CIGNA VIRTUAL HEALTH™ PRIVACY POLICY – FULL POLICY

1. THIS PRIVACY POLICY

1.1 We are committed to protecting your personal information. "Personal information" is any data which can identify an individual, which would include your name, postal address, email address and other information about you such as your age and information you provide on your lifestyle.

1.2 This privacy policy describes how we, Cigna European Services (UK) Limited, collect personal information about you when using the Cigna Virtual Health™ version 1 mobile application software (App). It also describes how we might use that personal information and any other information you have provided to us. Please read this policy carefully. Some parts of the App are not provided by us and will be subject to a separate privacy policy and terms of use when you use those parts of the App. Please refer to section 3.1 for further information.

1.3 This policy (together with our end-user licence agreement as set out at https://h-library.cigna.com/content/public/h-lib/vh/en_gb/user_agreement-cms.html (EULA) and any additional terms of use incorporated by reference into the EULA) (Terms of Use) apply to your use of the App once you have downloaded the App onto your mobile telephone or other device (Device).

1.4 This privacy policy was last updated on 9^th May 2018.This privacy policy may change from time to time, for example, as a result of changes to law or changes to technologies and the App. We will provide you with the most up-to-date privacy policy and any changes will be displayed on-screen when you use the App. You will be required to read and accept the changes before you continue to use the App.

2. WHO WE ARE

2.1 Cigna European Services (UK) Limited ("we","us","our") is a provider of healthcare scheme administration and related services, including the App. In order for us to provide our services to you via the App, we need to collect and process your personal information. This makes us the data controller of your personal information.

2.2 Please contact us if you have any queries about this privacy policy using the contact details set out in section 11.

3. USING THE APP

3.1 The App contains links to and from the websites and apps of our third party suppliers, partner networks and affiliates (each a Third Party).

3.2 If you follow a link to any of this Third Party content, any services that may be accessed through such link will be subject to their own terms of use and privacy policies. We do not accept any responsibility or liability for any personal information (including sensitive personal information) that may be collected by these Third Parties. The table below provides details of our current Third Parties' privacy policies. Please check the relevant privacy policies below for the full details of how your information will be used by those Third Parties before you submit any personal information to these websites or use these services.

3.3 By using the App you accept the terms of this privacy policy. Your use of this App is voluntary.

3.4 If you give us information on behalf of someone else such as dependents who are under 18 years of age, you confirm to us that you have obtained their consent to do so, you have referred them to or they are aware of the content of this privacy policy and that they do not have any objection to us processing their information in accordance with this privacy policy.

4. INFORMATION WE MAY COLLECT FROM YOU WHEN YOU USE OUR APP

4.1 We may collect and process the following personal information about you:

4.1.1 information you give us (Submitted Information);

4.1.2 information we collect about you and your Device;

4.1.3 information we receive from third parties; and

4.1.4 location information.

4.2 Submitted Information

4.2.1 You may give us personal information about you by filling in forms on the App or by corresponding with us (for example, by e-mail or post). This includes personal information you provide when you register to use the App, download or register the App, complete the questionnaires on the App, make an in-App purchase, enter a competition, promotion or survey and when you report a problem with the App such as name, address, contact phone number, email address and date of birth.

4.3 Please note that we do not collect your "special category data" relating to your physical and mental health. Where you input such information into the App, this is directly passed through to the relevant Third Parties and it is not used or stored, or collected by us or the App in any form.

4.4 Information we collect about you and your Device

Each time you visit the App we may automatically collect the following information: technical information, including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting and technical information of any user wearable devices that you link to the App (Device Information).

4.5 Third Party Information

When you use the My Virtual GP service we will receive notification that a user has accessed those services but such notification will be in an anonymous form which does not identify you. No other information relating to your use of those services will be provided to us.

4.6 Location Information

4.6.1 A core function of the Pharmacy Location Services is its use of GPS technology to determine your current location and so the closest pharmacy services to you. If you do not wish your information to be used in this way you can turn off this functionality at any time by changing your privacy settings on your Device. However, please note that you will be unable to use the Pharmacy Location Services should you turn off this functionality.

4.6.2 Any maps in the App are provided by Google. When using such maps Google will handle any personal information you provide to Google in accordance with its privacy policy which is incorporated by reference into this privacy policy.

5. USES MADE OF THE INFORMATION

5.1 We use your personal information to:

5.1.1 provide you with information about Third Party Services as set out in section 3.2. When using your personal information for this purpose we will rely on the following legal grounds:

5.1.1.1 it is necessary to perform our contract (the EULA) with you; and we have a business need to ensure that we provide you with sufficient information about our Third Party Services.

5.1.2 tailor your experience on the App including by providing you with results of questionnaires you complete. When using your personal information for this purpose we will rely on the following legal ground:

5.1.2.1 we have a business need to ensure that we provide high quality services which are tailored for your uses of the App.

5.1.3 respond to your queries and fulfil your requests. When using your personal information for this purpose we will rely on the following legal grounds:

5.1.3.1 it is necessary to perform our contract (the EULA) with you; and

5.1.3.2 we have a business need to ensure that we respond to all your communications and any queries you have.

5.1.4 develop our product offerings and carry out market research and analysis. When using your personal information for this purpose we will rely on the following legal ground:

5.1.4.1 we have a business need to run an efficient business and where possible, improve our business and develop and improve the services we offer.

5.1.5 business functions such as data analysis, market research, quality assessment, product development and enhancement, service improvement and usage monitoring, invoicing, performance assessments and audits; When using your personal information for this purpose we will rely on the following legal ground:

5.1.5.1 we have a business need to run an efficient business.

5.1.6 send you administrative information, including information regarding the App and changes to our terms, conditions and policies. When using your personal information for this purpose we will rely on the following legal grounds:

5.1.6.1 it is necessary to perform our contract (the EULA) with you; and

5.1.6.2 we have a business need to provide you with any information which is relevant to the App.

5.1.7 protect our rights, privacy, safety or property, or that of our group companies, you or others, for example to enforce any legal rights we have under the EULA. When using your personal information for this purpose we will rely on the following legal grounds:

5.1.7.1 it is necessary to perform our contract (the EULA) with you; and

5.1.7.2 we have a business need to protect our business and our commercial interests

5.1.8 comply with legal requirements, including requests from public or government authorities, including public or government authorities outside your country of residence; When using your personal information for this purpose we will rely on the following legal ground:

5.1.8.1 it is necessary to comply with our legal or regulatory obligations.

6. DISCLOSURE OF YOUR INFORMATION

6.1 We may disclose some or all of your personal information to the following parties where necessary for the purposes set out in section 5:

6.1.1 other members of the Cigna group of companies;

6.1.2 Dr Now (in the form of your name, date of birth, address, gender and email address) when you request services from Dr Now through the App; and

6.1.3 Google (in the form of your postcode) if you use the App's location-enabled services including the Pharmacy Location Services.

6.2 We may also disclose your personal information to third parties:

6.2.1 in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets, but we will only do so once appropriate confidentiality agreements are in place;

6.2.2 if we or substantially all of our assets are acquired by a third party, in which case personal information held by us might be one of the transferred assets, but we will only do so once appropriate confidentiality agreements are in place;

6.2.3 if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request for example an ICO investigation;

6.2.4 in order to enforce or apply the EULA. This may include sharing information with our external legal advisers; or

6.2.5 to protect the rights, property or safety of Cigna, our customers, or others..

6.3 We will never sell or share your personal information with a third party for marketing purposes.

6.4 If you link the App to your wearable device, we may share information on your fitness with your wearable device provider where you have permitted us to do so.

7. HOW WE PROTECT YOUR PERSONAL INFORMATION

7.1 We are strongly committed to data security and we take reasonable and appropriate steps to protect your personal information from unauthorised access, loss, misuse, alteration or corruption. We have put in place physical, electronic, and managerial procedures to safeguard and secure the information you provide to us.

7.2 We may collect and store personal information on your Device using application data caches.

8. WHERE WE STORE YOUR PERSONAL INFORMATION

We do not transfer your personal information outside the European Economic Area (EEA). In the event that this changes, we will notify you.

9. HOW LONG WE KEEP YOUR PERSONAL INFORMATION

9.1 We take reasonable steps to ensure that the personal information we hold about you is reliable for its intended use and as accurate and complete as is necessary to carry out the relevant purposes described in this privacy policy.

9.2 We will retain your personal information for 10 years from the end of our relationship with you, for example 10 years from when your insurance policy is terminated or expires.

10. YOUR RIGHTS

10.1 Under data protection laws, you have the following rights set out below. You can exercise any of these by contacting us at any time using the contact details set out in section 11:

10.1.1 We do not carry out any marketing but in the event that this changes in the future, we will notify you and you will have the right to ask us not to process your personal information for marketing purposes.

10.1.2 You are entitled to a copy of the personal information we hold about you and certain details of how we use it (unless a relevant exemption applies).

There will not usually be a charge for dealing with these requests. Your information will usually be provided to you in writing, unless otherwise requested, or where you have made the request by electronic means, in which case the information will be provided to you by electronic means where possible.

10.1.3 You are entitled to request us to amend or update any inaccuracies in the personal information we hold about you.

10.1.4 In certain circumstances, you have the right to ask us to stop using your personal information, to erase your personal information or to transfer it to another third party of your choice.

10.1.5 We do not carry out any automated decision-making but in the event that this changes in the future, we will notify you.

11. CONTACT US

If you have any queries about your personal information or any of your rights please email our Data Protection Officer at Henry.Velasquez@Cigna.com or write to us at Cigna, Clyde View, Riverside Business Park, 22 Pottery Street, Greenock, Scotland PA15 2UZ.