Healthcare Savings Card Benefits

Member Privacy Rights

This Privacy Policy (“Policy”) describes our collection, use, storage, sharing and protection of your Personal Information. The Policy applies to Franco Signor LLC, a Delaware Limited Liability Company, d/b/a CareMDRx (“CareMDRx”) and all related sites, services and tools.

Consent

You accept this Policy, and grant CareMDRx permission to perform any of the activities described by the Policy, when you sign up for, access, or use our products, services, content, features, technologies or any function offered on our website, consumer portal and all related applications. Franco Signor LLC reserves the right to amend this Policy at any time. Any revised version will be published on the applicable website and is considered effective as of the published date.

Definition of Personal Information

For purposes of this Policy, Personal Information shall include information that identifies an individual, including date of birth, name, address, phone number, email, records of any financial or credit institution, including any records of deposits, withdrawals and balances of any checking and savings account and their respective account numbers. Any personal identification number or passwords that would permit access to an individual’s financial accounts is also encompassed within the scope of this Policy.

Collection of Personal Information

When you utilize Franco Signor LLC, we collect and track Personal Information sent to us by your computer, mobile phone or other access devices. The information sent to us includes, but is not limited to, computer IP address and device ID. We reserve the right to collect information about your transactions and activities. If an account is established with Franco Signor LLC, we may collect the following types of information:

• Contact information, such as name, address, phone number, email address and other similar information
• Financial information, such as the full bank account number, or credit card numbers linked to your account
• Detailed personal information such as date of birth, social security number, or Member ID.

How We Protect and Store Personal Information

Throughout this Privacy Policy, we use the term “Personal Information” to describe any information that can be associated with a specific person and can be used to identify said person. We store and process your Personal Information in North America, where our facilities are located. We protect your information using physical, technical and administrative security measures to mitigate the risk of loss, misuse, alteration, unauthorized access or disclosure. Some of the safeguards we use are firewalls and data encryption. Additionally, we also have physical access controls in place at our data center(s).

How Your Personal Information Is Used

Our sole objective is to provide the services described in the User Agreement while providing you with a secure and efficient experience. Personal Information may be used in the following scenarios:

• Provide Franco Signor LLC post administration service and customer support
• Process transactions and issue notifications to you on transactions specific to your account
• Verify your identity
• Resolve disputes
• Direct, prevent, and/or remediate fraud or other illegal activities
• Manage and protect our information technology and infrastructure
• Contact you at any telephone number (or email) by placing a phone call or sending an email as authorized by our User Agreement or this Policy
• Franco Signor LLC does not sell or rent your information to third parties.

How We Share Personal Information with Other Third Parties

We may share your Personal Information we collect, including your name, transaction and activity history with:

• Secure partners that provide healthcare benefits to our members
• Banking partners
• Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal proceedings applicable to Franco Signor LLC.

How You Can Access or Change Your Personal Information

As a member, you can review and edit your personal information at any time by logging in to your account and reviewing your profile. If you close your account with Franco Signor LLC, we will label your account as “terminated” within our database. We may retain Personal Information from your account to resolve disputes, troubleshoot problems, enforce our User Agreement, or take other actions as required or permitted by law.