Privacy Policy

This Privacy Policy explains how Ensure Health, Inc. (“Ensure Health,” “we,” “us,” or “our”) collects, uses, discloses, and protects information through the WellBee mobile app, the website at getwellbee.com, and related services (together, the “Services”). It also explains the rights you have under federal law and California law, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA), and the California Confidentiality of Medical Information Act (CMIA).

The short version:

We never sell your personal information, and we never share it for targeted advertising.
We never give your employer your individual health information. Your employer only learns whether you are eligible for WellBee and, if you opt in, sees aggregate, de-identified trends.
We use your health information to provide the Services you asked for, based on the consent choices you make, and as the law requires or permits.
You can see, download, correct, or delete your data, and change your consent choices at any time, subject to limited legal exceptions.

Who We Are and How HIPAA Applies

WellBee is a healthcare navigation and medication-affordability app built by Ensure Health, Inc. WellBee is offered to you as a benefit through participating employers. WellBee organizes information, identifies options, and routes you toward a next step. It does not diagnose, prescribe, or independently change a medication.

How HIPAA applies. When we handle protected health information (PHI) on behalf of a HIPAA-covered entity, such as your employer’s group health plan, a pharmacy benefit partner, or a health care provider, we act as that entity’s business associate under a signed Business Associate Agreement. In those cases, we use and disclose PHI only as that agreement and the HIPAA Privacy, Security, and Breach Notification Rules allow, and the covered entity’s own Notice of Privacy Practices also applies to you.

Where HIPAA does not apply, we still handle health information with the same safeguards, and it remains protected by this Policy and by other applicable laws, such as the CMIA, the CCPA, and the FTC Act.

Notice at Collection

This section is our notice at collection under the CCPA. We collect the categories of personal information described in Information We Collect, for the purposes described in How We Use Information. We keep each category for the periods described in Data Retention. We do not sell or share personal information, including sensitive personal information.

Early-access waitlist. The form on our Early Access page collects only your first and last name, email address, mobile number, whether your employer is a WellBee partner, and, optionally, your employer’s name. We use this information only to tell you about WellBee availability and to activate your account if your employer participates. Please do not enter health information into the waitlist form.

Information We Collect

Information you give us

Identifiers and contact details: such as your name, email address, phone number, date of birth, and account login details.
Employment and benefits information: your employer, eligibility status, and health plan or pharmacy benefit identifiers needed to check your coverage.
Health and medication information: the questions you ask in your own words, medications, prescriptions, pharmacy details, coverage and cost details, and requests you approve. This is sensitive personal information and, where applicable, medical information under the CMIA or PHI under HIPAA.
Consent and preference choices: the consent categories you turn on or off, notification preferences, and quiet-hour settings.
Communications: messages you send to our support team.

Information we receive from others

Your employer or its benefits administrator: eligibility (census) information such as your name, work email, and an employee identifier, so we can confirm you’re eligible. Employers do not send us your medical records.
Health plans, pharmacy benefit managers, and pharmacies: coverage, formulary, pricing, and prescription information, when you authorize it or when a covered entity provides it to us as its business associate.
Licensed pharmacists and clinicians who review requests that require professional review.
Sign-in providers: if your employer uses single sign-on (SSO), we receive basic identity information from that provider.

Information collected automatically

Device and usage information: device type, operating system, app version, crash reports, pages or screens viewed, and approximate time of use.
Network information: IP address and general location derived from it (city or region, not precise location).

We do not use advertising identifiers.

Categories of personal information (CCPA)

In the last 12 months, we have collected the following categories of personal information as described in the CCPA:

CCPA category	Examples	Disclosed for a business purpose to
Identifiers	Name, email, phone, account ID, IP address	Service providers; your employer (eligibility only)
Customer records (Cal. Civ. Code § 1798.80)	Contact details, benefit and plan identifiers	Service providers; health plans and pharmacies you choose
Protected classification characteristics	Date of birth (age)	Service providers; health plans and pharmacies you choose
Internet or network activity	App usage, crash logs, device information	Service providers
Professional or employment information	Employer name, eligibility status	Service providers
Inferences	Recommended options based on your coverage and questions	Not disclosed outside the Services
Sensitive personal information	Health and medication information; account login credentials	Service providers under HIPAA/CMIA-compliant agreements; pharmacists, clinicians, health plans, and pharmacies involved in a request you approved

How We Use Information

We use personal information to:

Provide the Services: confirm eligibility, check coverage, compare costs, surface lower-cost options (such as generics or assistance programs), and carry out requests you approve.
Route requests for professional review to licensed pharmacists or clinicians where a decision requires one.
Communicate with you: send reminders and status updates you’ve opted into. Notifications never contain PHI. Push, SMS, and email bodies stay generic, and details are available only after you sign in.
Keep the Services secure: authenticate users, prevent fraud and abuse, and detect and respond to security incidents.
Improve the Services: fix bugs and measure reliability. Where we analyze usage to improve WellBee, we use de-identified or aggregated data whenever we can.
Provide aggregate reports to employers: share de-identified, aggregated trends only if you opt in, and never in a form that identifies you.
Comply with law: meet legal, regulatory, and professional obligations, and respond to lawful requests as described below.

We use sensitive personal information only for purposes permitted by California law, such as providing the Services you requested, ensuring security, and complying with law. We do not use it to infer characteristics about you for any other purpose.

How We Disclose Information

We disclose personal information only as follows:

Service providers and contractors that host, secure, or support the Services (for example, cloud hosting, customer support, and messaging). They are contractually bound to use data only to provide services to us. Every vendor that touches health information signs a Business Associate Agreement or equivalent CMIA-compliant contract.
Pharmacists, clinicians, pharmacies, health plans, and pharmacy benefit managers involved in carrying out a request you approved.
Your employer, only in two limited ways: (1) confirming whether you’re eligible for WellBee, and (2) aggregate, de-identified trends, if you opt in. Your employer never receives your individual health information, questions, medications, or requests.
Legal and safety reasons: when required by law, subpoena, or court order, or to protect the rights, safety, or property of you, us, or others, and only as permitted by HIPAA and the CMIA. California law limits disclosures in response to out-of-state legal process involving health care that is lawful in California, including reproductive and gender-affirming care. We follow those limits.
Business transfers: in a merger, acquisition, or sale of assets, subject to the same protections in this Policy and any applicable HIPAA or CMIA obligations. We will notify you before your information becomes subject to a different privacy policy.
With your authorization: any other disclosure happens only with your express, written (including electronic) authorization, which you can revoke.

We do not sell personal information and do not share it for cross-context behavioral advertising, as those terms are defined in the CCPA. We have not done so in the past 12 months.
We do not sell or share the personal information of consumers under 16.
We do not place advertising pixels, tracking SDKs, or third-party ad cookies in the WellBee app or on pages where you enter health information. We do not disclose health information to advertising platforms or social networks.
We do not use your medical information for marketing, and we do not disclose personal information to third parties for their direct-marketing purposes (California “Shine the Light” law, Cal. Civ. Code § 1798.83).

Because we don’t sell or share personal information, and we use sensitive personal information only for permitted purposes, we do not offer a “Do Not Sell or Share” or “Limit the Use of My Sensitive Personal Information” link. We still honor opt-out preference signals as described below.

Artificial Intelligence and Automated Recommendations

WellBee uses automated technology, including AI, to understand the questions you type, organize coverage and pricing information, and rank options for you. Here is how we keep that technology in check:

AI recommends. Rules protect. You decide. Every recommendation is a proposal, not an action, until you approve it.
Every recommendation explains itself in plain language, and alternatives stay visible.
A licensed professional reviews decisions that require one. WellBee’s AI does not diagnose, prescribe, or change a medication. It never presents itself as a doctor, pharmacist, nurse, or other licensed professional, and it does not use titles or wording that imply you are receiving care from a licensed person when you are not (Cal. Bus. & Prof. Code § 4999.8 et seq.).
You can reach a person. You can contact our support team at any time, and requests that require professional review are routed to a licensed pharmacist or clinician.
Vendors can’t use your data for their own purposes. Vendors that process your information, including AI technology vendors, may use it only to provide services to us. They may not use it for their own purposes, such as training their own models.

Because a person (you, and a licensed professional where required) makes the final decision, WellBee is designed so that it does not make significant healthcare decisions solely by automated means. You may still ask us how our automated technology produced a recommendation for you, including the main factors it considered. If we ever use automated technology to make a significant decision about you, we will give you advance notice, the right to opt out, and the right to access information about that decision, as the CCPA regulations on automated decisionmaking technology require.

We ask for consent in clear, separate categories, not one blanket checkbox:

Let WellBee look at your medication and coverage information to find savings. (Required for core features.)
Let WellBee send you reminders about next steps. (Optional.)
Share aggregate, de-identified trends with your employer. (Optional. Your employer never sees your individual information.)

You can change these choices at any time in Profile & Consent Settings in the app. Changes take effect immediately. Turning off required consent means we can no longer provide core features, and you may delete your account instead. Proactive reminders respect quiet hours (8am–8pm local time) and frequency caps.

Your California Privacy Rights

If you are a California resident, you have the following rights under the CCPA:

Right to know and access: request the categories and specific pieces of personal information we have collected about you, where it came from, why we collected it, and whom we disclosed it to.
Right to delete: request that we delete personal information we collected from you, subject to legal exceptions (for example, records we must keep under pharmacy or health care laws).
Right to correct: request that we correct inaccurate personal information.
Right to data portability: receive your information in a portable, commonly used format. You can download your data directly in the app.
Right to opt out of sale or sharing: we don’t sell or share personal information. You may still submit an opt-out request, and we will honor it if our practices ever change.
Right to limit use of sensitive personal information: we already use sensitive personal information only for purposes the CCPA permits without offering this right.
Rights related to automated decisionmaking technology: where the CCPA regulations apply, the right to a pre-use notice, to opt out, and to access information about significant decisions made using automated technology, as described above.
Right to non-discrimination: we will not deny you the Services, charge you a different price, or give you a different level of quality because you exercised your privacy rights.

How to exercise your rights

In the app: go to Profile & Consent Settings to download your data, change consent, or delete your account without contacting support. Deletion can take up to 30 days to complete across all systems.
By email: write to support@getwellbee.com with the subject line “California Privacy Request.”

We will confirm receipt within 10 business days and respond within 45 calendar days. If we need more time (up to another 45 days), we will tell you why. To protect your information, we verify your identity by matching information you give us with information already in your account. We are not required to respond to requests to know or access more than twice in a 12-month period.

Authorized agents. You may use an authorized agent to submit a request on your behalf. We will ask the agent for your signed permission and may ask you to verify your identity directly with us, unless the agent holds a valid power of attorney under California Probate Code §§ 4121–4130.

Opt-out preference signals. We treat a browser Global Privacy Control (GPC) signal, or any other legally recognized opt-out preference signal, as a valid request to opt out of sale and sharing for that browser or device and, if we know who you are, for your account, with no further action needed from you.

Where to learn more or file a complaint: the California Privacy Protection Agency (CalPrivacy) at privacy.ca.gov or the California Attorney General at oag.ca.gov/privacy. If you believe your HIPAA privacy rights were violated, you may also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights at hhs.gov/ocr. We will not retaliate against you for filing a complaint.

California Medical Information (CMIA)

Where we maintain medical information as defined in California Civil Code § 56 et seq., we:

Do not disclose your medical information without your prior written authorization, except as the CMIA permits or requires (for example, to the pharmacists and clinicians involved in a request you approved, or as required by law).
Do not sell your medical information or use it for marketing.
Store, maintain, and dispose of medical information in a way that keeps it confidential.
Honor your right to revoke or limit an authorization at any time, going forward.
Give extra protection to information about sensitive services, such as reproductive health, sexual health, gender-affirming care, and mental health. We limit internal access to this information and do not disclose it in response to out-of-state subpoenas or requests where California law prohibits disclosure.

Cookies, Analytics, and Do Not Track

Website (getwellbee.com): we use only technologies that are necessary for the site to work. If we measure site traffic, we use privacy-focused analytics that do not use cookies, do not build profiles, and do not track you across other websites.
App: any diagnostic or performance tools we use in the app are used only to keep WellBee working, and the vendors that provide them may not use the data for their own purposes.
Do Not Track: we do not track you over time or across third-party websites, and we do not allow third parties to do so through the Services. Because of this, we do not change our practices in response to a browser “Do Not Track” signal. We do honor GPC signals as described above (California Business and Professions Code § 22575).

Data Retention

We keep personal information only as long as we reasonably need it for the purposes described in this Policy, then delete or de-identify it:

Waitlist information: until WellBee becomes available to you or you unsubscribe, whichever comes first. If WellBee does not become available to you, we delete it once we no longer need it to tell you about availability.
Account, consent, and health information: for as long as your account is active. When you delete your account, deletion can take up to 30 days to complete across all systems, except as described below.
Records we must keep by law: some records, such as audit logs, records of pharmacist review, or records a covered entity requires us to keep under a Business Associate Agreement, are retained for the period required by law or contract, then securely destroyed.
Backups: deleted data may remain in encrypted backups for a limited time until those backups are overwritten on their normal schedule.
De-identified data: we may keep de-identified or aggregated data that can no longer reasonably identify you. We will not try to re-identify it.

How We Protect Your Information

We use administrative, technical, and physical safeguards designed to meet the HIPAA Security Rule and California’s “reasonable security” requirement (Cal. Civ. Code § 1798.81.5), such as:

Encryption of data in transit and at rest.
Access controls that limit who can see your information, with extra restrictions on sensitive health information.
Secure sign-in, including SSO where your employer has it configured.
Audit logs, vendor security reviews, and risk assessments.
Workforce training on privacy and confidentiality.

No system is perfectly secure. If a breach affects your information, we will notify you, and regulators where required, as required by the HIPAA Breach Notification Rule, the FTC Health Breach Notification Rule, and California’s breach notification law (Cal. Civ. Code § 1798.82).

Children’s Privacy

WellBee is offered to adults through employer programs and is not intended for anyone under 18. We do not knowingly collect personal information from children under 18. If you believe a child has given us personal information, contact us and we will delete it.

Changes to This Policy

We review and update this Policy at least once every 12 months, as the CCPA requires. If we make material changes, we will notify you in the app or by email before the changes take effect. We will not use previously collected health information in a materially different way without your consent.

Contact Us

For questions about this Policy or to exercise your rights:

Email: support@getwellbee.com
In the app: Profile & Consent Settings
Company: Ensure Health, Inc. (ensure.health)

This Policy is available in accessible formats on request. If you have a disability and need this Policy in another format, please email us.