and standard inquiry forms, is treated as Personal Information and not as PHI unless expressly stated otherwise.

HIPAA Notice; Relationship to Covered Entity Notices.

Where the Company Processes PHI as a Business Associate, the applicable covered entity’s notice of privacy practices (and not this Policy) describes permitted uses and disclosures of PHI by the covered entity and individuals’ rights with respect to PHI. This Policy describes the Company’s Website privacy practices and, to the extent the Company Processes PHI through the Website on behalf of a covered entity, the Company will handle such PHI in accordance with HIPAA and the Company’s applicable business associate obligations.

Permitted Uses and Disclosures; Minimum Necessary.

The Company may Process information collected through the Website to operate, maintain, secure, and improve the Website; respond to inquiries; provide support; communicate about Website functionality and security; prevent fraud and misuse; comply with law; and enforce this Policy. To the extent any information collected through the Website constitutes PHI, the Company will make uses, disclosures, and requests for PHI subject to HIPAA’s minimum necessary standard and will make reasonable efforts to ensure that access to PHI in connection with the Company’s services is limited to the minimum necessary to accomplish the intended purpose of the particular use, disclosure, or request. The Company will support and document its minimum necessary determinations consistent with reasonable recordkeeping practices and taking into account relevant privacy and security risks and the Company’s technical capabilities.

Cookies, Analytics, and Similar Technologies.

The Website uses cookies, pixels, SDKs, tags, scripts, and similar technologies (collectively, Tracking Technologies) to operate the Website, maintain session state, remember preferences, measure performance, detect and prevent fraud and misuse, and understand how users interact with the Website. The Company may collect, through Tracking Technologies, information such as IP address, device identifiers, browser type, operating system, referring/exit pages, pages viewed, links clicked, timestamps, approximate location derived from IP address, and other usage and diagnostic data (collectively, Usage Data). The Company will not intentionally deploy Tracking Technologies on the Website for the purpose of collecting Protected Health Information (PHI) unless the Website feature expressly indicates it is intended for PHI and is secured for that purpose. Users may control cookies through browser settings and, where available on the Website, through cookie preference tools; however, disabling certain cookies may cause portions of the Website to function improperly. Where required by applicable law, the Company will provide notice and obtain consent for non-essential cookies before placing them. The Company may use Analytics providers and other vendors to support Website operations; to the extent any such vendor creates, receives, maintains, or transmits PHI on behalf of the Company in connection with the Website, the Company will require such vendor to be bound by written obligations consistent with the Company’s HIPAA business associate responsibilities. To the extent any information collected through Tracking Technologies constitutes PHI, the Company will make uses, disclosures, and requests for such PHI subject to HIPAA’s minimum necessary standard and will make reasonable efforts to ensure access to PHI in connection with Website-related services is limited to the minimum necessary to accomplish the intended purpose of the particular use, disclosure, or request; the Company will support its minimum necessary determinations with a rational justification reflecting (i) the Company’s technical capabilities and (ii) relevant privacy and security risks, and will record and maintain documentation of such determinations consistent with reasonable recordkeeping practices and HIPAA rules.

Safeguards; HIPAA Compliance; Direct Liability.

Where applicable the Company will implement and maintain administrative, technical, and physical safeguards designed to protect the privacy and security of PHI and ePHI and to prevent uses or disclosures not permitted by HIPAA. The Company acknowledges that, as a Business Associate, it may be directly liable under HIPAA and the HITECH Act and subject to civil (and, in certain cases, criminal) penalties for making uses or disclosures of PHI not authorized by HIPAA or required by law and for failing to safeguard ePHI in accordance with the HIPAA Security Rule.

Service Providers; Subcontractors; Flow-Down Obligations.

The Company may disclose information to vendors and service providers that support the Website (including hosting, analytics, security, and communications providers) solely to perform services for the Company. To the extent any such vendor or service provider creates, receives, maintains, or transmits PHI on behalf of the Company, the Company will ensure such subcontractor or agent agrees in writing to the same restrictions, conditions, and obligations that apply to the Company with respect to such PHI, including compliance with applicable HIPAA requirements. The Company remains responsible for such subcontractors to the extent required by law.

Legal Disclosures; Protection of Rights; Transfers.

The Company may disclose information (including, where applicable, PHI) as required by law or legal process, or as reasonably necessary to protect the rights, safety, and security of the Company, Website users, and others. The Company may transfer information in connection with a merger, acquisition, reorganization, financing, or sale of assets, provided that any recipient is bound to protect such information consistent with this Policy and, for PHI, consistent with HIPAA and applicable business associate obligations.

Retention; Return/Destruction of PHI.

The Company will retain Personal Information only as long as reasonably necessary for the purposes described in this Policy, unless a longer period is required or permitted by law. To the extent the Company receives or creates PHI through the Website on behalf of a covered entity, upon termination of the applicable relationship or as otherwise required, the Company will

retain PHI only as necessary for the Company’s proper management and administration or to carry out its legal responsibilities,

return to the covered entity or, if agreed by the covered entity, destroy remaining PHI that the Company maintains in any form, and

if PHI is retained, continue to use appropriate safeguards and comply with the HIPAA Security Rule with respect to ePHI to prevent use or disclosure of PHI other than as permitted, and limit any further use or disclosure of retained PHI to the purposes for which it is retained and subject to the same conditions that applied prior to termination, until such PHI is returned or destroyed when no longer needed for such purposes.

Changes to This Policy.

The Company may update this Policy from time to time. Changes are effective when posted on the Website unless a later effective date is stated. Continued use of the Website after posting constitutes acceptance of the updated Policy.

TERMS OF SERVICE 

Binding Agreement.

These Website Terms of Service (the “Terms of Service” or “Agreement”) constitute a legally binding agreement between you and LifeX Research Corporation, and all affiliate companies and any related sites, applications, features, content, products, and services that we may offer from time to time (collectively, the “Site” or “Service”). 

1. Acceptance by Access or Use. By accessing, browsing, or using the Site in any manner, including but not limited to visiting or browsing the Site, registering an account, or contributing content or other materials to the Site, you acknowledge that you have read, understood, and agree to be bound by these Terms of Service, as they may be amended from time to time in accordance with this Agreement. If you do not agree to all of the terms and conditions of this Agreement, you must not access or use the Site. 

1. No Users Under Age 18. In order to access this Site you represent and warrant that you are at least 18 years old. If you are under the age of 18 you are not permitted to use the Site.  

1. Incorporation of Additional Terms and Policies. Certain areas, features, or services of the Site may be subject to additional terms, guidelines, rules, or policies, including, without limitation, any end-user license agreements, specific feature terms, community guidelines, acceptable use policies, payment terms, and our Privacy Policy (collectively, “Additional Terms”). All such Additional Terms are hereby incorporated into and made a part of this Agreement by reference, and to the extent of any conflict between such Additional Terms and these Terms of Service, the Additional Terms shall govern solely with respect to the applicable area, feature, or service. 

Description and Use of the Site 

1. General Description. The Services provide information and administrative support for group health benefit plans, including self-funded plans with Stop-Loss protection, plan selection guidance, and TPA services. 

1. The Services are intended for businesses and employers in the United States seeking guidance on group health insurance. You may not use the Services in jurisdictions where it would be unlawful or require registration under local laws. 

1. Important: The Services are not a substitute for legal, tax, or regulatory advice. If your business must comply with laws such as HIPAA, GLBA, or other industry-specific regulations, consult appropriate professionals before using the Services. The Services do not provide medical, clinical, or healthcare advice, diagnoses, or treatment recommendations. Nothing on the Site is intended to be, or should be construed as, medical advice or a substitute for professional medical judgment. Use of the Services does not create a doctor–patient, fiduciary, broker–client, or other professional relationship. 

1. Permitted Use. Subject to and conditioned upon your compliance with this Agreement and all applicable laws, we grant you a limited, revocable, non-exclusive, non-transferable, and non-sublicensable license to access and make personal, non-commercial use of the Site strictly in accordance with these Terms of Service. Any use of the Site not expressly permitted by this Agreement is unauthorized and may result in termination of your rights to use the Site. 

1. Prohibited Uses of the Site. You may not: 

• Access or use the Site for any purpose that is unlawful or prohibited by this Agreement; 

• Use the Site in any manner that could damage, disable, overburden, or impair any of our servers or networks or interfere with any other partys use and enjoyment of the Site; 

• Use any robot, spider, scraper, crawler, or other automated means to access the Site for any purpose without our express written permission, except for standard indexing by bona fide search engines; 

• Use the Site to provide or engage in any services, activities, or conduct that would infringe or violate any third-party rights, including intellectual property, privacy, or publicity rights; 

• Use the Site for any commercial purpose, including the sale or licensing of access or information obtained from the Site, unless expressly authorized in writing by us. 

• Upload viruses, malware, or harmful scripts 

• Collect user information without consent 

• Attempt to reverse engineer the software or content.  

1. Service Availability and Changes. We do not guarantee that the Site or any content thereon will always be available, uninterrupted, secure, or error-free. We may suspend or restrict the availability of all or any part of the Site at any time for business, security, operational, or legal reasons. 

User Registration, Accounts, and Security 

1. Registration Obligations. To access certain features or areas of the Site, you may be required to register for an account and provide certain information about yourself. You agree to: 

• Provide accurate, current, and complete information as prompted by any registration form on the Site (“Registration Data”); 

• Maintain and promptly update the Registration Data and any other information you provide to keep it accurate, current, and complete; 

• Not create an account for anyone other than yourself without appropriate authorization. 

1. Account Termination by Company. We may, in our sole discretion and at any time, with or without notice, and without liability to you: 

• Suspend or terminate your account or your access to all or part of the Site; 

• Remove or disable any content or materials associated with your account; 

• Take any other action we deem appropriate under the circumstances.
  Grounds for termination may include, without limitation, violation of this Agreement, suspected fraudulent or abusive activity, or requests by law enforcement or other governmental authorities. 

1. Account Termination by You. You may terminate your account at any time by following the instructions on the Site or by contacting us at [contact email]. Upon termination, your right to use the Site under this Agreement shall cease immediately, subject to those provisions that are expressly stated to survive termination or that by their nature should survive. 

Intellectual Property of the Company 

1. Ownership of Site Content. As between you and the Company, the Site and all Site Content, including all text, graphics, logos, icons, images, audio clips, video clips, data compilations, software, and the arrangement and compilation thereof, are the exclusive property of the Company or its licensors, and are protected by copyright, trademark, trade dress, trade secret, and other intellectual property and proprietary rights laws. 

1. Trademarks. The Company name, the Site name, and all related names, logos, product and service names, designs, and slogans are trademarks or service marks of the Company or its affiliates or licensors (collectively, the “Company Marks”). You must not use the Company Marks without our prior written permission. All other names, logos, product and service names, designs, and slogans on the Site are the trademarks or service marks of their respective owners. 

1. Limited License to Use Site Content. Subject to your compliance with this Agreement, the Company grants you a limited, revocable, non-exclusive, non-transferable, and non-sublicensable license to access and use the Site Content solely for your personal, non-commercial use. You shall not: 

• Copy, reproduce, modify, adapt, translate, or create derivative works of the Site Content; 

• Distribute, transmit, publish, sell, license, or otherwise exploit any Site Content for any commercial purpose; 

• Remove, obscure, or alter any copyright, trademark, or other proprietary rights notices from any Site Content; 

• Use any Site Content in a manner that suggests an unauthorized association with any of our products, services, or brands. 

1. Reservation of Rights. Except for the limited rights expressly granted to you in this Agreement, all right, title, and interest in and to the Site, the Site Content, and the Company Marks are and shall remain with the Company and its licensors. No rights are granted to you by implication, estoppel, or otherwise. 

Third-Party Links, Content, and Services 

1. Third-Party Websites and Resources. The Site may contain links to or be accessible from third-party websites, applications, content, or resources that are not owned or controlled by the Company (“Third-Party Services”). These links are provided solely as a convenience to you. 

1. No Endorsement or Responsibility. The Company does not endorse, monitor, or have any control over any Third-Party Services. We make no representations or warranties, and accept no responsibility or liability, for: 

• The availability, accuracy, completeness, quality, legality, or any other aspect of any Third-Party Services; 

• Any content, advertising, products, or other materials on or available from such Third-Party Services; 

• Any damages, losses, or other harm arising out of or relating to your access to or use of any Third-Party Services.
  Your use of Third-Party Services is at your sole risk and subject to the terms and conditions of use and privacy policies applicable to such Third-Party Services. 

Privacy; Personally Identifiable Information 

1. Privacy Policy. Your use of the Site is also governed by our Privacy Policy, which describes our practices regarding the collection, use, storage, and disclosure of personal information. Our Privacy Policy is incorporated into and forms part of this Agreement by reference. By using the Site, you acknowledge that you have read and understand our Privacy Policy. 

1. Consent to Data Practices. You consent to the collection, use, storage, and disclosure of your information, including personal information, in accordance with our Privacy Policy and applicable law. You understand that the Company may process your personal information on servers located in jurisdictions that may not provide the same level of data protection as your home jurisdiction. 

1. Disclosure Required by Law. The Company may disclose your information, including personal information and User Content, if required to do so by law or in the good-faith belief that such disclosure is reasonably necessary to: 

• Comply with any applicable law, regulation, legal process, or governmental request; 

• Enforce this Agreement, including investigation of potential violations; 

• Detect, prevent, or otherwise address fraud, security, or technical issues; 

• Protect the rights, property, or safety of the Company, its users, or the public as required or permitted by law. 

Disclaimer of Warranties 

1. As-Is and As-Available Basis. The Site, including all content, information, materials, products, and services provided on or through the Site, is provided on an “as is” and “as available” basis, without any representations or warranties of any kind, whether express, implied, or statutory. 

1. No Warranties. To the fullest extent permitted by applicable law, the Company and its affiliates, licensors, and service providers expressly disclaim all warranties of any kind, whether express, implied, or statutory, including but not limited to: 

• Any implied warranties of title, merchantability, fitness for a particular purpose, non-infringement, and quiet enjoyment; 

• Any warranties arising out of course of dealing or usage of trade; 

• Any warranties that the Site will meet your requirements, be compatible with any particular hardware or software, or achieve any intended result; 

• Any warranties that the Site will be uninterrupted, timely, secure, error-free, accurate, reliable, complete, or free of harmful components. 

1. No Responsibility for Third-Party Content or Services. The Company does not warrant, endorse, guarantee, or assume responsibility for any product, service, content, or information provided by third parties, whether or not linked to or referenced on the Site. 

1. Jurisdictional Limitations. Some jurisdictions do not allow the exclusion of certain warranties or the limitation or exclusion of liability for certain damages. Accordingly, some of the above disclaimers may not apply to you. In such jurisdictions, the limitations and disclaimers shall apply to the maximum extent permitted by applicable law 

Limitation of Liability 

1. Exclusion of Certain Damages. To the fullest extent permitted by applicable law, in no event shall the Company or its affiliates, officers, directors, employees, agents, licensors, or service providers be liable to you or any third party for any: 

• Indirect, incidental, special, punitive, exemplary, or consequential damages; 

• Loss of profits, loss of revenue, loss of goodwill, loss of data, business interruption, or other intangible losses; 

• Damages arising out of or in connection with: 

• Your access to or use of, or inability to access or use, the Site; 

• Any conduct or content of any user or third party on or related to the Site; 

• Any content obtained from the Site; 

• Unauthorized access, use, or alteration of your transmissions or information. 

Indemnification 

1. Indemnity Obligations. You agree to indemnify, defend, and hold harmless the Company and its affiliates, officers, directors, employees, agents, licensors, and service providers from and against any and all claims, demands, actions, suits, proceedings, investigations, liabilities, damages, losses, costs, and expenses (including reasonable attorneys fees and costs) arising out of or relating to: 

• Your access to or use of the Site; 

• Your User Content; 

• Your violation of this Agreement or of any applicable law, rule, or regulation; 

• Your infringement, misappropriation, or violation of any intellectual property, proprietary, privacy, publicity, or other rights of any third party; 

• Any other partys access to or use of the Site using your account credentials. 

1. Defense and Settlement. The Company reserves the right, at its own expense, to assume the exclusive defense and control of any matter for which you are required to provide indemnification, and you agree to cooperate fully with any such defense. You shall not settle or compromise any claim or matter subject to indemnification under this Agreement without the prior written consent of the Company. 

1. Survival. Your indemnification obligations under this section shall survive the termination of this Agreement and your use of the Site. 

User Information 

1. If you submit, upload, post, or transmit any health information, medical history, conditions, problems, symptoms, personal information, consent forms, agreements, requests, comments, ideas, suggestions, information, files, videos, images, or other materials to us or our Platform (“User Information”), you agree not to provide any User Information that: (a) is false, inaccurate, defamatory, abusive, libelous, unlawful, obscene, threatening, harassing, fraudulent, pornographic, or harmful, or that could encourage criminal or unethical behavior; (b) violates or infringes the privacy, copyright, trademark, trade dress, trade secrets, or intellectual property rights of any person or entity; or (c) contains or transmits a virus or any other harmful component.  You agree not to contact other Platform users through unsolicited e-mail, telephone calls, mailings, or any other method of communication.  You represent and warrant to Company that you have the legal right and authorization to provide all User Information to Company for use as set forth herein and required by Company. 

1. Company may de-identify your information such that it is no longer considered personally identifiable information.  Company may disclose, aggregate, sell, or otherwise use such de-identified information to third parties for analytics, research, or other purposes. De-identified information will be processed in compliance with applicable de-identification standards under HIPAA or other applicable law.   

1. Company may monitor your use of this Platform, and subject to Company’s Privacy Policy, Company may freely use and disclose any information and materials received from you or collected through your use of this Platform for any lawful reason or purpose.