Privacy Policy

1. INTRODUCTION AND OUR COMMITMENT TO PRIVACY

Unity Global Care, Inc. (“Unity Global Care,” “Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal information. We are a corporation organized under the laws of the State of Delaware, with a principal business address of 203 Main Street, No. 179, Flemington, New Jersey 08822.

ALBERTai® is a software platform and family of websites owned and operated by Unity Global Care®, Inc. ALBERTai is designed to provide families, individuals, caregivers, and business clients with an Aging-In-Place Score and to match interested persons with need-based service providers. Users may search our websites to learn about federal, state, and local need-based government and charitable programs and services in their area (each a “Benefit” and collectively, “Benefits”) and, depending on the provider, may be able to apply for Benefits through our websites.

This Privacy Policy (“Policy”) describes the categories of personal information we collect, how we use and disclose that information, the choices and rights available to you, and how you can contact us. This Policy applies to:

• www.unityglobalcare.com
• www.goalbertai.com
• www.myalbertai.com
• Any other website, mobile application, portal, or online service that links to this Policy
• Our Short Message Service (SMS) text messaging program
• Our email and telephone communications with you
• Our offline interactions with you in connection with the above

(collectively, the “Websites,” and together with the products, features, tools, scores, referrals, and services offered through them, the “Services”).

Your use of our Websites or Services, and any dispute over privacy, is subject to this Policy and to our Terms of Use, including their applicable limitations on damages and provisions governing the resolution of disputes. This Policy is incorporated by reference into our Terms of Use.

Our Websites and Services are designed for persons located in the United States.

Please read this Policy carefully. By accessing or using the Websites or Services, you acknowledge that you have read and understood this Policy. Where applicable law requires your consent for a specific processing activity, we will obtain that consent separately.

Related documents. This Policy works together with our Terms of Use, which govern your access to and use of the Services, and with our HIPAA Compliance Statement, which describes how we handle Protected Health Information when we act as a Business Associate or Subcontractor. All three are available on our Websites.

2. SUMMARY OF KEY POINTS

The paragraphs below are a plain-language overview offered for convenience. They do not replace the full Policy, which controls in the event of any inconsistency.

You may search our Websites and view Benefit listings without creating an account or telling us anything about yourself. We collect information when you create an account, request an Aging-In-Place Score, apply for a Benefit, contact us for help, or enroll in text messaging. Depending on which Benefit you pursue, some of what we collect is sensitive, and can include health and wellness information, disability status, pregnancy status, substance use history, criminal history, income, and details about the people in your household, including children.

We share your information mainly at your direction, with the Benefit providers and service organizations you ask us to contact, and with the vendors who help us run the Services. We do not sell your personal information for money. We do not hand it to third parties for their own marketing without telling you first and, where the law requires it, obtaining your consent. Information you give us when you sign up for text messages, including your consent itself, is never shared for marketing purposes.

Depending on where you live, you may have the right to see the information we hold about you, to correct or delete it, to receive a copy of it, to opt out of certain kinds of processing, to limit how we use sensitive information, and to appeal if we turn down a request. Sections 14 and 15 explain those rights and how to use them.

You can reach us at UnityInfo@unityglobalcare.com or 800.315.1217.

3. WHO WE ARE AND HOW TO CONTACT US

Entity name: Unity Global Care, Inc.

State of incorporation: Delaware

Mailing address: 203 Main Street, No. 179, Flemington, New Jersey 08822

Email: UnityInfo@unityglobalcare.com

Toll-free telephone: 800.315.1217

Privacy requests: UnityInfo@unityglobalcare.com (please write “Privacy Request” in the subject line) or call 800.315.1217

Unity Global Care, Inc. is the entity responsible for the personal information described in this Policy, except where we act as a service provider, processor, or business associate on behalf of a business client, as described in Section 4.

4. OUR ROLE: WHEN WE ACT AS A BUSINESS AND WHEN WE ACT AS A SERVICE PROVIDER

Privacy laws distinguish between an organization that determines the purposes and means of processing personal information (referred to as a “business” or “controller”) and an organization that processes personal information on behalf of another organization (referred to as a “service provider,” “processor,” or “contractor”).

When we act as a business or controller. When you visit our Websites directly, create an account with us, request an Aging-In-Place Score for yourself or a family member, apply for Benefits through our Websites, subscribe to our communications, or contact us, we generally act as a business or controller with respect to your personal information, and this Policy governs.

When we act as a service provider or processor. We also license the ALBERTai platform to business clients, including health systems, payers, employers, senior living operators, care management organizations, agencies, and community-based organizations. When we process personal information on behalf of such a client, that client, and not Unity Global Care, determines the purposes and means of the processing. In those circumstances, our processing is governed by our written agreement with that client and by that client’s own privacy notice. If you submit a rights request to us relating to information we process on behalf of a business client, we will, where appropriate, refer your request to that client or act on that client’s documented instructions, and we will notify you of the referral.

If you are unsure which capacity applies to your information, contact us at UnityInfo@unityglobalcare.com and we will help you determine the correct point of contact.

5. NOTICE AT COLLECTION: CATEGORIES OF PERSONAL INFORMATION WE COLLECT

This section constitutes our “notice at collection” for purposes of the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”), and comparable notice requirements under other state laws. It describes the categories of personal information we collect, the purposes for which we use each category, whether each category is sold or shared, and the period for which each category is retained. Retention is described in Section 12.

We collect the following statutory categories of personal information. Not every category is collected about every individual; what we collect depends on how you interact with us and which Benefits or Services you request.

Category A: Identifiers. Real name; alias; postal address; unique personal identifier; online identifier; internet protocol (IP) address; email address; account name and password; telephone number; mobile telephone number; date of birth; and, where a Benefit provider requires it, an indication of whether you possess a form of government identification such as a Social Security number, passport, or state driver’s license. We do not routinely collect or store the full digits of a Social Security number, and you should not submit one to us through unsecured channels.

We disclose this category for the business purposes described in Section 11. We do not sell it, and we do not share it for cross-context behavioral advertising.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Name; signature; physical characteristics or description; address; telephone number; insurance policy number; education; employment; employment history; bank account number, credit card number, debit card number, or any other financial information; medical information; and health insurance information. Some of the information in this category overlaps with Category A. We collect financial account information only where necessary to process a payment or where a Benefit provider requires it as an eligibility criterion.

We disclose this category for the business purposes described in Section 11. We do not sell it, and we do not share it for cross-context behavioral advertising.

Category C: Protected classification characteristics under California or federal law. Age (40 years or older); race; color; ancestry; national origin; citizenship or immigration status; religion or creed; marital status; medical condition; physical or mental disability; sex, including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions; sexual orientation; veteran or military status; and genetic information. We collect information in this category only where it is relevant to eligibility for a Benefit you have asked us to help you obtain, or where it is required by a Benefit provider, funder, or grantor.

We disclose this category for the business purposes described in Section 11. We do not sell it, and we do not share it for cross-context behavioral advertising.

Category D: Commercial information. Records of Services requested, obtained, or considered; Benefits saved to a favorites list; applications submitted; referral history; and other purchasing or consuming histories or tendencies.

We disclose this category for the business purposes described in Section 11. We do not sell it, and we do not share it for cross-context behavioral advertising.

Category E: Biometric information. We do not collect, capture, purchase, receive through trade, or otherwise obtain biometric identifiers or biometric information such as fingerprints, voiceprints, retina or iris scans, or scans of hand or face geometry. We do not use facial recognition technology on our Websites.

We do not collect this category.

Category F: Internet or other similar network activity. Browsing history on our Websites; search history within our Websites; information regarding your interaction with our Websites, applications, advertisements, and emails; browser type and version; device type; operating system; language preference; referring and exit pages; date and time of visit; time spent on and logged in to the Websites; pages viewed; and clickstream data.

We disclose this category for the business purposes described in Section 11. We do not sell it. Section 10.4 explains the limited circumstances in which the use of advertising cookies could be treated as sharing under state law.

Category G: Geolocation data. Approximate location derived from IP address, and city, county, ZIP code, or service area that you provide so that we can identify Benefits available in your area. We do not collect precise geolocation from your device unless you affirmatively enable that feature and grant permission through your device settings.

We disclose this category for the business purposes described in Section 11. We do not sell it, and we do not share it for cross-context behavioral advertising.

Category H: Sensory data. Audio recordings of customer support telephone calls, where permitted by law and where you are notified at the outset of the call; and content of text messages exchanged through our SMS program. We do not collect electronic, visual, thermal, olfactory, or similar information other than as stated.

We collect this category only in the limited circumstances described above. We disclose it for the business purposes described in Section 11. We do not sell it or share it for cross-context behavioral advertising.

Category I: Professional or employment-related information. Current or past job history; employer; employment status; work hours; and income derived from employment. For job applicants and personnel, see Section 24.

We disclose this category for the business purposes described in Section 11. We do not sell it, and we do not share it for cross-context behavioral advertising.

Category J: Non-public education information (as defined under the Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g). We do not routinely collect education records. We may collect self-reported educational attainment where it is an eligibility criterion for a Benefit.

Our collection of this category is limited to the circumstances described above. We disclose it for the business purposes described in Section 11. We do not sell it or share it for cross-context behavioral advertising.

Category K: Inferences drawn from other personal information. Profiles reflecting an individual’s preferences, characteristics, predispositions, needs, and aptitudes, including the Aging-In-Place Score and related sub-scores, risk indicators, and Benefit-match recommendations generated by the ALBERTai platform. See Section 8 for a detailed description of how these inferences are generated and your rights with respect to them.

We generate this category ourselves rather than collecting it from you. We disclose it for the business purposes described in Section 11. We do not sell it or share it for cross-context behavioral advertising.

Category L: Sensitive personal information. See Section 6 below.

6. SENSITIVE PERSONAL INFORMATION

Because the Services help individuals qualify for need-based Benefits, some of the information we collect is treated as “sensitive personal information” under the CCPA and as “sensitive data” under the comprehensive privacy laws of Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, among others.

Depending on the Benefit you request, we may collect the following sensitive categories:

• Personal information revealing racial or ethnic origin
• Personal information revealing religious or philosophical beliefs
• Personal information revealing citizenship or immigration status
• Information concerning your health, including physical and mental health conditions, functional and mobility status, activities of daily living, cognitive status, diagnoses, treatments, medications, and care needs
• Information concerning pregnancy or childbirth
• Information concerning a history of drug or alcohol use or substance use disorder treatment
• Information concerning disability status
• Information concerning sex life or sexual orientation
• Information concerning status as a victim of crime, abuse, neglect, or domestic violence, where relevant to a Benefit
• Criminal history and justice-involvement information, where a Benefit provider requires it
• Precise geolocation, only where you affirmatively enable it
• Account log-in credentials in combination with a password or credentials allowing access to an account
• Financial account information, including a financial account number in combination with a required security or access code, where a Benefit provider or payment requires it
• Information about children in your household, including their dates of birth
• Genetic information, only in the rare case where a Benefit program requires it

Why we collect it. We collect sensitive personal information for the limited purpose of determining your potential eligibility for Benefits, generating an Aging-In-Place Score you have requested, transmitting an application at your direction to the Benefit provider you have selected, providing customer support, and complying with legal obligations.

Consent. In states that require opt-in consent before processing sensitive data, we will obtain your consent before collecting or processing sensitive data, and you may withdraw that consent at any time by contacting us at UnityInfo@unityglobalcare.com. Withdrawing consent will not affect the lawfulness of processing that occurred before withdrawal, but may mean we can no longer help you apply for certain Benefits. Where you are a known child, we obtain consent in accordance with Section 23.

Limits on our use. We do not use or disclose sensitive personal information for purposes other than those permitted under California Civil Code § 1798.121 and the implementing regulations. Those permitted purposes include performing the Services you requested, ensuring security and integrity, short-term transient use, performing services on our behalf, verifying or maintaining quality, and other purposes that do not infer characteristics about you. Because our use is limited to these permitted purposes, we are not required to offer, and do not separately offer, a “Limit the Use of My Sensitive Personal Information” link. If our practices change, we will update this Policy and provide the required mechanism.

We do not sell sensitive personal information. We do not sell or share sensitive personal information, and we do not process it for targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects, except where you have expressly directed us to submit an application on your behalf.

7. HOW WE COLLECT INFORMATION AND THE SOURCES OF THAT INFORMATION

We obtain personal information from the following categories of sources.

7.1 Information You Provide Directly to Us

You are free to search and browse the Websites without providing any information about yourself. We collect information you provide when you:

• Create an account. We collect your email address, a password you create, your name, and other information identifying your membership with us. An account is required to save Benefits or providers to a personalized favorites list, to track applications, or to apply for Benefits through our Websites.
• Request an Aging-In-Place Score or assessment. We collect the responses you provide to our assessment questions, which may include health, functional, housing, financial, caregiving, and household information.
• Apply for or inquire about a Benefit. The third-party Benefit provider, and not Unity Global Care, determines the scope of the information it wishes us to collect from you. Depending on the particular Benefit, and in accordance with the provider’s instructions, we may request information including: name; mailing address; telephone number; date of birth; gender; whether you have proof of identification such as a Social Security number, passport, or state driver’s license (but not the details associated with that identification); information about children, including birthdates; living situation (house, apartment, shelter, facility, or other); information about your health and wellness; whether you are pregnant; history of drug or alcohol use; insurance coverage; criminal history; income information (employment, government benefits, child support, pension, and similar); and additional program-specific eligibility criteria, which vary by program.
• Report a change. If you believe information on our Websites is inaccurate or out of date, you may use the “Report A Change” function and provide additional or revised information. We use this information only to review and update our Websites. Comments submitted through this function are not publicly available, but we may share your comments on an anonymized basis with the Benefit provider so that we may update our listings.
• Enroll in our SMS program. We collect your mobile telephone number, mobile carrier, and the date, time, and content of messages, along with other information you provide. Your mobile carrier may also collect data from you, as described in the carrier’s own privacy policy.
• Contact customer support. We collect your name, contact information, and the contents of your inquiry, including any attachments.
• Refer a friend. If you choose to send another person information about a Benefit listed on our Websites, we collect your email address, your friend’s email address, and any message you wish to share. We will send the Benefit information to your friend along with your message and email address. We use your friend’s email address only for this purpose.
• Participate in surveys, webinars, events, or research. We collect the information you elect to provide.
• Apply for employment. See Section 24.

The program or agency determines the application process. If you do not want to apply through our Websites, please contact the program or agency directly to determine whether an alternative application process is available.

7.2 Information We Receive from Others About You

We may receive your information from a third party, including your name, contact information, and other details, as part of an information-sharing arrangement or a referral to a Benefit through the Websites. Sources may include:

• Business clients who license the ALBERTai platform, and their authorized personnel
• Referring health care providers, care managers, discharge planners, social workers, and community-based organizations, where you or your authorized representative has directed the referral
• Family members, caregivers, guardians, powers of attorney, and other authorized representatives acting on your behalf
• Benefit providers and program administrators, who may report application status, eligibility determinations, or enrollment outcomes back to us
• Government and charitable program registries and public databases
• Service providers, including identity verification, fraud prevention, address standardization, and analytics vendors
• Publicly available sources and lawfully obtained commercial data sources

7.3 Information You Provide About Other People

We may collect information from you about someone else, such as a parent, spouse, or child for whom you are seeking Benefits. If you provide information about someone else, you represent and warrant that you are authorized to disclose that information to Unity Global Care and ALBERTai, and that, without Unity Global Care taking any further steps required by applicable data privacy laws, we may collect, use, and disclose that information for the purposes described in this Policy. You are responsible for informing that person about this Policy. If you are not authorized, do not submit the information.

7.4 Information Collected Automatically

We and our service providers use cookies, pixels, tags, software development kits, server logs, and similar technologies to automatically collect information when you visit our Websites or use our Services, including your IP address, browser type, domain name, operating system, device identifiers, date and time of visit, referring website, time spent on and logged in to the Websites, and pages viewed. See Section 10.

8. AUTOMATED PROCESSING, PROFILING, AND ARTIFICIAL INTELLIGENCE

Because ALBERTai uses automated processing to generate the Aging-In-Place Score and Benefit-match recommendations, we want to be clear about how that works and what rights you have.

ALBERTai analyzes the information you (or an authorized person acting for you) supply, including household composition, housing type and accessibility, functional and mobility status, health and wellness responses, caregiving supports, income and insurance information, and geographic location, together with information about available Benefits and providers. It produces an Aging-In-Place Score, related sub-scores or indicators, and a ranked set of programs, services, and providers that may fit your situation.

The Aging-In-Place Score is an informational and educational tool. It is not a medical diagnosis, a clinical assessment, a determination of eligibility for any Benefit, an insurance underwriting decision, a credit decision, a housing decision, or an employment decision. Unity Global Care does not determine whether you qualify for any Benefit. Each Benefit provider makes that determination under its own criteria and through its own process. We do not apply for any Benefit on your behalf without your knowledge and direction.

Score outputs and recommendations are advisory. You decide whether to act on them, and to which providers, if any, you wish us to transmit an application. Our staff are available to review a score with you and to correct information you believe is inaccurate.

Your rights regarding profiling. Residents of states including California, Colorado, Connecticut, Delaware, Florida, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, and Virginia have the right to opt out of profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning them. We do not currently use profiling to make solely automated decisions producing legal or similarly significant effects. If we do so in the future, we will update this Policy and provide a mechanism to opt out before that processing begins.

Additional rights for Minnesota residents. If you are a Minnesota resident and personal data about you was profiled in furtherance of a decision that produced a legal or similarly significant effect, you have the right to question the result of that profiling, to be informed of the reason the profiling resulted in that decision, to be informed of what actions you might take to secure a different decision in the future, to review the personal data used in the profiling, and, if the decision was based on inaccurate personal data, to have the data corrected and the profiling re-evaluated. To exercise these rights, contact us at UnityInfo@unityglobalcare.com.

Accuracy, testing, and oversight. We take reasonable steps to test the models and logic underlying the Aging-In-Place Score for accuracy and for unlawful discriminatory effects, to document their intended uses and known limitations, to maintain human oversight, and to provide notice when you are interacting with an automated system. Where a state artificial intelligence or automated decision-making technology law imposes additional disclosure, assessment, or notification obligations on us, we will comply with those obligations and will notify affected individuals as required.

We do not use your personal information to train third-party generative models. We do not sell or provide your personal information to third parties for the purpose of training their general-purpose artificial intelligence models. Where we improve our own models, we use de-identified or aggregated data wherever practicable.

Questions. If you believe an Aging-In-Place Score or recommendation is based on inaccurate information, contact us at UnityInfo@unityglobalcare.com or 800.315.1217 and we will review the underlying data and correct it where appropriate.

9. HOW WE USE YOUR INFORMATION

We use personal information for the following business and commercial purposes.

To provide the Services you request. To create and administer your account; to generate an Aging-In-Place Score; to identify Benefits for which you may be eligible; to prepare and transmit applications and referrals at your direction; to save favorites; and to track the status of applications and referrals.

To communicate with you. To respond to your requests, questions, and support inquiries; to send transactional and service messages about your account, applications, and referrals; to send appointment, deadline, renewal, and recertification reminders; and to notify you of changes to the Services or to this Policy.

To recommend other programs and services. We may use your profile information to identify other programs and services that we believe would be of interest to you, and we may email or text you about them if you have not opted out. We will not, however, apply for any Benefits on your behalf without your knowledge.

To operate, maintain, and improve the Services. For troubleshooting, technical support, debugging, quality assurance, capacity planning, and to better understand how users access and use our Websites and Services, on both an aggregated and an individualized basis; and to develop new features, content, scoring methodologies, and provider matches.

For research, analytics, and reporting. To produce aggregate and de-identified analyses regarding unmet need, service gaps, program utilization, and outcomes; and to report aggregate, de-identified metrics to business clients, funders, grantors, and community partners.

For security and integrity. To detect, investigate, prevent, and respond to fraud, unauthorized access, security incidents, malicious or deceptive activity, and violations of our Terms of Service; to authenticate users; and to protect the rights, property, and safety of Unity Global Care, our users, and the public.

For legal and compliance purposes. To comply with applicable laws, regulations, subpoenas, court orders, and lawful requests from government authorities; to establish, exercise, or defend legal claims; to conduct audits; and to enforce our agreements.

For corporate transactions. In connection with a merger, acquisition, financing, reorganization, sale of assets, or bankruptcy, as described in Section 11.

For any other purpose disclosed to you at the time of collection or to which you consent.

We will not collect additional categories of personal information, or use personal information we collected for materially different, unrelated, or incompatible purposes, without first providing you notice and, where required, obtaining your consent.

Data minimization. We limit our collection, use, retention, and sharing of personal information to what is adequate, relevant, and reasonably necessary to accomplish the purposes described in this Policy or as otherwise permitted or required by law. Residents of states such as Maryland benefit from heightened minimization standards, which we apply as required by law.

10. COOKIES, TRACKING TECHNOLOGIES, ANALYTICS, AND ADVERTISING

10.1 What We Use

We and our third-party service providers use cookies and other tracking mechanisms to collect information about your use of our Websites and Services. We may combine this information with other personal information we collect from you, and our third-party service providers may do so on our behalf.

Cookies. When you come to the Websites, our web server sends a cookie to your device. Cookies are alphanumeric identifiers transferred to your device through your web browser for record-keeping purposes. There are two general types:

• Session cookies exist only during an online session. They disappear from your device when you close your browser or turn off your device. We use session cookies to allow our systems to uniquely identify you while you are logged into the Websites, to process your online transactions and requests, and to verify your identity as you move through our Websites.
• Persistent cookies remain on your device after you have closed your browser or turned off your device. We may use persistent cookies to remember your preferences and to track aggregate and statistical information about user activity, which may be combined with other user information.

We also may permit certain third-party cookies to be placed on our Websites.

Pixels, tags, and web beacons. Small graphic images or code snippets that record whether a page or email was opened, which links were clicked, and similar interaction data.

Local storage and software development kits. Technologies that store information locally on your device to support functionality and performance.

Server logs. Records automatically generated when your device connects to our servers.

10.2 Categories of Cookies by Purpose

• Strictly necessary. Required for the Websites to function, to authenticate you, to maintain your session, to balance load, and to protect security. These cannot be disabled through our preference tools.
• Functional. Remember your preferences, language, and prior inputs.
• Analytics and performance. Help us understand how the Websites are used so that we can improve them.
• Advertising and marketing. Where used, help us measure the effectiveness of our campaigns and, in some cases, reach individuals who have visited our Websites. See Section 10.4.

10.3 Third-Party Analytics

We may use automated devices and applications, such as Google Analytics, to evaluate usage of our Websites, and we may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance, and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not have access to or control over these third-party cookies, and this Policy does not cover such third parties’ independent use of data.

In addition, ALBERTai offers functionality that allows certain business clients with their own site integrations to use automated devices and applications, such as Google Analytics, and other analytic means to evaluate the Services. For information about a business client’s use of third-party analytics, please review the privacy policy of the ALBERTai client associated with your use of ALBERTai.

You may be able to opt out of or restrict the collection or use of information by some commonly used tracking pixels and services. The following links are provided for your convenience and may change without notice:

• Google Analytics: https://tools.google.com/dlpage/gaoptout/
• Meta (Facebook) advertising preferences: https://www.facebook.com/settings?tab=ads
• Microsoft (Bing) opt-out: https://choice.microsoft.com/en-US/opt-out
• Digital Advertising Alliance: https://optout.aboutads.info
• Network Advertising Initiative: https://optout.networkadvertising.org
• Google advertising settings: https://adssettings.google.com

10.4 Advertising and “Sale” or “Sharing” Under State Law

We do not sell your personal information for monetary consideration.

Certain state privacy laws define “sale” broadly to include disclosures for other valuable consideration, and define “sharing” or “targeted advertising” to include the disclosure of personal information to a third party for cross-context behavioral advertising. To the extent we use advertising or analytics cookies that transmit online identifiers to a third-party advertising network, that activity could be characterized as a “sale” or “sharing” under those laws. We do not knowingly engage in such activity in connection with any health-related information, sensitive personal information, or information submitted in connection with a Benefit application.

If and to the extent we engage in “sharing” or “targeted advertising” through advertising cookies, you may opt out at any time by:

• Using the cookie preference controls available on our Websites, where offered
• Transmitting an opt-out preference signal such as Global Privacy Control (see Section 10.6)
• Emailing UnityInfo@unityglobalcare.com with the subject line “Do Not Sell or Share My Personal Information”
• Calling 800.315.1217

We do not knowingly sell or share the personal information of consumers under 16 years of age. We have no actual knowledge of any such sale or sharing.

10.5 Disabling Cookies

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors who disable their browsers’ ability to accept cookies will still be able to browse the Websites; however, you must enable cookies to use most of our Services. Disabling cookies may also delete previously set opt-out cookies, which may cause opt-out preferences stored in cookies to be lost.

10.6 Do Not Track and Opt-Out Preference Signals

Do Not Track. Some browsers offer a “Do Not Track” (“DNT”) setting. There is no uniform industry standard for how to respond to DNT signals. Our systems do not currently respond to browser DNT signals. You may, however, disable certain tracking as described in this Section.

Global Privacy Control and universal opt-out mechanisms. We honor the Global Privacy Control (“GPC”) and other universal opt-out mechanisms recognized under the laws of California, Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, and other states that require recognition of such signals. If you transmit a valid opt-out preference signal from your browser or device, we will treat it as a request to opt out of the sale and sharing of personal information associated with that browser or device, and of processing for targeted advertising. Because such a signal is typically browser- and device-specific, you should transmit it from each browser and device you use. If you are logged into your account when the signal is received, we will apply the opt-out to your account as well. You can learn more at https://globalprivacycontrol.org.

11. HOW WE DISCLOSE YOUR INFORMATION

We share your information primarily at your direction. With the limited exceptions discussed below, we do not share your information with third parties unless you agree in advance. We will not share your personal information under any circumstance with any third party for that third party’s own direct marketing purposes unless you are first notified and, where required by law, provide consent.

In the preceding twelve (12) months, we have disclosed the categories of personal information described in Section 5 for a business purpose to the following categories of recipients.

11.1 With Third Parties That Provide Benefits

We primarily share your information, including your personal information, with the third parties that provide the Benefits you would like to receive. Specifically, at your direction, we submit your application or inquiry to the appropriate third parties. The third party, not Unity Global Care or ALBERTai, evaluates your eligibility to obtain service from its program. The third party’s use of your personal information is governed by that third party’s own privacy policy. Unity Global Care and ALBERTai do not have control over your information once it is submitted to a third party for receipt of Benefits.

For example, if you are interested in transportation services, we will share your information, at your direction, with agencies that provide transportation that may fit your particular situation. In some instances, your information may be shared with third parties who are providing grants, financial assistance, or other support for the programs to which you are applying.

In sharing your personal information with third-party providers, such information will be provided to each and every third party that you request. By consenting to this sharing, you further agree that the third parties themselves may also collaborate and share your information solely in support of the service that you are seeking. To the extent that any other information is generated from that collaboration and is stored in the ALBERTai platform, such information will be deemed to be covered by this Policy.

ALTHOUGH WE SHARE INFORMATION WITH THIRD PARTIES AT YOUR DIRECTION, WE ARE NOT RESPONSIBLE FOR THE ACTS AND OMISSIONS OF THIRD PARTIES.

11.2 With Service Providers Performing Services on Our Behalf

We may engage vendor companies to provide limited services on our behalf, such as website hosting, cloud infrastructure, data storage, payment processing, sending postal and electronic mail, text message delivery, customer relationship management, identity verification, fraud prevention, analytics, security monitoring, professional advisory services, and technical support, and to assist us in providing the products and services that you request from us. We provide those service providers only with the information necessary to perform the requested service, and we require them by contract to protect the information, to use it only for the purposes we specify, and not to sell it or retain, use, or disclose it for any other purpose.

11.3 With Business Clients

Where you access the Services through, or were referred by, a business client of Unity Global Care (such as a health system, payer, employer, senior living operator, agency, or community organization), we may share information with that client in accordance with our agreement with them and with the consent or authorization you provided.

11.4 With a Third-Party Support System

If you submit a support request through a third-party support service we use, you will be asked to provide certain information, including without limitation your name and email address. Support requests are operated by a third-party support and contact request management service provided by the support organization. Participation in this service is entirely at your discretion and is governed by that support organization’s privacy policy.

11.5 With Your Friends and Other Persons at Your Direction

You have the option of sending another person information about Benefits listed on our Websites, as described in Section 7.1.

11.6 With Your Authorized Representatives

With family members, caregivers, guardians, agents under a power of attorney, or other representatives you have authorized, or who are authorized by law, to act on your behalf.

11.7 In Connection with a Corporate Transaction

If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy or similar proceeding, we may transfer the information we have collected from you to the other company or to a prospective acquirer under an obligation of confidentiality. We will provide notice as required by law, and any successor will be bound by commitments made in this Policy unless and until you are notified of a change.

11.8 To Protect Ourselves and for Legal Purposes

We may disclose your information to protect our rights and property, to prevent fraud and abuse, and to protect other users of our Services. For example, if we believe that you are misusing our Websites or taking an action that is harming our Websites (such as uploading a virus), we may share your information with law enforcement to protect our Services. We also may disclose your information as permitted or required by law, including in response to court orders, subpoenas, warrants, or other requests from government agencies, or where we believe in good faith that disclosure is necessary to prevent imminent physical harm or serious financial loss, or to report suspected illegal activity.

Requests concerning reproductive health, immigration status, and similar sensitive matters. Where permitted by applicable law, we will resist overbroad or improper requests, will require valid legal process, and will notify you of a request for your information unless we are legally prohibited from doing so or notification would present a risk to life or safety.

11.9 With Affiliates

With our parent, subsidiary, and affiliated entities, for the purposes described in this Policy and subject to the same protections.

11.10 Aggregated and De-Identified Information

We may disclose aggregated or de-identified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual. See Section 20.

12. DATA RETENTION

We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, including to provide the Services, to maintain a record of Benefits applied for and referrals made, to comply with our legal, contractual, accounting, grant-reporting, and audit obligations, to resolve disputes, and to enforce our agreements.

We do not retain personal information for longer than is reasonably necessary for the disclosed purpose. Because retention periods depend on context, we apply the following general criteria and periods, which may be extended where a legal hold, investigation, dispute, or regulatory obligation applies:

• Account records (identifiers, credentials, profile): for the life of the account and for up to twenty-four (24) months after the account is closed or becomes inactive.
• Benefit application and referral records (including eligibility information and sensitive data submitted with an application): for the period required by the applicable program, funder, or grantor, and otherwise for up to seven (7) years, which reflects common federal and state grant and program record-retention requirements.
• Aging-In-Place Score inputs and outputs: for the life of the account and for up to twenty-four (24) months after closure, after which we retain only de-identified or aggregated data.
• SMS program records (mobile number, consent record, message logs): for the duration of your enrollment and for at least four (4) years after opt-out, in order to demonstrate consent and honor your opt-out as required under telecommunications rules.
• Customer support records: up to thirty-six (36) months after the matter is closed.
• Website and device logs, analytics, and cookie data: generally up to twenty-six (26) months, and often much less.
• Financial and transaction records: up to seven (7) years, as required by tax and accounting rules.
• Marketing preferences and suppression lists: indefinitely, so that we can continue to honor your opt-out.
• Records required for legal defense or compliance: for the duration of the applicable statute of limitations or regulatory retention period.

When personal information is no longer needed, we delete it, de-identify it, or render it not reasonably capable of being associated with you, using commercially reasonable methods. Information may persist for a limited period in encrypted backup or disaster recovery systems, from which it is deleted on our regular backup rotation cycle.

13. SECURITY OF YOUR INFORMATION

We want the information that you submit to us to be secure. We use industry-standard administrative, technical, physical, and organizational safeguards designed to protect the information that you provide to us through our Websites. These measures may include encryption of data in transit and at rest, access controls and role-based permissions, multi-factor authentication for administrative access, network monitoring and logging, vulnerability management, vendor security assessment, personnel training, and written incident response procedures.

Notwithstanding our commitment to safeguarding your information, please be aware that there is a risk that others could find a way to thwart our security systems or the security systems of the third parties that host our servers. No method of transmission over the internet or method of electronic storage is completely secure. As a result, we cannot ensure or warrant the security or privacy of any information that you choose to submit to us.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, enabling multi-factor authentication where offered, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords, or for any activity on your account resulting from unauthorized password activity. Please notify us immediately at UnityInfo@unityglobalcare.com if you believe your account has been compromised.

Breach notification. If we become aware of a security incident affecting your personal information, we will investigate promptly and will notify you and the appropriate regulators as required by applicable state and federal breach notification laws, within the timeframes those laws prescribe.

14. YOUR PRIVACY RIGHTS UNDER STATE PRIVACY LAWS

Depending on your state of residence and subject to certain exceptions and verification requirements, you may have some or all of the following rights. Where a right is available to you under the law of your state, we will honor it regardless of whether it is separately listed in the state-specific sections below.

Right to know and to access personal information. You may ask us to confirm whether we are processing your personal information and to give you access to it. This includes the categories of personal information collected, the categories of sources, the business or commercial purposes for collecting, selling, or sharing it, the categories of third parties to whom we disclose it, and the specific pieces of personal information we have collected about you.

Right to obtain a list of third parties. In certain states, including Delaware, Minnesota, Oregon, and Rhode Island, you may request a list of the specific third parties (rather than only the categories of third parties) to which we have disclosed your personal data, or to which we have disclosed any consumer’s personal data, as the applicable statute provides.

Right to data portability. You may request a copy of your personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit it to another entity without hindrance.

Right to correct. You may ask us to correct inaccurate personal information we maintain about you. In responding, we consider the nature of the information and the purposes for which we process it.

Right to delete. You may ask us to delete personal information we have collected from or about you, subject to exceptions permitted by law. Exceptions apply where retention is necessary to complete a transaction, provide a service you requested, detect security incidents, comply with a legal obligation, exercise free speech, or conduct research in the public interest.

Right to opt out of the sale of personal information. We do not sell personal information for monetary consideration, so there is no sale for you to opt out of.

Right to opt out of sharing and targeted advertising. You may direct us not to process your personal information for targeted advertising or cross-context behavioral advertising. See Section 10.4.

Right to opt out of profiling. You may direct us not to profile you in furtherance of solely automated decisions that produce legal or similarly significant effects. See Section 8.

Right to limit our use and disclosure of sensitive personal information. Section 6 describes how we handle sensitive personal information and why this right operates as it does.

Right to withdraw consent. Where we rely on your consent, you may withdraw it at any time. We give effect to a withdrawal as soon as reasonably practicable, and in no event later than fifteen (15) days after we receive it.

Right to non-discrimination and against retaliation. We will not discriminate or retaliate against you for exercising any privacy right. We will not deny you goods or services, charge you a different price or rate, provide you a different level or quality of service, or suggest that we will do any of these things because you exercised a privacy right. We also will not retaliate against an employee, applicant, or independent contractor for exercising privacy rights.

Right to appeal. In states that provide for it, you may appeal our refusal to act on a request. See Section 15.5.

15. HOW TO EXERCISE YOUR RIGHTS

15.1 How to Submit a Request

You may submit a privacy rights request using either of the following methods:

• Email: UnityInfo@unityglobalcare.com with the subject line “Privacy Request”
• Toll-free telephone: 800.315.1217

You may also write to us at Unity Global Care, Inc., Attn: Privacy, 203 Main Street, No. 179, Flemington, New Jersey 08822.

Please include your full name, the email address and telephone number associated with your account (if any), your state of residence, and a description of the right you wish to exercise. Providing this information helps us locate your records and verify your identity.

15.2 Verification

Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. We will take commercially reasonable steps to verify that the person making the request is the consumer about whom we have collected personal information, or that person’s authorized agent. Depending on the sensitivity of the information requested and the risk of harm from unauthorized disclosure, verification may require you to confirm information already in our records, to log in to your account, or to provide a signed declaration under penalty of perjury. We will not require you to create an account solely to make a request. We use information provided for verification only for that purpose, and we delete it as soon as practicable after processing the request. If we cannot verify your identity, we will notify you and explain why.

15.3 Authorized Agents

You may designate an authorized agent to submit a request on your behalf. We may require the agent to provide written permission signed by you, may require you to verify your own identity directly with us, and may require the agent to verify its own identity. An agent holding a valid power of attorney under applicable probate law need not provide separate written permission, but must furnish proof of the power of attorney.

15.4 Response Timelines

We will acknowledge receipt of your request within ten (10) business days where required by law. We will respond to a verified request within forty-five (45) days of receipt. If we need more time, we will notify you of the extension and the reason for it, and we may take up to an additional forty-five (45) days, for a total of ninety (90) days, where permitted. For requests governed by the Washington My Health My Data Act, we respond within forty-five (45) days, with a single extension of up to fifteen (15) additional days where reasonably necessary.

There is no charge for exercising your rights, and we will honor at least two (2) free requests per twelve-month period. If a request is manifestly unfounded, excessive, or repetitive, we may charge a reasonable administrative fee or decline to act, and we will explain why.

15.5 Appeals

If we decline to take action on your request, you may appeal that decision within a reasonable period by emailing UnityInfo@unityglobalcare.com with the subject line “Privacy Appeal,” or by writing to us at the address in Section 15.1. Please include a copy of our original response and an explanation of why you believe the decision should be reconsidered.

We will review the appeal and inform you in writing of our decision, and the reasons for it, within forty-five (45) days of receipt, or within sixty (60) days in states where that period applies. If your appeal is denied, we will provide you with a method to contact your state Attorney General or other applicable regulator to submit a complaint.

15.6 If We Act as a Service Provider

For consumers whose information we process as a service provider or processor on behalf of a business client, we will direct you to exercise your rights through that client, or will act on the client’s documented instructions, as described in Section 4.

16. ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

This Section supplements the rest of this Policy and applies to residents of the State of California. It is provided pursuant to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the “CCPA”), and its implementing regulations.

16.1 Notice at Collection

The categories of personal information and sensitive personal information we collect, the purposes for which each category is used, whether each category is sold or shared, and the retention period or criteria for each category are described in Sections 5, 6, 9, 10, and 12 above.

16.2 Categories Collected, Sold, Shared, and Disclosed in the Preceding 12 Months

In the preceding twelve months, we have collected the categories of personal information identified in Section 5. We have disclosed each of those categories for a business purpose to the categories of recipients identified in Section 11.

We have not sold personal information for monetary consideration, and we have not shared personal information for cross-context behavioral advertising other than as described in Section 10.4. We have not sold or shared the personal information of consumers we know to be under 16 years of age, and we have no actual knowledge of any such sale or sharing.

16.3 Your CCPA Rights

California residents have the rights described in Section 14, including the right to know, the right to delete, the right to correct, the right to opt out of sale or sharing, the right to limit the use and disclosure of sensitive personal information (subject to Section 6), and the right to non-discrimination and against retaliation. Instructions for exercising these rights appear in Section 15.

16.4 Right to Opt Out of Sale or Sharing

We do not sell personal information. To the extent any activity described in Section 10.4 constitutes “sharing,” you may opt out by emailing UnityInfo@unityglobalcare.com with the subject line “Do Not Sell or Share My Personal Information,” by calling 800.315.1217, by using the “Do Not Sell or Share My Personal Information” link where posted on our Websites, or by transmitting a Global Privacy Control signal. We honor opt-out preference signals as described in Section 10.6.

16.5 Notice of Financial Incentive

We do not offer financial incentives, price differences, or service-level differences in exchange for the retention or sale of personal information.

16.6 California “Shine the Light” Law

California Civil Code § 1798.83 permits California residents who have an established business relationship with us to request, once per calendar year, information about the categories of personal information (if any) that we disclosed to third parties for those third parties’ direct marketing purposes, and the names and addresses of those third parties. We do not disclose personal information to third parties for their own direct marketing purposes. To make a Shine the Light request, email UnityInfo@unityglobalcare.com with “California Shine the Light Request” in the subject line.

16.7 Removal of Content Posted by California Minors

If you are a California resident under the age of 18 and a registered user of any website where this Policy is posted, California Business and Professions Code § 22581 permits you to request and obtain removal of content or information that you have publicly posted. To make such a request, send an email with a detailed description of the specific content or information to UnityInfo@unityglobalcare.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted, and that there may be circumstances in which the law does not require or allow removal even if requested.

16.8 California Online Privacy Protection Act (CalOPPA)

We disclose our online tracking practices and our response to Do Not Track signals in Section 10.6. We will post material changes to this Policy as described in Section 26.

16.9 Employees, Applicants, and Contractors

California residents who are our employees, job applicants, owners, directors, officers, medical staff members, or independent contractors have CCPA rights with respect to personal information collected in that context. See Section 24.

16.10 Contact for California Residents

For questions about your California privacy rights, contact UnityInfo@unityglobalcare.com or 800.315.1217. If you have a complaint that we have not resolved, you may contact the California Privacy Protection Agency or the California Attorney General.

17. ADDITIONAL DISCLOSURES FOR COLORADO RESIDENTS

This Section is provided pursuant to the Colorado Privacy Act (“CPA”) and its rules.

Colorado residents have the rights of access, correction, deletion, portability, opt-out of targeted advertising, opt-out of the sale of personal data, opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects, and the right to appeal, as described in Sections 8, 14, and 15.

Universal opt-out mechanism. We recognize and honor universal opt-out mechanisms appearing on the Colorado Attorney General’s public list, including Global Privacy Control. See Section 10.6.

Consent for sensitive data. We process sensitive data concerning Colorado residents only with consent, and only for the purposes described in Section 6. We obtain consent from a parent or lawful guardian before processing the sensitive data of a known child.

Appeals. Colorado residents may appeal as described in Section 15.5. If your appeal is denied, you may contact the Colorado Attorney General at https://coag.gov/file-complaint/.

Biometric identifiers. As stated in Section 5, we do not collect biometric identifiers or biometric data.

Minors. We do not use a system design feature to significantly increase, sustain, or extend a minor’s use of the Services, and we do not process a minor’s personal data for targeted advertising, sale, or certain profiling without consent.

18. ADDITIONAL DISCLOSURES FOR VIRGINIA, CONNECTICUT, UTAH, AND TEXAS RESIDENTS

Virginia. Under the Virginia Consumer Data Protection Act, Virginia residents have the rights of access, correction, deletion, portability, opt-out of targeted advertising, opt-out of the sale of personal data, opt-out of profiling in furtherance of decisions producing legal or similarly significant effects, and appeal. We obtain consent before processing sensitive data. Appeals are handled under Section 15.5; if denied, you may contact the Virginia Attorney General at https://www.oag.state.va.us/.

Connecticut. Under the Connecticut Data Privacy Act, Connecticut residents have the same core rights, plus the right to have us honor an opt-out preference signal, the right to withdraw consent, and the right to appeal. We do not process the personal data of a consumer we know to be between 13 and 16 years of age for targeted advertising or sale without consent. Complaints may be directed to the Connecticut Attorney General.

Utah. Under the Utah Consumer Privacy Act, Utah residents have the right to confirm processing and access personal data, the right to delete personal data they provided, the right to obtain a copy of personal data, the right to opt out of targeted advertising, and the right to opt out of the sale of personal data. We provide clear notice and an opportunity to opt out before processing sensitive data, and we obtain consent for a known child in accordance with COPPA.

Texas. Under the Texas Data Privacy and Security Act, Texas residents have the rights of access, correction, deletion, portability, opt-out of targeted advertising, opt-out of the sale of personal data, opt-out of profiling in furtherance of decisions producing legal or similarly significant effects, and appeal. We do not sell sensitive personal data, and we do not sell biometric personal data. Because we do not engage in such sales, the specific notices required by Texas Business and Commerce Code § 541.102 for the sale of sensitive or biometric personal data do not apply to us. If our practices change, we will post the required notice. Texas residents may submit complaints to the Texas Attorney General at https://www.texasattorneygeneral.gov/consumer-protection.

19. ADDITIONAL DISCLOSURES FOR RESIDENTS OF OTHER STATES

The following state-specific provisions supplement the rights described in Sections 14 and 15. Where a state law becomes effective or is amended after the date of this Policy, we will comply with it as of its effective date whether or not this Section has yet been updated.

Delaware. Under the Delaware Personal Data Privacy Act, Delaware residents have the rights of access, correction, deletion, portability, opt-out of targeted advertising, sale, and profiling, and appeal. Delaware residents may also obtain a list of the categories of third parties to which we have disclosed personal data. We obtain consent before processing sensitive data, and we do not process the personal data of a consumer we know to be between 13 and 17 years of age for targeted advertising or sale without consent.

Oregon. Under the Oregon Consumer Privacy Act, Oregon residents have the core rights described above and may additionally request a list of the specific third parties, by name, to which we have disclosed the consumer’s personal data or any personal data. We obtain consent before processing sensitive data. Complaints may be directed to the Oregon Attorney General.

Minnesota. Under the Minnesota Consumer Data Privacy Act, Minnesota residents have the core rights described above; the right to obtain a list of the specific third parties to which we have disclosed personal data; the right to question the result of profiling and obtain an explanation, as described in Section 8; and the right to appeal. We maintain a data privacy and security policy and have designated personnel responsible for it; you may request a description of those practices at UnityInfo@unityglobalcare.com.

Maryland. Under the Maryland Online Data Privacy Act, Maryland residents have the core rights described above. Maryland imposes heightened obligations, which we observe: we limit collection of personal data to what is reasonably necessary and proportionate to provide or maintain a specific product or service requested by the consumer; we do not sell sensitive data; we do not process sensitive data except where strictly necessary to provide or maintain a requested product or service; and we do not sell the personal data of, or process for targeted advertising the personal data of, a consumer we know or should know is under 18 years of age.

New Jersey. Under the New Jersey Data Privacy Act, New Jersey residents have the rights of access, correction, deletion, portability, opt-out of targeted advertising, sale, and profiling, and appeal. We honor universal opt-out mechanisms. We obtain consent before processing sensitive data, which under New Jersey law includes financial information such as an account number or access code, and we do not process for targeted advertising, sale, or profiling the personal data of a consumer we know or willfully disregard to be between 13 and 17 years of age. Complaints may be directed to the New Jersey Division of Consumer Affairs.

New Hampshire. Under the New Hampshire data privacy act, New Hampshire residents have the core rights described above, including the right to appeal, and we honor universal opt-out mechanisms.

Montana. Under the Montana Consumer Data Privacy Act, Montana residents have the core rights described above, including appeal, and we honor universal opt-out mechanisms. We obtain consent before processing sensitive data and observe heightened protections for consumers known to be under 18.

Nebraska. Under the Nebraska Data Privacy Act, Nebraska residents have the core rights described above, including appeal. We do not sell sensitive data or process it without consent, and we honor universal opt-out mechanisms.

Iowa. Under the Iowa Consumer Data Protection Act, Iowa residents have the rights to confirm processing and access personal data, to delete personal data they provided, to obtain a copy of personal data, and to opt out of the sale of personal data. We provide notice and an opportunity to opt out before processing sensitive data.

Indiana. Under the Indiana Consumer Data Protection Act, Indiana residents have the rights of access, correction, deletion, portability (including the right to obtain a representative summary), opt-out of targeted advertising, sale, and profiling, and appeal.

Tennessee. Under the Tennessee Information Protection Act, Tennessee residents have the rights of access, correction, deletion, portability, opt-out of targeted advertising, sale, and profiling, and appeal. We obtain consent before processing sensitive data.

Kentucky. Under the Kentucky Consumer Data Protection Act, Kentucky residents have the rights of access, correction, deletion, portability, opt-out of targeted advertising, sale, and profiling, and appeal. We obtain consent before processing sensitive data.

Rhode Island. Under the Rhode Island Data Transparency and Privacy Protection Act, Rhode Island residents have the core rights described above. In addition, if we sell personal data to third parties or process personal data for targeted advertising, we will identify in this Policy all third parties to which we have sold or may sell a customer’s personally identifiable information. We do not sell personal data to third parties.

Florida. The Florida Digital Bill of Rights applies to certain large technology companies. To the extent it applies to us, Florida residents have the rights of access, correction, deletion, portability, opt-out of targeted advertising, sale, and profiling, opt-out of the collection of sensitive data (including precise geolocation), and opt-out of the collection of personal data through the operation of a voice or facial recognition feature. We do not use voice recognition or facial recognition features, and we do not sell sensitive data.

Nevada. Under Nevada Revised Statutes Chapter 603A, Nevada residents may submit a verified request directing us not to make any sale of covered information we have collected or will collect about them. We do not sell covered information as defined by Nevada law. To submit a request, email UnityInfo@unityglobalcare.com with the subject line “Nevada Do Not Sell Request,” and include your name, the email address associated with your account, and a statement that you are a Nevada resident. See also Section 21 regarding Nevada Senate Bill 370 and consumer health data.

Washington. See Section 21 regarding the Washington My Health My Data Act.

Illinois, Texas, and Washington biometric laws. We do not collect, capture, purchase, receive, store, or disclose biometric identifiers or biometric information as those terms are defined under the Illinois Biometric Information Privacy Act, the Texas Capture or Use of Biometric Identifier Act, or Washington’s biometric identifier statute.

Vermont, Michigan, and other states. Residents of states with data broker registration, video privacy, genetic privacy, or similar statutes retain all rights afforded by those laws. We are not a data broker, we do not collect or process genetic testing data, and we do not disclose video viewing records.

All other states. If you reside in a state whose comprehensive privacy law takes effect after the date of this Policy, we will honor the rights afforded to you under that law as of its effective date.

20. DE-IDENTIFIED AND AGGREGATED INFORMATION

Where we maintain or use de-identified information, we take reasonable measures to ensure that the information cannot be associated with an individual or household, we publicly commit to maintain and use the information in de-identified form and not to attempt to re-identify it (except as permitted by law for the purpose of testing our de-identification methods), and we contractually obligate any recipient to comply with the same restrictions.

We may create, use, and disclose aggregate statistics and reports, such as the number of users in a county who were matched to home-modification programs, for research, grant reporting, program evaluation, public policy, and business purposes. Such aggregate information does not identify you.

21. CONSUMER HEALTH DATA (WASHINGTON, NEVADA, AND CONNECTICUT)

This Section serves as our Consumer Health Data Privacy Policy for purposes of the Washington My Health My Data Act (“MHMDA”), Nevada Senate Bill 370, and the consumer health data provisions of the Connecticut Data Privacy Act. It applies to Washington and Nevada residents and to consumers whose consumer health data is collected in those states, and it supplements the balance of this Policy.

What consumer health data we collect. Consistent with Sections 5, 6, and 7, we may collect information that identifies your past, present, or future physical or mental health status, including: individual health conditions, treatment, diseases, or diagnoses; social, psychological, behavioral, and medical interventions; health-related surgeries or procedures; use or purchase of medication; bodily functions, vital signs, symptoms, or measurements; diagnoses or diagnostic testing, treatment, or medication; reproductive or sexual health information, including pregnancy status; gender-affirming care information; information about substance use; disability and functional status, including activities of daily living and mobility; caregiving needs; insurance coverage; and any information that is derived or extrapolated from non-health information, including the Aging-In-Place Score and related inferences, that is used to identify a consumer’s past, present, or future health status.

How we collect it. Directly from you through assessments, applications, account forms, support communications, and text messages; from authorized representatives and referring organizations; from business clients; and, in limited cases, from Benefit providers reporting outcomes.

Why we collect it and how we use it. To generate the Aging-In-Place Score you request; to identify Benefits for which you may be eligible; to prepare and transmit applications and referrals at your direction; to provide support; to improve and secure the Services; and to comply with legal obligations. We collect consumer health data only with your consent, or as necessary to provide a product or service you have requested.

With whom we share it. With Benefit providers you direct us to contact; with our service providers and processors, who are contractually bound to protect it and to use it only as we instruct; with business clients where you accessed the Services through them; with your authorized representatives; and as required by law. The categories of recipients are described in Section 11. We do not sell consumer health data, and we will not sell it without obtaining your valid authorization on a separate signed form that meets the requirements of RCW 19.373.030 or the equivalent Nevada requirement.

Your rights regarding consumer health data. If you are a Washington or Nevada resident, you have the right to:

• Confirm whether we are collecting, sharing, or selling your consumer health data, and to access that data, including a list of all third parties and affiliates with whom we have shared or sold it, along with an active email address or other online mechanism to contact each such recipient
• Withdraw your consent to our collection and sharing of your consumer health data
• Have your consumer health data deleted, including from our records and, where applicable, from the records of our affiliates, processors, contractors, and other third parties with whom we have shared it
• Not be discriminated against for exercising these rights

To exercise these rights, email UnityInfo@unityglobalcare.com with the subject line “Consumer Health Data Request,” or call 800.315.1217. We will respond within forty-five (45) days, with one extension of up to fifteen (15) additional days where reasonably necessary, and we will notify you of any extension and the reason for it. You may appeal a denial as described in Section 15.5. If your appeal is denied, Washington residents may submit a complaint to the Washington Attorney General at https://www.atg.wa.gov/file-complaint.

Deletion. Upon receiving a verified deletion request, we will delete your consumer health data from our records, including from all parts of our network, and will notify our affiliates, processors, contractors, and other third parties with whom we have shared the data of your request and direct them to delete it. Where deletion from archived or backup systems is not immediately feasible, we will isolate and protect the data from further processing and delete it on our next regular backup rotation.

Geofencing. We do not implement, and will not implement, a geofence around any entity that provides in-person health care services for the purpose of identifying or tracking consumers seeking health care services, collecting consumer health data, or sending notifications, messages, or advertisements related to consumer health data or health care services.

Employee and contractor access. We restrict access to consumer health data to the employees, processors, and contractors for whom access is necessary to further the purposes for which you provided consent, or as necessary to provide a service you requested. We maintain administrative, technical, and physical safeguards to protect the confidentiality, integrity, and accessibility of consumer health data.

22. HEALTH INFORMATION, HIPAA, AND OTHER SPECIALIZED LAWS

HIPAA. Unity Global Care is not a Covered Entity under the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”) with respect to the consumer-facing Services described in this Policy, and information you submit to us through the Websites is generally not Protected Health Information subject to HIPAA. Where we provide services to a Covered Entity or to another Business Associate and receive Protected Health Information in that capacity, we act as a Business Associate or Subcontractor and handle that information under the applicable Business Associate Agreement and under HIPAA, which control over any inconsistent provision of this Policy as to that information. Our HIPAA Compliance Statement describes these roles, our safeguards, and the rights available to individuals whose Protected Health Information we hold in that capacity.

Where HIPAA does not apply. Information that falls outside HIPAA is not unprotected. It remains subject to this Policy, to the consumer health data protections described in Section 21, and to the state privacy rights described in Sections 14 through 19.

42 C.F.R. Part 2. Where we receive substance use disorder treatment records from a Part 2 program, we handle those records in accordance with 42 C.F.R. Part 2 and will not redisclose them except as permitted by that regulation or with your written consent.

Text messaging and health information. If you request a referral to a program and you use text messages as your primary form of communication with us, in certain circumstances text messages may include protected health information or consumer health data by the nature of the programs to which you are referred. Because text messaging is unencrypted, there is a risk that this information could be intercepted or viewed by third parties, including others who have access to your device. When you choose to receive text messages from us, you do so at your own risk. See Section 23.

Genetic information. We do not conduct genetic testing and do not collect genetic testing results, except in the rare circumstance where a Benefit program requires it and you affirmatively provide it. In that case, we treat the information as sensitive data under Section 6.

23. SHORT MESSAGE SERVICE (SMS) AND MOBILE MESSAGING

You may opt to enroll in our SMS program. By enrolling, you represent that you are the account holder for the mobile telephone number or numbers that you provide to us. You are responsible for notifying us immediately if you change your mobile telephone number.

Consent. We send text messages only to individuals who have provided prior express consent, or prior express written consent where required. Consent to receive marketing text messages is not a condition of purchasing any goods or services or of receiving any Benefit or referral.

Message frequency and cost. Message frequency varies. We provide this service without a fee; however, message and data rates may apply from your mobile carrier. By providing your consent to participate in this program, you approve such charges from your mobile carrier. Unity Global Care and ALBERTai are not responsible for any charges related to the use of this service.

Delivery. Unity Global Care and ALBERTai do not guarantee the successful or timely delivery of text messages by your mobile carrier. Delivery of information and content to a mobile device may fail due to a variety of circumstances or conditions. You understand and acknowledge that network services, including mobile network services, are outside of our control, and that we are not responsible or liable for issues arising from them. Carriers are not liable for delayed or undelivered messages.

How to opt out. If you no longer wish to participate in our SMS program, reply with any of the keywords STOP, END, QUIT, CANCEL, or UNSUBSCRIBE to any message you receive from us, or text one of those keywords to 800.315.1217. You may receive one final message from us confirming that you have been deactivated in our system. Following that confirmation message, no additional messages will be sent unless you reactivate your SMS subscription.

How to get help. Reply HELP to any message, email UnityInfo@unityglobalcare.com, or call 800.315.1217.

Termination. Unity Global Care and ALBERTai reserve the right to terminate the SMS program, in whole or in part, at any time and without notice.

23.1 Mobile Opt-In and Consent Data

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All of the categories of information sharing described elsewhere in this Policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, other than with the aggregators, messaging platform providers, and telecommunications carriers strictly necessary to transmit the messages you have asked to receive.

24. JOB APPLICANTS, EMPLOYEES, AND CONTRACTORS

If you apply for a position with Unity Global Care, or if you are an employee, owner, director, officer, medical staff member, contractor, or emergency contact or beneficiary thereof, we may collect personal information in that context, including: identifiers; contact information; résumé and application materials; employment and education history; professional licenses and certifications; references; results of background and reference checks where permitted by law; government identification and work authorization documents; compensation and payroll information; financial account information for direct deposit; tax information; benefits enrollment and dependent information; health information necessary to administer leave and accommodations; emergency contact information; and records of performance, training, and workplace conduct.

We use this information to evaluate candidacy, administer the employment relationship, provide compensation and benefits, maintain workplace safety and security, comply with legal obligations, and defend legal claims. We disclose it to service providers such as payroll, benefits, background check, and human resources vendors, and to government agencies as required.

California residents in these categories have the rights described in Sections 14 and 15 with respect to this information. We do not sell or share personal information collected in the employment context. Retention of employment-related records follows the criteria in Section 12 and applicable recordkeeping laws.

25. ADDITIONAL PROVISIONS

25.1 Children’s and Teens’ Privacy

Our Websites are not intended for persons under the age of 13, and we do not knowingly collect personal information directly from persons under the age of 13 in violation of the Children’s Online Privacy Protection Act (“COPPA”). If we learn that a person under the age of 13 has created an account or directly applied for programs through our Websites, we will remove that information from our systems.

Please be advised, however, that certain programs offered by third parties may be applicable to persons under the age of 13, or may require us to collect information about the children in your household. In those situations, we collect information about persons under the age of 13 only from the registered adult user, who must be over the age of 13 and who represents that they are the parent, legal guardian, or otherwise authorized to provide that information.

We do not sell or share the personal information of consumers under 16 years of age, we do not process the personal data of consumers we know to be under 18 for targeted advertising or profiling, and we do not use design features intended to significantly increase, sustain, or extend a minor’s use of the Services. If you believe a child has provided us with personal information without appropriate authorization, contact us at UnityInfo@unityglobalcare.com and we will delete it.

25.2 User-Generated Content and Public Areas

We may maintain a blog or comment area on our Websites that is open to public participation. Interested persons may comment on programs after creating a username; we do not permit anonymous comments. Unity Global Care is not responsible for the privacy of any information that you choose to submit through our blog or comment areas, or for the accuracy of any information contained in those postings. Any information that you disclose through these public areas becomes public information. We cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy. Please do not post health information, application details, or other sensitive information in a public area. You may request removal of content you posted by contacting us, subject to Section 16.7 for California minors.

25.3 Third-Party Websites, Links, and Providers

Our Websites contain links to third-party websites, including those of Benefit providers, government agencies, and community organizations. This Policy does not apply to any third-party website, application, or service. We are not responsible for the privacy practices or the content of third parties. We encourage you to review the privacy policy of every website you visit and every provider to whom you submit an application.

25.4 Updating Your Information

You may review or edit your profile information at any time by logging into your account, where that functionality is available, or by emailing us at UnityInfo@unityglobalcare.com or calling 800.315.1217. Please keep your information accurate and current so that we can serve you properly. Note that information already transmitted to a Benefit provider at your direction must be corrected with that provider directly.

25.5 Opting Out of Communications

Email. If you have created an account with us or requested to receive information from us, we may send you email about topics and opportunities that we believe may be of interest to you. At any time, you may unsubscribe from our marketing emails by using the link contained in the email or by emailing UnityInfo@unityglobalcare.com. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or about Services you have requested or received from us.

Telephone. If you no longer wish to receive telephone calls from us, email UnityInfo@unityglobalcare.com or call 800.315.1217. We maintain an internal do-not-call list and honor the National Do Not Call Registry as required by law.

Text messages. See Section 23.

Postal mail. To stop receiving postal mail, write to us at the address in Section 3.

25.6 Accessibility

We are committed to making this Policy accessible to individuals with disabilities. If you use an assistive technology and are unable to access this Policy, or would like this Policy provided in an alternative format, contact us at UnityInfo@unityglobalcare.com or 800.315.1217 and we will provide it to you at no charge.

25.7 Users Located Outside the United States

Our Websites and Services are intended for persons located in the United States. If you access the Websites from outside the United States, you understand that your information will be transferred to, stored, and processed in the United States, where privacy laws may differ from those of your country of residence. We do not knowingly offer the Services to individuals in the European Economic Area, the United Kingdom, or Switzerland. Where we do process personal data subject to a non-U.S. law, we will comply with that law’s requirements.

25.8 No Waiver; Severability

Nothing in this Policy waives any right you have under applicable law. If any provision of this Policy is held to be invalid or unenforceable, the remaining provisions remain in full force and effect.

25.9 Relationship to Our Terms of Use

This Policy is incorporated into and governed by our Terms of Use, including the limitations of liability, arbitration, and dispute resolution provisions contained in them. Our HIPAA Compliance Statement addresses information we handle as a Business Associate or Subcontractor and is likewise incorporated by reference. If a provision of this Policy conflicts with a provision of the Terms of Use on a matter of privacy, this Policy controls.

26. CHANGES TO THIS PRIVACY POLICY

We may update this Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. We will post changes to this Policy on our Websites and will update the “Last Revised” date at the top. Changes become effective upon posting unless otherwise stated.

If we make a material change, we will endeavor to notify account holders by prominently highlighting the change upon posting and by sending an email to the most current email address we have on file for each account holder. Where required by law, we will obtain your consent before applying a material change to personal information we already collected. We review and update this Policy at least once every twelve (12) months.

We encourage you to review this Policy periodically.

27. CONTACT US

If you have any questions, concerns, or complaints regarding this Policy or our privacy practices, or if you wish to exercise a privacy right, please contact us:

Unity Global Care, Inc. Attn: Privacy 203 Main Street, No. 179 Flemington, New Jersey 08822

Email: UnityInfo@unityglobalcare.com

Toll-free: 800.315.1217

We will respond as promptly as we can and in accordance with the timelines described in Section 15.

If you are not satisfied with our response, you may have the right to contact your state Attorney General or applicable privacy regulator.

Unity Global Care, Inc. is a Delaware corporation. ALBERTai is owned and operated by Unity Global Care, Inc.

Effective Date: March 11, 2025 | Last Revised: Aug 3, 2026