Notice of Privacy Practices

Last updated: June 9, 2025

Maven Clinic Co. (“Maven”, “we”, or “us”) are committed to protecting the privacy of the health-related information we collect, store, use, and otherwise process Consumer Health Data, as that term is defined by the consumer health data privacy laws in Nevada and Washington.

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This Consumer Health Data Privacy Notice (“Health Privacy Notice”) applies to the Consumer Health Data we collect through the Maven website, located at www.mavenclinic.com, Maven’s mobile applications, Maven’s benefits administration services, and other products and services (collectively, our “Services”). We encourage you to read this Health Privacy Notice closely.

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This notice only applies to residents of Nevada and Washington. See review our Privacy Policy to understand our general practices for processing personal data.

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SOURCES OF CONSUMER HEALTH DATA

We collect Consumer Health Data in the following ways:

Information you provide to us. Consumer Health Data and other information you may provide to us when you use our Services or otherwise interact with us.
Information automatically collected. We automatically collect certain information when you visit, use, or navigate our website and other digital properties, including through cookies and similar technologies.
Information that we obtain from third party sources. We may receive Consumer Health Data about you from third party sources, such as your healthcare provider.

CONSUMER HEALTH DATA WE COLLECT

Depending on how you use our Services, we may collect the following categories of Consumer Health Data:

Health status or treatment information, such as your health conditions, status of your medical treatment, interventions, diseases, and diagnoses.
Medical history, including your health-related surgeries or procedures, use of purchase of prescribed medications,
Bodily functions, such as your vital signs, symptoms, or measurements (e.g., height, weight, and BMI).
Inferences about health derived from other health or non-health data, including the fact that you may be visiting our Services to seek healthcare.

HOW WE USE CONSUMER HEALTH DATA

We use the Consumer Health Data we collect for a variety of business purposes as described below:

To manage our relationship with you, including responding to your requests or inquiries, giving you access to content or information you request, and better understanding your interests and needs.
To analyze, personalize, and improve our Services and business.
To market and advertise our products and Services, including via email and through advertisements.
To comply with our legal obligations, including with respect to responding to authorities or reporting to government entities.
To create aggregated, de-identified, or other anonymous data; once the Consumer Health Data has been aggregated, de-identified, or anonymized, we may use and disclose it without restriction and in compliance with law.
To operate our business in an effective and compliant way, including to ensure you can access our Services, prevent fraud, protect our interests as a company, assess and defend claims, exercise rights and protect the rights of others, and for corporate matters like restructuring or potential reorganization or sale of our business or assets.

HOW WE SHARE CONSUMER HEALTH DATA

We share all the categories of Consumer Health Data that we collect with the categories of recipients described below:

Service providers that perform services on our behalf. It is our practice to prohibit our service providers from using your Consumer Health Data for any purpose other than to provide services to us. We use the following types of service providers:
- Companies that analyze data, including providing website statistics and metrics related to our product sales;
- Companies that provide technical business support such as data storage, software suites, cybersecurity services, and information technology troubleshooting services;
- Event planning and travel organizations that help facilitate our programs and services; and
- Companies that support us in product marketing and commercialization.

Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Business partners, such as entities with whom we jointly offer services or co-sponsor events. These entities may collect data directly from you or via our Services.
Advertising Partners, where we have your consent to use your Consumer Health Data for marketing purposes, we may share your information with third parties for the purposes of serving you with personalized or targeted advertisements on third-party platforms and to measure advertisement engagement.
Government or law enforcement officials or private parties as required by law, as we believe necessary or appropriate to comply with applicable law and lawful requests and legal process.
In connection with any business deal (or potential business deal) such as a merger, consolidation, sale of some or all our business or assets, financing or acquisition, reorganization, or in the event of bankruptcy.

THIRD PARTY DATA COLLECTION VIA TRACKING TECHNOLOGIES

Certain third parties with which we partner or engage for services may use cookies and other tracking technologies to collect information about you from our Services. This information may include Consumer Health Data. Please see our Privacy Policy for details about our use of tracking technologies. ‍

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YOUR RIGHTS

Washington and Nevada consumers have certain rights regarding their Consumer Health Data, including:

Right to Access. You have the right to confirm whether we process your Consumer Health Data and to obtain information about how we process that data.
Right to Delete. You have the right to request that we delete your Consumer Health Data.
Right to Withdraw Consent. If you provided consent for our processing of your Consumer Health Data, you may have the right to withdraw that consent.
Right to Change. You have the right to ask that we change the Consumer Health Data that we collect.

To exercise your rights, please contact us at privacy@mavenclinic.com

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CHANGES TO THIS HEALTH PRIVACY NOTICE

We may update this Health Privacy Notice to reflect changes to our data and personal data privacy practices. If we make any material changes to this Health Privacy Notice, we will take appropriate steps to notify you of such changes. We encourage you to periodically review this page for the latest information on our privacy practices.

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This Notice of Privacy Practices applies to the employees and independent providers of DCW Providers (IL) PLLC; DCW Providers, P.C.; DCW Providers NJ P.C.; and Maven Clinic Administrators Inc. The practices and entities that are subject to this Notice are collectively known as “Maven” (“us,” “we,” or “our”). The providers who deliver services through Maven are independent professionals practicing within several groups of independently owned professional practices.

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Maven Clinic Co. operates the websites located at https://www.mavenclinic.com/ and other websites, products, services, and mobile applications with links to this Notice of Privacy Practices, including without limitation the Maven webpages and applications (collectively, the “Sites” or “Websites”, unless otherwise specified). Individuals who use the Sites and access services through the Sites are referred below as “Users”, “Members”, “you”, “your”, or “yours”.

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This Notice of Privacy Practices (the “Notice”) will tell you about the ways in which we may use and disclose medical or billing records or other health information we use to make decisions about you (“Protected Health Information” or “PHI”). We also describe your rights and certain obligations we have regarding the use and disclosure of your PHI and how you can access your PHI.

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We understand that information about you and your health is sensitive, and we are committed to safeguarding your PHI. By PHI, we mean protected health information as defined under federal law (the Health Insurance Portability and Accountability Act of 1996, or “HIPAA”, and its implementing regulations). We also strongly believe that individuals should control their own health information, and in that regard you have certain rights with respect to your health information.

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Get an electronic or paper copy of your medical record.

Request confidential communications.

Ask us to limit what we use or share.

Get a list of those with whom we’ve shared information.

Get a copy of this privacy notice.

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For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do and we will follow your instructions.

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In these cases, you have the right and choice to tell us to:

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In these cases, we never share your PHI without your written authorization:

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In certain situations, we must obtain your written authorization in order to use and/or disclose your PHI. However, unless the PHI is “Highly Confidential Information” (as defined in the next sentence) and the applicable law regulating such information imposes special restrictions on us, we may use and disclose your PHI without your written authorization for the purposes described below. “Highly Confidential Information” means certain health information that is given special privacy protection by applicable state and federal laws and may include substance use disorder treatment program records, mental health records, reproductive health information and other health information that is given special privacy protection under state or federal laws other than HIPAA. In order for us to disclose any Highly Confidential Information for a purpose other than those permitted by law, we must obtain your authorization.

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We may use or share your PHI without your authorization in the following ways:

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In addition to federal privacy laws like HIPAA, many U.S. states have enacted laws that provide additional protections for certain types of health information. Depending on where you live, additional privacy protections may apply to your health information, particularly for the following types of data:

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Where state law provides stronger privacy protections than federal law, we follow the more protective state requirements. If you have questions about specific state protections that may apply to your health information, please contact us at privacy@mavenclinic.com.

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Except for the purposes described above, we only use or disclose your PHI when you give us your written authorization. For example:

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For more information, see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.

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We may change the terms of this Notice at any time, and the changes will apply to all PHI that we maintain, including medical information we created or received prior to making such changes. If we update this Notice, we will post the updated notice on our Websites. You also may obtain any updated notice by contacting us using the information set forth below.

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For all inquiries, requests for records, special requests, or to file a complaint, you can email us at privacy@mavenclinic.com or write to us at the following address: :

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Maven Clinic Co.

Attn: Legal

160 Varick Street, 6^th Floor

New York, NY 10013

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Customer shall complete Maven’s Wallet onboarding survey to confirm the design of its applicable benefit plan(s), including but not limited to member enrollment eligibility requirements, eligible expense types that Participants can have reimbursed, and tax treatment.
Customer shall provide Maven an eligibility file on an agreed upon cadence, but at a minimum on a monthly basis
Each Wallet-enrolled Participant is responsible for timely submitting valid proofs of payment, itemized invoices for services, applicable bank account information, and any requested substantiation documentation to Maven and/or its designated agent.
Customer and Maven will set up payment funding instructions during the implementation process. Customer shall be responsible for providing appropriate funds in advance for Maven Wallet reimbursements in order to complete the fund transfer to reimburse Participants in a timely fashion.
Maven will collect expense reimbursement information from Wallet-enrolled Participants using its online platform.
Maven will review expense reimbursement requests received from Wallet-enrolled Participants against the applicable benefit plan rules confirmed by the Customer, and will refer to the Customer any questions that arise which are not clearly determined by the applicable benefit plan rules.
Customer shall promptly respond to any questions from Maven regarding clarification of applicable benefit plan rules.
Customer understands, acknowledges, and agrees that any Eligible Customer Beneficiary included in the Eligibility File will be considered eligible for Wallet reimbursements unless otherwise indicated by Customer in writing.
Maven will compile receipts and expenses provided by Wallet-enrolled Participants and prepare aggregated Wallet expense reports and invoices (“Wallet Invoices”), which it will send to Customer on a weekly basis for any week in which a Wallet-enrolled Participant submits a reimbursement request.
Customer shall confirm which Wallet Invoice expenses are approved to be reimbursed and ensure that sufficient funds are available for Maven or its designated agent to process approved reimbursement payments within 3 business days of Customer’s receipt of a Wallet Invoice.
Maven will, at its discretion, either: (1) remit Customer-provided reimbursement funds to the applicable Participant’s bank account within 5 business days of Customer approving the reimbursement, provided that sufficient Customer funds have been made available for reimbursement and the applicable Participant has provided their bank account information; or (2) provide a report of approved reimbursement amounts, type, and tax treatment to facilitate Customer’s direct reimbursement of the applicable Participant(s) via its payroll system.
Customer’s obligations under this Attachment shall continue for a minimum of 90 days beyond the termination of the Agreement, to facilitate Maven’s provision of its administrative reimbursement services for Participants enrolled in Wallet prior to termination of the Agreement who wish to submit reimbursement requests for eligible expenses incurred prior to the termination of the Agreement.
Customer acknowledges and agrees that it is solely responsible for any communications to members about its employer-sponsored benefit plans, including any communications necessary to inform members of alternative claim submission procedures upon the termination or expiration or this Agreement.
Customer, as the fiduciary, plan sponsor, and plan administrator of its employee benefit plan(s), acknowledges that it is fully responsible, and Maven shall have no liability, for the establishment, design and administration of Customer’s employee benefit plan(s) and all tax compliance and payroll reporting associated with any such employee benefit plan(s). Customer understands, acknowledges and agrees that: (A) Maven is not a plan sponsor, plan administrator or fiduciary with respect to any Customer plan supported by Maven Wallet; (B) Maven shall have no responsibility or liability with respect to any Customer plan supported by Maven Wallet; (C) to the extent that Maven provides any administrative or other services with respect to a Customer plan, (I) all such services shall be non-discretionary, ministerial services taken on behalf of Customer and at Customer’s specific direction, (II) Maven shall not take on any fiduciary or other obligations as a result of such services under the Employee Retirement Income Security Act of 1974, as amended (ERISA), or any other law, and (III) Customer shall remain solely responsible and liable for such services and any underlying obligations; (D) Customer will defend and hold harmless Maven and its owners, employees, officers, managers and directors from and against all liability, demands, damages, costs or expenses (including reasonable attorney’s fees) (collectively, “Liabilities”) arising from any claim, action or proceeding, in each case brought by a third party (each, a “Claim”) to the extent such Claim is related to any Customer plan supported by Maven Wallet.