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Privacy Policy

Last Revised: September 29, 2025

Recode Health, LLC (“Recode Health,” “us,” or “we”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and protect your Personal Data when you interact with our websites, mobile apps, and services (collectively, the “Services”).

1. User Consent

By using our Services or agreeing to our Terms of Use, you consent to our collection, use, and disclosure of your Personal Data in accordance with this Privacy Policy.

2. HIPAA Compliance and Applicability

Our Services may collect, process, or use your Personal Data in ways that may be subject to the provisions of the Health Insurance Portability and Accountability Act of 1996, codified at 45 C.F.R. Parts 160, 162, and 164 (HIPAA). To the extent the terms of this Privacy Policy contradict the terms and application of HIPAA to our Services and the collection, processing, or use of your Personal Data via our Services, the provisions of HIPAA shall prevail.

Further, your benefits plan administrator(s) may have implemented additional Notices of Privacy Practices (NOPP) that impact the collection, processing, and use of your Personal Data, including via our Services. Contact your benefits plan administrator(s) to request or review any NOPP that may apply to your Personal Data.

3. Children’s Privacy

Our Services are not intended for children under the age of 13. We do not knowingly collect Personal Data from anyone under 13. If you believe we may have collected data from a child under 13, please contact us.

4. Types of Data We Collect

Anonymous Data refers to information that cannot identify you individually, such as aggregated usage statistics.

Personal Data includes information that identifies you, such as:

  • Name
  • Email address
  • Telephone number
  • Account login credentials

We collect data when you:

  • Register for an account
  • Use our mobile app
  • Contact us via email or feedback forms
  • Participate in surveys

Automatically collected data:

  • IP address
  • Browser and device information
  • Operating system
  • Referring URL
  • Location data (with permission)
  • Cookies and similar technologies (see below)

5. Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to:

  • Personalize content and experiences
  • Remember your preferences
  • Analyze site traffic and usage
  • Deliver targeted advertisements

You can manage your cookie preferences through your browser settings.

6. Mobile and Health Data

Mobile App Data:

  • Device type and ID
  • Mobile OS and version
  • Location data (if enabled)
  • Network and carrier info

Health Data:

We may request access to health-related information such as steps and distance traveled. This data is used solely to provide functionality related to health and fitness. It is processed locally and not shared externally.

  • You can grant or revoke permissions in your device settings.
  • Health data is retained only as long as needed for service functionality and is not sold or shared.

7. How We Use Your Data

We use Personal Data to:

  • Create and manage your account
  • Deliver and improve Services
  • Provide customer support
  • Send administrative and promotional communications (you may opt out)
  • Analyze usage and personalize content
  • Detect and prevent fraud or abuse
  • Comply with legal obligations

8. Anonymous Data

Anonymous Data refers to information that cannot identify you individually, such as aggregated usage statistics.

We may de-identify Personal Data to create Anonymous Data, which we may use and share for any lawful purpose.

 9. Disclosure of Your Data

We may share your Personal Data with:

  • Third-party service providers (e.g., payment processors, analytics tools) who must keep it confidential
  • Affiliates and corporate transactions (e.g., mergers, acquisitions, telehealth providers, health advocacy providers)
  • Authorities or legal entities when required by law or to protect our rights

We do not sell or share your Personal Data with third parties for their direct marketing purposes.

 10. Your Rights and Choices

Depending on your location, you may have rights to:

  • Access, correct, or delete your data
  • Opt out of sale/sharing of your data
  • Opt out of targeted advertising or profiling
  • Port your data

You can make requests via mailto:(clientsuccess@onestrive.com) or by contacting us at the address below.

Recode Health, LLC

2000 S Colorado Blvd

BLDG 1 – 2000 – #82

Denver, CO 80222

UNITED STATES

 11. Security Measures

We use industry-standard measures including:

  • Encryption (at rest and in transit)
  • Secure data storage Password protection
  • Two-factor authentication (2FA)
  • FaceID/fingerprint authentication (on supported mobile devices)

Despite these measures, no method of data transmission is 100% secure. Use caution when sharing information online.

 12. Data Retention

We retain your Personal Data as long as your account is active or as necessary to fulfill the purposes outlined in this Policy. We may also retain it to comply with legal obligations, resolve disputes, or enforce agreements.

 13. International Users

If you access the Services from outside the U.S., you consent to the transfer and processing of your data in the United States and other jurisdictions.

 14. Additional Disclosures for California Residents (CCPA/CPRA)

Under California law, you have the right to:

Know what categories of Personal Data we collect and disclose

  • Request deletion or correction of your data
  • Opt out of sale/sharing of Personal Data
  • Limit use of sensitive data (we do not currently use sensitive data for inferring characteristics)

To exercise these rights, email us at clientsuccess@onestrive.com

 15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will:

  • Notify you via email (if available) -or-
  • Post a prominent notice on our website

Changes take effect 30 days after posting. Your continued use of the Services after notice constitutes your acceptance of the changes.

 16. Contact Us

For questions or concerns about this Privacy Policy or your data, please contact us:

Recode Health, LLC

2000 S Colorado Blvd

BLDG 1 – 2000 – #82

Denver, CO 80222

UNITED STATES

Email: mailto:(clientsuccess@onestrive.com)

17. Additional Policies

Certain services may be governed by additional privacy disclosures. In case of conflict, those disclosures will prevail.