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FOCUSfwd Privacy Notice

The FOCUSfwd program is made available to you by BlueChoice HealthPlan of South Carolina, Inc. through its vendor, Vitality.

Although this FOCUSfwd website and/or mobile application contains the FOCUSfwd name, the website and/or application is not the website or application of BlueChoice HealthPlan of South Carolina, Inc. Instead, it is provided by Vitality and allows you to more efficiently interact with the FOCUSfwd program.

The Privacy Notice below is Vitality’s Privacy Notice and applies to your use of the FOCUSfwd website and/or mobile application and the FOCUSfwd program Vitality provides for BlueChoice HealthPlan of South Carolina, Inc. Vitality may also collect consents you provide while interacting with the website and/or mobile application.

In addition, Vitality’s Privacy Notice does not alter the Privacy Policy on BlueChoice HealthPlan of South Carolina, Inc.'s website or other applications or any agreement you may have with your health plan or with BlueChoice Health Plan of South Carolina, Inc., as appropriate, which continues to apply as indicated therein.

EFFECTIVE JANUARY 1, 2026

The Vitality Group, LLC including its affiliates and group companies (“Vitality”; “We”; “Us”; “Our”) provides to you the website FOCUSfwd and the mobile application FOCUSfwd (“Application”), which may be referred to collectively as the “Program(s).”

The Program/s are provided on Vitality’s platform and are made available to you by BlueChoice HealthPlan of South Carolina and on behalf of either Your employer;

Your spouse’s employer; or another provider (“Program Provider”). This Privacy Notice applies to Personal Information (defined below) collected by or received Vitality whether online or offline.

By accessing or using Vitality’s Programs, you are aware of the collection, receipt, use, disclosure and retention of your information as described in this Privacy Notice and accept the terms of this Privacy Notice and Our Terms of Use.

Should you require that this Privacy Notice be read to you please contact the Vitality Customer Care Team on 877-224-7117.

This Privacy Notice will address the following:

1. FROM WHOM OR WHERE DOES VITALITY COLLECT PERSONAL INFORMATION ABOUT ME?

From your Program Provider: As part of your eligibility for the Program, your Program Provider will provide Vitality the information necessary to verify your identity when you register for the Program and to manage your account on an ongoing basis.

If you do not want Vitality to receive this information, please contact your Program Provider and ask them to stop sending Vitality any information about you.

Please note that this will make you ineligible to participate in the Program.

Directly from You, including from your devices: By engaging with the Program, information linked to you and your interactions with the Program (e.g. your physical activity, reward earning events and redemption, and form submission) will be collected or created by Vitality.

You can also choose to allow certain devices and mobile applications, such as Garmin, to sync data to a Vitality Application you use.

Once you consent and link your device, 90 days of historical fitness device data will be collected by Vitality from date of linking.

You can delink your device at any time, through the settings menu of the applicable application.

Note such action may impact your ability to earn rewards and our ability to administer the Program for your full benefit.

Should you wish to no longer use the Program ensure you delink your device.

From authorized Third-Party Service Providers on behalf of you or your Program Provider: When you or your Program Provider grant authorization Vitality may receive information about your participation with Third-Parties Service Providers.

The authorization from your Program Provider is based on the service agreement, or related agreement, it has in place with Vitality.

Additionally, if you engage with Vitality on a social media platform Vitality may respond or contact you through the applicable social media platform.

2. WHAT TYPES OF PERSONAL INFORMATION DOES VITALITY COLLECT ABOUT ME?

For the purposes of this Privacy Notice, Vitality’s definition of Personal Information is any information relating to an identified or identifiable natural person.

The following is a list of the types of information that Vitality may collect through its Program(s).

Please note that the types of information collected about you will depend on the particular Program you are using and the activities in which you participate:

  • Name
  • Gender
  • Address
  • Contact details
  • Date of birth
  • Program enrollment or Program registration date
  • Reporting classifications (e.g. at which branch location you are employed)
  • A unique ID (e.g. your employee ID or SSN)
  • Dependents / Spouse / Partner (if applicable)
  • Eligibility start and end date data (if relevant)
  • Cookies
  • Log data including IP address
  • Answers to questionnaires about your health and well-being
  • Program engagement information
  • Survey responses, commentary, or feedback you give when engaging with the Program otherwise provide to Vitality
  • Reward partner engagement if authorized
  • Devices’ information such as
    • the type of device
    • operating system
    • data that you have synched, which may include health and fitness related information (which can include physical activity data, body measurements, heart rate data, sleep data, meditation data) and location data if you have consented to this data synching for example where you have consented to data synching from Polar.
  • Details of rewards you have earned and your reward redemptions
  • Limited financial information such as transactions and payment details
  • Health information including biometrics and medical conditions
  • Additional information provided by you through online form submission or by otherwise contacting Vitality

3. DOES VITALITY PROCESS SPECIAL CATEGORIES OF PERSONAL INFORMATION?

Vitality may receive the below Special Categories of Personal Information from your Program Provider or authorized third parties, or directly from you, depending on the particular Program you are using and the activities in which you participate

Health Data including but not limited to: information which includes your answers to questions about your health and well-being;

annual biometric screening results; preventative screening proof; vaccination proof; proof of participation in a qualifying event;

activity information collected from a personal device; smoking status.

Vitality receives the above, based on the consent you provided to your Program Provider or authorized third party/ies.

If you wish to revoke such consent, please contact your Program Provider or authorized third parties.

Please note that such revocation will make you ineligible to participate in the Program.

Please redeem your rewards prior to withdrawing your consent.

In relation to Special Categories of Personal Information which you submit to Vitality on your own, Vitality may request your consent to process such information.

If you wish to revoke such consent, please refer to your rights in terms of section 14 below, as applicable.

Please note that such revocation will make you ineligible to participate in the Program.

Please redeem your rewards prior to withdrawing your consent. We do not collect Special Categories of Personal Information without your consent and we will only use such information in accordance with this Privacy Notice.

4. WHAT IS VITALITY’S LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

Vitality mostly acts as a Processor/ Operator/ equivalent under applicable law and signs a data protection addendum or data protection clauses or master services agreement (“DPA”) with the Controller/ Responsible Party/ equivalent under applicable law, that is most often the Program Provider.

This DPA, provides the legal basis for which Vitality may process Personal Information.

In addition to the above, in instances where Vitality will collect Personal Information from you directly We may rely on the legal basis of consent or the agreement you have entered into with your Program Provider or the DPA.

In such instances:

  • Vitality will be acting in accordance with the Program Provider’s instructions which are set out in the DPA and
  • Where Vitality collects your consent, you will be entitled to revoke the provided consent in terms of section 14 below, as applicable.

Please note that such revocation will make you ineligible to participate in the Program.

Please redeem your rewards prior to withdrawing your consent

5. HOW DOES VITALITY USE PERSONAL INFORMATION IT COLLECTS ABOUT ME?

Vitality will use the Personal Information that it collects about you, to facilitate the Vitality Program which may include the use cases specified below.

Vitality will only use Personal Information in accordance with this Privacy Notice and applicable laws.

To administer and manage your account

  • Creating and maintaining your profile
  • Generating goals, activities, and/or targets
  • Recommending activities and engagements
  • Applying rewards earned
  • Making Program features available to you
  • Fulfilling purchase orders you make through the Program
  • Tracking your progress through the Program

To resolve any complaints or inquiries you may have

  • Registering complaints and inquiries
  • Managing and resolving complaints and inquiries

For management of any debts owed to Vitality, if applicable

  • Tracking and administration of payment installments (if any)
  • Recovery of unpaid debts or reimbursement of damages under a contract

To prevent, detect, and investigate fraud or security incidents

  • Investigating suspicions of fraud
  • Prosecuting fraud
  • Investigating security incidents

For Vitality company and management information purposes and internal analysis of products and services

  • Accounting and financial records; analysis and reporting
  • Audit requirements
  • System security and effective operation
  • Program quality assessments, improvements, and developments
  • Conduct internal research to develop or improve the Program

For training purposes: to improve your customer experience

  • Assessing customer experiences
  • Developing and improving your customer experience

To fulfill legal obligations

  • Reporting necessary information to your Program Provider for benefit administration
  • Complying with any applicable law, regulation, subpoena, or legal process, or responding to any governmental requests and cooperating with law enforcement, if we believe such action is required or permitted by law
  • Enforcing our Terms and Conditions

Creating De-identified or Aggregated Data Sets

  • De-identified data sets are data sets that contain member-level information, without identifiers that can be used to link the information back to a particular individual.
  • Aggregated Data Sets are data sets that contain only aggregated information which cannot be decompiled or reverse engineered to identify any individual whose data may be included.
  • De-identified and Aggregated Data Sets are not Personal Information; subject to any applicable laws or other restrictions, Vitality may use and disclose De-identified and Aggregated data sets for any purpose.
  • De-identified data will be used for AI model training purposes.
  • Vitality will not attempt to re-identify De-identified data or Aggregated Data Sets

Vitality may also seek to use your Personal Information in a way not described above, such as in using a testimonial you have written on our website or in our marketing materials.

Before using your Personal Information in this way, Vitality will first seek your voluntary and explicit consent.

6. HOW IS VITALITY PROTECTING MY PERSONAL INFORMATION?

Personal Information that you share on the website is kept strictly confidential and fully secure.

Your encrypted (encoded) Personal Information is protected using "Secure Socket Layers (SSL)" as it passes between your browser and this website.

We follow generally accepted industry standards to protect the Personal Information we receive, both during transmission and upon receipt.

Personal Information collected by the Program, for example Personal Information received from Apple Health, will be stored securely in accordance with accepted industry standards.

No method of transmission over the Internet, or method of electronic storage, is 100% secure.

Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee absolute security.

7. WHO CAN ACCESS MY PERSONAL INFORMATION AT VITALITY?

Your Personal Information is accessible by Vitality employees, including employees of Vitality affiliates, only on a need-to-know basis for the provision of services and support.

Only such authorized persons are permitted to access your Personal Information.

All authorized persons must abide by security, privacy, and confidentiality agreements, rules and laws.

8. OUTSIDE OF VITALITY, WITH WHOM WOULD VITALITY SHARE MY PERSONAL INFORMATION?

Your Program Provider: Vitality may share with your Program Provider (or a third party that assists and is authorized by your Program Provider) only the necessary information to enable them to administer your incentives, general administration, and for analytics purposes.

Administration can include: calculation of health plan premium discounts, health club dues subsidies, applicable taxation, reward redemption, or other arrangements for which such information is relevant.

Such information may be shared via the employer portal.

Your Program Provider’s authorized Third-Party Service Providers: Your Program Provider may make additional incentives available to you that are provided by Third-Party Service Providers, this could include your Program Provider’s inhouse service provider such as your Program Provider’s in house coaching service In order to administer this benefit, Vitality relies on the service agreement in place with your Program Provider, and/or any related agreement, to share your Personal Information with the Third-Party Service Provider to the extent necessary to make the offering available to you.

Service Providers to Vitality: There are instances when Vitality may disclose your Personal Information to our agents, service providers, third-party partners, affiliates and subsidiaries to enable them to perform functions or provide services on our behalf.

These service providers are only permitted to share, store and/or use the minimum amount of information for contracted business purposes.

Peer: where you sign up for a challenge limited Personal Information may be shared with a peer who is also participating in a challenge

Additionally, We may share your Personal Information when We believe that such action is necessary to:

  • Fulfill an enforceable government request;
  • Conform with the requirements of the law or legal process;
  • Protect or defend Our legal rights or property, Our Websites or Applications, or other users;
  • or
  • Protect your health and safety or the health and safety of this website's users or the general public.
  • Respond to lawful request by public authorities, including to meet national security or law enforcement requirements.

With your express authorization and consent, We may share your Personal Information for a specific purpose not provided above.

Agreeing to the terms and conditions and privacy notice is not your express authorization for any unspecified uses.

When appropriate, while you are logged into the Program, you will be presented with a specific electronic authorization form on which you may or may not provide your consent.

You may revoke such authorization at any time by navigating to your My Accounts page within the Program.

9. DOES THE PROGRAM CONTAIN LINKS TO THIRD-PARTY WEBSITES OR APPS?

The Program may contain links to other websites that are not owned or controlled by Us or our clients (i.e., your Program Provider).

We provide these links to other websites or mobile applications for your convenience to participate.

If you choose to submit Personal Information while visiting these websites or using these mobile applications, please be aware your rights will be governed by the third parties’ privacy policies.

We strongly encourage you to carefully read the privacy policies of any website or mobile application you visit or use.

10. DOES VITALITY SELL MY PERSONAL INFORMATION?

No. Vitality will never sell, rent, or lease your Personal Information.

11. HOW LONG WILL MY PERSONAL INFORMATION BE RETAINED?

Unless otherwise specified herein, Personal Information will only be retained for as long as is required for Us to administer the Program, subject to: legislative or regulatory retention periods;

requirements by the Program Provider; or as required for Our legitimate business reasons - after which any Personal Information will be anonymized, archived or destroyed.

12. HOW WILL I KNOW IF THIS PRIVACY NOTICE CHANGES?

Vitality reserves the right to update this Privacy Notice from time to time.

If We decide to change this website's privacy policies, We will post those changes to this Privacy Notice, on the Program’s homepage, and other places that We deem appropriate.

You should therefore refer to this Privacy Notice each time you make use of the Program.

13. WILL VITALITY COMMUNICATE WITH ME DIRECTLY?

As a member, We aim to provide you with a fully invested experience and dedication to your wellness journey.

We may deliver marketing, status updates, or other informational emails to you via the email address you provide on your My Account page.

If you choose, you may opt out of receiving these emails at any time by adjusting the settings on your account on POV or the Application you use.

If you use a Vitality Application, push notifications and triggered communication may be sent to you through the App.

These notifications can be turned off at any time by adjusting the application’s settings on your device.

Certain communications are necessary and cannot be turned off; these include;

  • transactional emails, such as order confirmations, emails relating to payment processing activities, and reward redemptions;
  • communications from our Customer Care team in response to contacts initiated by you;
  • or other important updates like security and fraud notices or change in services.

If you send questions or comments to an email address listed within the Program or via a contact form provided within the Program, We will share your correspondence with a Vitality associate most capable of addressing your questions and concerns.

We will retain your communications until we have done our very best to provide you with a complete and satisfactory response.

Ultimately, We will either discard your communication or, in some cases, archive it.

We will not keep your email address for secondary purposes.

All information and correspondence you share with us will be handled in the strictest confidence.

We may agree that email has become a standard communication tool used by many different parties.

Unfortunately, by design standard Internet email is not secure. For that reason, please do not use unsecured email to communicate information to us that you may consider to be confidential.

14. I RECEIVE THE PROGRAM IN THE US– WHAT ARE MY RIGHTS?

You have certain rights regarding your Personal Information under applicable U.S. state privacy laws.

These rights may vary depending on your state of residence, but generally include the following:

A. Right to know

You have the right to request information about: i) the categories of Personal Information we collect, use, disclose, and retain;

ii) the source from where such Personal Information was collected from and the third parties with whom such information is shared.

B. Right to access

You may request access to the Personal Information we hold about you.

The right of access includes the rights to receive a copy of the Personal Information we hold about you.

C. Right to correct

You have the right to request that we correct inaccurate or incomplete Personal Information.

D. Right to delete

You may request the deletion of your Personal Information, subject to certain legal exceptions.

E. Right to Limit Use of Special Categories of Personal Information or equivalent

Where required by law, you may request that we limit the use and disclosure of your Special Categories of Personal Information to only what is necessary to provide the requested services.

F. Right to opt out

Where required by applicable law, you have the right to opt out of your Personal Information being: i) used for targeted advertising;

ii) sold; iii) used for in the furtherance of a decision that produces a legal or similarly significant effect concerning you;

G. Right to opt out of the collection of Special Categories of Personal Information or equivalent

Where required by applicable law, the right to opt out of the collection of sensitive data, including precise geolocation data, or the processing of sensitive data

H. Right to Non-Discrimination

You will not be discriminated against for exercising any of your privacy rights.

How to Exercise my Rights

In order to exercise rights enumerated above, please contact Vitality in one of the following ways

  • please contact us through our Contact Us page when logged into the Program.
  • If you are not a current member or one of the above options does not work for you, please contact Vitality through the following link: https://www.vitalitygroup.com/get-in-touch/.
  • Alternatively, you may submit your request by calling Us at +1.312.224.7100.

Note you may submit a reasonable number of requests per year, as permitted by applicable law.

Such request will focus on Personal Information processed by Vitality in the 12 months preceding your request, unless a longer period is required by applicable law.

Once a request is submitted, Vitality may first contact your Program Provider to inform them of the request and then work with them to complete the request.

Vitality will attempt to verify your request by using information related to your account, but in some cases additional information may be required.

Subject to certain exceptions that may apply, if We are able to verify your request, We will accommodate your request in accordance within applicable laws.

15. ARTIFICIAL INTELLIGENCE (AI) USE

We use AI to enhance our Program offering while prioritizing data privacy and security.

We are committed to fairness, transparency, and human oversight in all our use of AI.

Should you have any questions reach out to us as set out in section 30.

16. INFORMATION FOR GOOGLE FIT USERS

Vitality complies with the Google API Services User Data Policy including the Limited Use requirements.

Vitality will only receive the below device data from Google Fit where you allow your mobile application to sync data to the Application.

You can modify these permissions at any time through the settings menu of the applicable application.

If you have consented to data synching, the device data that Vitality will collect through the Program includes:

  • physical activity data (including meditation data)
  • body measurements,
  • heart rate data,
  • sleep data

The above device data will only be used to facilitate the Program in accordance with section 5 above.

Vitality may disclose your device data, to our agents, service providers, third-party partners, affiliates and subsidiaries to enable them to perform functions or provide services on our behalf.

These service providers are only permitted to share, store and/or use such data for contracted business purposes.

Vitality will protect your device data in accordance with section 6 of this Privacy Notice.

17. INFORMATION FOR FITBIT USERS

The use of information received from Fitbit APIs and/or Developer Tools will adhere to the Fitbit Platform Developer and User Data Policy (https://dev.fitbit.com/legal/platform-developer-and-user-data-policy/), including the Limited Use requirements.

18. HOW CAN I CONTACT VITALITY WITH MY PRIVACY CONCERNS OR INQUIRIES?

Individuals with inquiries or complaints regarding the privacy of their Personal Information at Vitality or this Privacy Notice should first contact Vitality at:

The Vitality Group, LLC
Attn: Data Privacy Officer
120 S. Riverside Plaza, Suite 400
Chicago, IL 60606
US_Privacy@vitalitygroup.com