Privacy Policy

This Privacy Policy explains how Telehealth GG LLC ("Telehealth GG," "we," "us," or "our") collects, uses, and shares information in connection with the website located at Telehealth.gg and the related account-registration, login, and billing-support features we provide (collectively, the "Platform" or the "Services"). This Privacy Policy is incorporated into and subject to our Terms of Service.

Please read the following carefully. Telehealth GG is a front-end technology, marketing, and administrative platform. We do not provide medical or health-care services, and we do not collect, receive, host, store, access, or process any medical records or health information. All health-care services, and all of the health information generated through them, are provided and controlled by an independent third party, Wheel Health, Inc. and its affiliated professional entities, provider groups, and clinicians (collectively, "Wheel"). As used here, "Health Information" means any health, medical, clinical, treatment, prescription, diagnostic, or similar information about you, including any "protected health information" under the Health Insurance Portability and Accountability Act of 1996, as amended ("HIPAA").

THIS PRIVACY POLICY DOES NOT GOVERN, AND TELEHEALTH GG IS NOT RESPONSIBLE FOR, WHEEL'S COLLECTION OR HANDLING OF YOUR HEALTH INFORMATION. WHEEL'S PRIVACY PRACTICES AND, WHERE APPLICABLE, ITS HIPAA NOTICE OF PRIVACY PRACTICES GOVERN YOUR HEALTH INFORMATION AND YOUR CARE. TELEHEALTH GG IS NOT A HIPAA COVERED ENTITY AND IS NOT YOUR HEALTH-CARE PROVIDER. ANY QUESTION OR REQUEST CONCERNING YOUR HEALTH INFORMATION OR YOUR CARE MUST BE DIRECTED TO WHEEL.

Your Health Information is collected, used, and disclosed by Wheel under the Wheel Provider Group Notice of Privacy Practices and the Wheel Provider Group Telehealth Informed Consent, which you accept directly with Wheel during onboarding and which are available at https://care.telehealth.gg/care/legals/notice-of-privacy-practices and https://care.telehealth.gg/care/legals/consent-to-telemedicine. Wheel's provider group is the HIPAA covered entity that provides your care, and Wheel Health, Inc. acts as its business associate. Telehealth GG is neither a covered entity nor a business associate and receives no Health Information.

1. Scope of This Policy

This Privacy Policy applies only to information that Telehealth GG itself collects through the Platform. It does not apply to: (a)Wheel medical PAs clinicians, or any information you provide to or that is generated by Wheel, including your intake responses, clinical communications, diagnoses, prescriptions, laboratory results, and medical records; (b) any third-party website or service; or (c) any payment processor or other vendor that maintains its own relationship with you. Information you submit directly to Wheel is governed by Wheel's own Privacy Policy and the Wheel Provider Group Notice of Privacy Practices, not by this Policy.

2. The Information We Collect

2.1 Information You Provide to Us. When you create a Telehealth GG Account, we collect basic front-end account information, namely your name and email address. If you contact us for support, we collect the information in your communication.

2.2 Payment and Billing Information. When a payment is made through the Platform, we hold final payment information relating to the charge, such as the amount, date, a transaction or order reference, the status of the payment, and related billing information. Full payment-card details are collected and processed by our third-party payment processor and are not stored by Telehealth GG, except as described in Section 6.

2.3 Information We Collect Automatically. Like most websites, when you use the Platform we and our service providers may automatically collect limited technical and usage information, which may include:

• device and connection information, such as IP address, browser type, operating system, and device identifiers;
• usage information, such as pages viewed, links clicked, dates and times of access, and referring pages; and
• information collected through cookies and similar technologies, as described in Section 5.

2.4 Information From Wheel and Other Sources. To enable your account to connect to Wheel's platform (including through single sign-on), we may exchange limited account identifiers, such as your name, email address, and an authentication token, with Wheel. We do not receive your Health Information from Wheel in connection with these features.

2.5 INFORMATION WE DO NOT COLLECT. WE DO NOT COLLECT, RECEIVE, HOST, STORE, ACCESS, OR PROCESS ANY HEALTH INFORMATION. WE DO NOT COLLECT YOUR INTAKE RESPONSES, CLINICAL COMMUNICATIONS, DIAGNOSES, PRESCRIPTIONS, LABORATORY RESULTS, OR MEDICAL RECORDS. ALL OF THAT INFORMATION IS COLLECTED AND MAINTAINED EXCLUSIVELY BY WHEEL WITHIN WHEEL'S OWN SYSTEMS.

3. How We Use Information

We use the limited information described above only for the following purposes:

• Provide and administer the Platform. To create and maintain your Account, authenticate you, and enable your account to connect to Wheel so that you can access Wheel's services.
• Process and collect payments. To collect charges through the Platform, acting as a billing and collection agent on behalf of Wheel as described in our Terms of Service, and to maintain billing records.
• Communicate with you. To send you account, transactional, and service-related messages, to respond to your inquiries, and, where permitted, to send you informational or marketing messages from which you may opt out. Clinical and appointment communications are sent by Wheel, not by us.
• Security and fraud prevention. To protect the Platform and our users, detect and prevent fraud, and enforce our Terms of Service.
• Improve the Platform. To understand how the Platform is used and to maintain and improve it.
• Legal and compliance. To comply with applicable law, respond to lawful requests, and establish, exercise, or defend legal claims.

4. How We Share Information

We do not sell your personal information for money. We share the limited information we hold only as follows:

• Service providers. With vendors that perform services for us, such as website hosting and infrastructure, payment processing, email delivery, identity verification, security, and analytics, who are permitted to use the information only to provide those services to us.
• Wheel. With Wheel, the limited account identifiers needed to connect your account and enable Wheel to provide its services to you. We do not provide Health Information to Wheel because we do not have it.
• Legal and safety. When we believe disclosure is required by law or legal process, or is reasonably necessary to protect the rights, property, or safety of Telehealth GG, our users, or others.
• Business transfers. In connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to customary protections.
• With your direction. When you ask us to share information or otherwise consent.
• Aggregated or de-identified information. We may create and use aggregated or de-identified information that does not identify you, for any lawful purpose.

5. Cookies and Tracking Technologies

We and our service providers use cookies and similar technologies to operate and secure the Platform, remember your preferences, and understand usage. You can control cookies through your browser settings, though disabling some cookies may affect how the Platform functions.

We honor browser-based opt-out preference signals, including the Global Privacy Control (GPC), where required by law. We do not knowingly use cookies or tracking technologies in a manner that reveals to third parties the specific health conditions or services you may be seeking.

6. Payment Processing

Payments made through the Platform are processed by a third-party payment processor (for example, Stripe). Your payment-card data is collected and handled by the processor under its own terms and privacy policy and in accordance with applicable payment-card security standards. Telehealth GG collects charges only as a pass-through billing and collection agent for Wheel and does not retain the clinical fees. We retain only the final payment and billing records described in Section 2.2.

7. Data Retention

We retain the limited information we collect for as long as your Account is active and for a reasonable period afterward as needed to provide the Services, comply with our legal, tax, and financial-recordkeeping obligations, resolve disputes, and enforce our agreements. When information is no longer needed, we delete it or de-identify it. Because we do not hold Health Information, requests to delete medical records must be directed to Wheel.

8. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect the limited information we hold. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. You are responsible for keeping your Account credentials confidential.

9. Your Privacy Rights

9.1 Communications. You may opt out of non-essential marketing emails at any time using the unsubscribe link or by contacting us. We may still send you transactional and account messages.

9.2 State Privacy Rights (General). Depending on your state of residence, you may have rights regarding the personal information we hold about you, which may include the right to: confirm whether we process your personal information and access it; correct inaccuracies; request deletion; obtain a portable copy; and opt out of the sale of personal information or of "targeted advertising" or "sharing." You also have the right not to be discriminated against for exercising these rights, and in some states the right to appeal a denial of your request. To exercise any right, contact us at legal@telehealth.gg. We will verify your request as required by law and respond within the time the law allows. You may use an authorized agent where permitted.

9.3 California (CCPA/CPRA). If you are a California resident, you have the rights described above with respect to the categories of personal information we collect, which include identifiers (such as name, email, IP address, and account identifiers), commercial information (such as transaction and billing records), internet or other network activity, and limited inferences. We collect this information for the purposes described in Section 3 and disclose it to the categories of recipients described in Section 4. We do not sell your personal information and do not knowingly collect or process sensitive personal information for the purpose of inferring characteristics. We do not knowingly process the personal information of consumers under 16 for sale or sharing.

9.4 Consumer Health Data. Some states, including Washington (My Health My Data Act), Nevada, and Connecticut, define "consumer health data" more broadly than HIPAA and may apply to information that can be associated with seeking health-care services, regardless of whether an entity is a HIPAA covered entity. Telehealth GG does not collect Health Information and does not use the limited account or usage information it holds to identify, infer, or share the specific health conditions or treatments you may be seeking. To the extent any information we hold is treated as consumer health data under applicable law, we will handle it consistent with that law and with this Policy, and you may exercise applicable rights by contacting us at legal@telehealth.gg.

9.5 Health Information Rights. Rights regarding your Health Information and medical records, including access, amendment, restriction, and accounting of disclosures, are handled by Wheel under applicable law. Please direct those requests to Wheel.

10. Children's Privacy

The Platform is intended only for individuals who are at least eighteen (18) years old. We do not knowingly collect personal information from anyone under 18, and we do not knowingly collect personal information from children under 13 within the meaning of the Children's Online Privacy Protection Act. If we learn that we have collected such information, we will delete it. If you believe a minor has provided us information, contact us at legal@telehealth.gg.

11. Third-Party Services and Links

The Platform connects you to Wheel and may contain links to or features provided by third parties, including a payment processor and other vendors. We do not control and are not responsible for the privacy practices of Wheel or any other third party. We encourage you to review the privacy notices of any third party whose services you use, including Wheel's.

12. United States Only

The Platform is intended for users located in the United States, and the information we collect is processed in the United States. We do not offer the Platform to, or knowingly collect information from, individuals located outside the United States.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will indicate the date of the most recent revision by updating the "Last Updated" date above and, where appropriate, by other notice. Changes are effective when posted. Your continued use of the Platform after an update signifies your acceptance of the revised Policy.

14. How to Contact Us

If you have any question about this Privacy Policy or our handling of the limited information we hold, contact us at: Telehealth GG LLC, 8120 Research Blvd, Suite 105-237, Austin, Tx, 78758, Attn: Privacy, email: legal@telehealth.gg.

For any question or request relating to your Health Information, your medical records, or your care, contact Wheel, and refer to the Wheel Provider Group Notice of Privacy Practices and the Wheel Provider Group Telehealth Informed Consent available at the links referenced above.