Higi Privacy Policy

LAST UPDATED and EFFECTIVE: April 1, 2025

Introduction

Higi SH LLC and its subsidiaries, divisions, and affiliates (collectively, “Higi”, “we”, “us”, and “our”) recognize the importance of protecting the privacy of the personal information you provide to us. Accordingly, we have developed this Privacy Policy (the “Policy”) so that you can make educated and informed decisions about the personal information that you entrust to us by engaging our services on the websites, social media, email exchanges, mobile apps, and other online services on which this Policy is posted (the “Service”), and understand how we collect, use, disclose, and otherwise manage this information.

Your use of the Service is conditioned upon your agreement with this Policy and our Terms of Use. If there are any terms in this Policy or in our Terms of Service to which you do not agree, you must discontinue your use of our services. Before using our services, please read this Policy carefully as it contains important information on who we are and how and why we collect, store, use, and disclose your personal information. This Policy also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

This Policy does not apply to protected health information as that term is defined in the Health Insurance Portability and Accountability Act of 1996, as amended (“HIPAA”) or other medical or health information covered by state medical information acts. Higi is not a medical provider or insurance company. To the extent that Higi collects, maintains or creates personal information covered by HIPAA or state medical laws, we would only do so for other non-related medical provider or insurance company clients and such information would be governed by our business associate agreements with those medical providers’ and insurance companies’ notice of privacy practices which are out of Higi’s control. If you have questions on whether this Policy applies, please contact us in the manner set forth below.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY USING OUR SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO THE TERMS OF THIS PRIVACY POLICY.

This Policy is written in the English language. We do not guarantee the accuracy of any translated versions of this Policy. To the extent that any translated versions of this Policy conflict with the English language version, the English language version of this Policy shall control.

Children and Individuals Under the Age of Eighteen

We are committed to protecting the privacy of children. Our services are not intended for or directed to persons under eighteen (18) years of age. IF YOU ARE UNDER THE AGE OF EIGHTEEN (18) YOU ARE NOT AUTHORIZED TO USE OUR SERVICE, EVEN IF YOU HAVE OBTAINED PARENTAL CONSENT TO DO SO. We do not knowingly collect, request, process, or disclose data of children on our services. We do not intend to collect children’s personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”). Upon notice that a child has provided us with personal information, or that another party has otherwise provided us with a child’s personally identifiable information, we will delete the child’s personally identifiable information from our records. If you are a parent or guardian and believe we have collected personal information on a child, please contact us at privacy@higi.com and we will remove such data.

Collection of Personal Information

Higi enables you to securely gather, store, manage, and share your personal information and provides tools and services to help you track and improve your health. To do this, Higi collects personal information from you in the ways described herein.

Information you provide to us directly

Higi will collect personal data from you directly when you interact with our Service, contact us, use our services, create an account, participate in an online survey, sign up to receive offers or emails from us, or purchase our products. When you visit the Site, we may ask you for your name, address, telephone number, email address, or other contact details to respond to your request or inquiry or to share products, services or education materials that we think you will find interesting via email, text message, push notification or using any other contact information that you provide.

To access and use certain features of the Site, you may be required to first complete registration. When you create an account or register with us or otherwise use our services, we may collect your contact information, other identity information (e.g., age, date of birth, gender), fitness level, wellness goals, physical characteristics or descriptions, health insurance information, insurance policy numbers, employment information, other demographic information, medical information, financial information, disability information, marital status, race, national origin, citizenship, veteran or military status, username and password, and other information you optionally provide for your profile including but not limited to, photographs or videos.

This information is necessary to enable us to provide you with the account you have requested and to maintain the account and your profile. You may update your account information by editing the information associated with your account.

Information we obtain indirectly

We may receive personal data about you from our third-party affiliates or partners and from marketing companies that provide us with such information as a part of their relationship with us.

We may collect records of products or services you purchased, obtained, considered or other purchasing or consuming histories or tendencies you may have.

We may combine this with data that we already have collected about you. Such collected data could include contact details (such as email address) and previous purchase history or interests. This information is used to provide you with advertising and a more personalized experience as well as help us improve our service offerings.

Information collected automatically

When you use our Service, we collect certain information about you automatically through our use of cookies and similar technologies such as web beacons and pixels. When you visit our Site, we automatically collect information from your browser or your mobile device, which includes the date and time of your visit, your Internet Protocol (IP) address or unique device identifier, domain server, your browser type, cookies and data about which pages you visit and how you use the Site in order to allow us to operate and provide the Site and our services. This information is used to understand how you interact with the Site and to provide you with advertising and a more personalized experience. To learn more about our collection of technical data, please see the Cookies and Similar Technologies section of this Policy below.

Non-Personal Information

Even if you do not register with or provide any personal information to Higi, we collect non- personal information about your use of Higi. “Non-personal information” means information that we cannot use to identify or contact you, such as aggregate statistics. We may also acquire non- personal Information about our users from external sources. If you do not want us to collect such information, please do not use the Service.

Categories of Personal Information and Purpose for Collection

Higi collects the following categories of personal information: (1) contact information including your name, email address, telephone number, company affiliation, and mailing address; (2) authentication information, including the user name and password that you use to register an account on the Service; (3) insurance policy information, including carrier information, plan details, coverage, and copays and deductibles; (4) user content, including survey responses, comments, reviews, and suggestions; (5) personal characteristics including age, date of birth, gender, and marital status; (6) online behavior information including online activity, product and online preferences, interests, demographic and geographic information, and time spent viewing features; and (7) information about the browser and hardware you use as you access and use our website, https://www.higi.com/ (the “Site”), including IP address, network information, device characteristics, browser type, cookie information, referring and exit pages, sites visited, and timestamps; and (8) if you opt-in to provide such information, information collected through our mobile device applications and mobile optimized websites (collectively, the “Higi App”), including motion data (e.g., proximity sensor on both ios and android for video calls to adjust audio output and enable/disable video, and other information), gyroscope data, and accelerometer data (tracking movement).

We may collect records of products or services you purchased, obtained, considered or other purchasing or consuming histories or tendencies you may have. This information is used to provide you with advertising and a more personalized experience as well as help us improve our service offerings.

We may collect genetic, physiological, behavioral and biological characteristics, faceprints, voice prints, iris or retina scans, keystroke gait, sleep, health or exercise data you optionally provide to us. This information is used to provide you with advertising and educational materials, and a more personalized experience.

We do not consider "Body Measurements," including data such as weight, Body Mass Index (BMI), blood pressure, and pulse, to be Personal Information unless it is combined with other Personal Information.

Additional Collection of Sensitive Personal Information

We do not “sell” or “share” (as these terms are defined in the California Consumer Privacy Act) your sensitive personal information. As described in the “Disclosure of Personal Information” section below, we may disclose your sensitive personal information to third-party employers to the extent they require such information to determine your eligibility for employment or process your application. We only make such disclosures when you use our services to interact with such third- party employers by applying, via our services, for an employment opportunity offered by such a third-party employer, and when you provide us with your sensitive personal information specifically for such purposes.

You may withdraw your consent to process your sensitive personal information at any time by contacting us at privacy@higi.com or Privacy, c/o Higi SH LLC, 100 S. Wacker Drive, Suite 1600, Chicago, IL, 60606.

Purpose for Collection and Processing of Personal Information

Higi only collects and processes the minimum amount of personal information from you that is necessary to the purposes of our information processing activities and retains such information only if required to fulfill such purposes. We will only keep your personal information for as long as we need it, as permitted by the agreement for the Service, or as permitted or required by applicable law.

If you are a job applicant, employee, owner, director, officer, or contractor of Higi (individually referenced in this Policy as “employee” and collectively referenced as “employees”), we may also collect educational, professional, and employment-related information, which may include certain sensitive personal information. Specifically, if provided to us, we may collect information such as your Social Security Number, driver’s license number or state ID card number, passport number, and other unique personal identifiers associated with you or other beneficiaries such as your spouse or child; employment and education history, professional licenses, marital or domestic partner status, date of birth, age, gender, classifications protected under state or federal Equal Employment Opportunity laws (such as race or national origin), medical condition or information, and health insurance information and policy number; precise geolocation history, including badge access and telematics data; and financial Information, which may include bank account and billing address.

When you use the Site, we may collect information about your use of the Site, including your interaction with advertising and analytics services on the Site, in order to (a) serve you the content and functionality you request, and (b) maintain the privacy and security of the Site and services. Location information collected may include your IP address or unique device identifier.

Unless you are an employee, or as otherwise stated in this Policy or a separate agreement, Higi does not collect the following types of sensitive personal information: your passport number; your account log-in, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; your religious or philosophical beliefs or associations, political opinions or membership; the contents of your mail, email and text messages, unless we are the intended recipient of the communication; your criminal background; your citizenship or citizenship status; or any personal information about a known child. We ask that you not send nor disclose any sensitive personal information that we do not explicitly collect for the purposes outlined in this Policy or to provide our Service to you.

We may provide technological methods by which you can display a driver's license, state identification card, or other government issued identification for scanning to auto-populate certain fields for data collection associated with your use of the Services; however we do not retain images of the scanned identification or any biometric data as part of the scanning and auto-population process.

Although Higi may provide its third-party partners with your personal information for the third- party partner to provide the Service to you, Higi does not trade, rent, or sell your personal information to third-parties, share your personal information with third-parties for cross-context behavioral advertising, or process it for targeted advertising or consumer profiling.

Where applicable, if Higi intends to further process your personal information for a purpose other than that for which the personal information was initially collected, Higi shall, prior to such processing, provide you with any relevant information on such additional purpose, and, to the extent required by applicable law, obtain your consent for this.

The personal information which we collect may be required for us to provide our services to you. If you decline to provide us with requested personal information (including sensitive personal information), we may be unable to provide some or all of our services to you.

We or our Service Providers (defined below) may also use certain information, including log-in credentials, IP addresses, hashed email addresses, and unique mobile device identifiers, to locate or try to locate the same unique users across multiple browsers or devices, such as smartphones, tablets, or computers, to better tailor content, features, and advertising, and to provide you with a seamless experience across the devices you use to access the Service.

Disclosure of Personal Information

As these terms are defined in the California Consumer Privacy Act, Higi does not sell your personal information to third-parties or share your personal information with third-parties for cross-context behavioral advertising. and in the preceding twelve months we have not sold or shared any personal information.

Higi may disclose your sensitive personal information as described below. We do not use or disclose your sensitive personal information for purposes beyond those which are reasonably necessary to carry out the services which you directly request from Higi.

We may share or disclose, and have within the preceding twelve months shared or disclosed, your personal information for the following limited purposes:

Third-Parties Providing Services on Our Behalf. We may share information with vendors and suppliers (collectively, “Service Providers”) who perform services and functions on our behalf to support our interactions with you. These Service Providers may assist with technical operation of our Service, provide analytics, process orders, transactions and payments, or provide customer service. These Service Providers do not have the right to use personal information we share with them beyond what is necessary to assist us. Additionally, these Service Providers must adhere to confidentiality, security, and legal obligations in a way that is consistent with this Policy and any applicable law. Specifically, we contractually require that our Service Providers (1) protect the privacy of your personal and non-personal information consistent with this Policy and (2) not use or disclose your personal or non-personal information for any purpose other than to provide the limited service or function for Higi.

Your Consent to Have Your Personal Information Shared. Higi may share personal information with third-parties when we have your consent to do so. Specifically, in connection with your use of the Service, you may be asked to opt-in to receive informational or marketing offers, or to otherwise consent to the sharing of your information with a third-party, including social networking sites such as Facebook, Instagram, or X (formerly known as Twitter). If you agree to have your personal information shared with a third-party, your personal information will be disclosed to the third-party and will be subject to the privacy policy and business practices of that third- party.

While we have not shared or disclosed your personal information for the reasons listed below within the last twelve months, we may also share or disclose your personal information for the following purposes:

Legal Disclosure. We may transfer and disclose information, including your personal information, usage information and device identifier, (including IP address), to third- parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our agreements, terms of use, or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third-parties, visitors to our Service, or the public.

Transfer in the Event of Sale or Change of Control. If the ownership of all or substantially all of our business changes, or we otherwise transfer assets relating to our business or the Site, Higi App, or Service to a third-party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer personal information to the new owner. In such a case, unless prohibited by applicable law, your information would remain subject to the privacy policy applicable at the time of such transfer, unless you discontinue use of our Service.
Emergencies. We may also disclose personal information about you to the appropriate medical, law enforcement, or other emergency response professionals in response to a physical threat to you or others.

Uses and Disclosures of Personal Health Data

In accordance with the HIPAA Privacy Rule, Higi follows national standards to protect individuals’ medical records and other Protected Health Information (PHI) when providing and conducting healthcare-related services and transactions electronically. Higi collects personal health information directly from you, implements appropriate safeguards to protect the privacy of such information, and obtains the necessary authorization before using and disclosing such information for the purposes of treatment, healthcare operations, and payment. Higi also respects all patient rights, including the rights to examine and obtain a copy of health records and to request corrections.

With your consent, Higi uses and discloses PHI, which includes the PHI described in the Categories of Personal Information and Purpose for Collection section of this Policy, in the following ways:

Treatment. Higi may disclose your PHI to another physician or healthcare provider for purposes of consultation or in connection with the provision of follow-up treatment.

Healthcare Operations. Higi may use and disclose your PHI in connection with its healthcare operations, such as providing healthcare consultations, customer service, and conducting quality review assessments.

Payment. We document the services and supplies you receive when we are providing care to you so that you, your insurance company, or another third-party can pay us. We may tell your health plan about upcoming treatment or services that require prior approval by your health plan.
Higi does not permit third-parties to collect PHI over time or across different websites or online services when you use our Service. Higi also does not trade, rent, or sell PHI to third-parties, share PHI with third-parties for cross-context behavioral advertising, or process PHI for targeted advertising or consumer profiling.
While Higi is permitted to use and disclose your PHI for the normal business activities that the law sees as falling into the categories of treatment, healthcare operations, and payment, you may revoke any such authorization at any time by contacting Higi at [email].
Retention of Personal Information. We will only retain your personal information for as long as we believe it is necessary to fulfill the purposes for which we collected it, or for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Cookies and Other Technologies

A “cookie” is a small file created by a web server that can be stored on a user’s device for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” cookie). This file may include information about your IP addresses, browser type, internet service provider (ISP), URLs of any referring or exited webpages, operating system, and/or date and time stamps.

We may use cookies, web beacons, pixel tags, mobile analytics software, log files, or other technologies to collect certain information about your online activity and interactions with our emails, online and mobile advertisements, and to allow us to keep track of analytics and certain statistical information that enables Higi to improve our services and provide you with more relevant content and advertising offered by Higi or through or linked from our services. You may, however, disallow receiving cookies at any time through your web browser. It is not our intention to use cookies to retrieve information that is unrelated to our Service or your interaction with our Service.

We may use the X Feed widget (formerly the Twitter Tweet widget) at the Site. As a result, our website makes requests to X’s servers for you to be able to post our webpages using your X account. These requests may make your IP address, browser type, operating system, hardware type, internet service provider, pages visited, location, your mobile carrier, and device information (including device and application IDs) visible to X, which may use it in accordance with their data privacy policy: https://x.com/en/privacy#update.

The Site also may use features provided by YouTube. As a result, when you visit a page with content embedded from or linked to YouTube, you are presented with cookies from YouTube. To view YouTube’s privacy policy, visit https://policies.google.com/privacy?hl=en.

Our Site may also use DoubleClick, an ad serving service provided by Google. DoubleClick uses cookies to personalize ads. Your browser is assigned a pseudonymous ID used to track the ads that have been served to your browser and to identify those on which you’ve clicked. The cookies enable Google and its partners to select and display ads based on your browsing behavior. For more information on how Google uses this information, visit https://support.google.com/admanager/answer/7670381. To block certain ads served by Google, please visit https://support.google.com/ads/answer/2662922.

The Site may also use the ShareThis social media cookies to allow you to share content from our Sites across your social networks such as Facebook, LinkedIn, X, and others. If you browse the internet while signed into a social network, that network may have the ability to collect information about the websites you are visiting, including ours. To view ShareThis' privacy policy, visit https://www.sharethis.com/privacy/.

We may use Facebook Custom Audiences to deliver personalized advertisements to you on Facebook based on email addresses that we have collected. We feature Facebook Connect, which gives you the option to post information about your activities to your profile page to share with others within your network by using a single sign-in service to authenticate your identity. You may learn more about Facebook Custom Audiences and Facebook Connect by visiting https://www.facebook.com/policy.php, where you can also find instructions for opting out of receiving advertisements.

We may use LinkedIn Widgets on the Site to allow you to share content from our Site on your LinkedIn account. To opt out of targeted advertising from LinkedIn please visit https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out. LinkedIn’s privacy policy is available at https://www.linkedin.com/legal/privacy-policy.

We may also use other third-party cookies in addition to those expressly listed above. If you would like more detailed information about first party and third-party cookies in use on or related to the Site, please contact us using the information provided below.

We require your consent prior to utilization of strictly necessary cookies. In the event you do not consent to the use of cookies other than strictly necessary cookies, our website may continue to be accessible to you but will only utilize strictly necessary cookies associated with the basic functionality of our website.

While we do not currently sell or share personal information, we do not recognize do-not-track (“DNT”) signals. We do recognize opt-out preference signals, such as the Global Privacy Control, on browsers, browser extensions, or devices that support such a signal. Such signals will be automatically linked to your browser or device identifier, and we will process them as a valid, automatic request to opt-out of the sale and sharing of your personal information in the event personal information is ever shared or sold.

If you would like more information about who we share our data with and why, please contact us using the information provided below.

Linked Sites

The Service may contain links to third-party owned or operated websites, including, without limitation, social media websites (each a “Linked Sites”), as a convenient method of accessing information that may be useful or of interest to you. This Policy and the practices that we follow under this Policy do not apply to Linked Sites. We are not responsible for the content, accuracy, or opinions expressed on any Linked Site or for the privacy practices or security standards used by third-parties on such Linked Sites. These Linked Sites have separate privacy and data collection practices, and we have no responsibility or liability relating to them.

You understand and agree that by clicking on a link to a Linked Site, you have left our Service and this Policy is no longer in effect.

User Contributions

Some features of the Services may now or in the future allow you to provide content, such as written comments or reviews, to be published or displayed on public areas of the Service (“User Contributions”). Be careful about giving out information in public areas of the Service. The information you share in public areas may be viewed by any user of the Service. We cannot control the actions of other users of the Service with whom you may choose to share your User Contributions.

Managing Your Information

If you do not want your personal information used by Higi as provided in this Policy, you should not use the Service or register as a member of Higi or for any specific tool or application on Higi’s Service that collects personal information.

You may correct, update, or review personal information you have submitted through registration, interactive services and tools, and applications by signing into your Higi account and updating your registration information or making the desired changes. If you have registered for a Higi account and no longer want Higi to use your personal information or desire to delete such information from our systems, you should delete your information as described in this Policy or contact Higi to assist you using the information listed below. You do not need to create an account with us to submit a request to delete. Upon your request, we will delete your personal information from our active databases and, where feasible, from our back-up media; however, you should be aware that it is not technologically possible to remove every record of the information you have provided to Higi from our servers.

You may reject and opt-out of cookies and other parts of the Service. Additionally, if you decide that you would prefer not to receive personalized emails, secure electronic messages, or other communications from Higi, you may also opt-out of these services by clicking on the settings tab on the home page of your Higi App and changing your email preference or following the unsubscribe instructions included in each promotional email.

Security of Your Information

If you choose to provide us with your personal information, you understand that we are transferring it to our locations and systems in the United States or to the locations and systems of our service providers around the world. We have safeguards and security controls in place to protect your personal information. This includes reasonable technical and organizational measures, such as encryption and Secure Socket Layers (SSL) technology, that protect the personal information (i) from accidental or unlawful destruction, and (ii) loss, alteration, unauthorized disclosure of, or access to the data. Please be advised, however, that while we take reasonable security measures to protect your personal information, such measures cannot be guaranteed to be secure. We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third-parties will not be able to defeat our security, and improperly collect, access, steal, or modify your personal information.

The security of your account relies on your protection of your user profile information. You are responsible for maintaining the security of your user profile information, including your password and for all activities that occur under your account. You may not share your password with anyone. We will never ask you to send your password or other sensitive information to us in an email. Any email or other communication purporting to be from one of our websites requesting your password or asking you to provide sensitive account information via email, should be treated as unauthorized and suspicious and should be reported to us immediately. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and report it immediately by contacting us via email at privacy@higi.com.

Newsletters and Emails

At registration and at various times during your use of the Service, you will be given the option of opting in to recurring informational or promotional newsletters via email from Higi or directly from third-parties. If you receive email communications from us, we may use certain tools to capture data related to when you open our message and when you click on any links or banners it contains. Other information collected through this email tracking feature includes: your email address, the date and time of your “click” on the email, a message number, the name of the list from which the message was sent, a tracking URL number, and a destination page. We use this information to enhance our marketing efforts.

When you provide your email address or sign up for one of our mailing lists, you may at any time choose to opt out of receiving additional informational or promotional newsletters from Higi. You can unsubscribe from a mailing list by following the directions included at the bottom of the newsletter.

When you communicate with us, we may retain your communications in order to process and respond to them, as well as to improve our services. We may use your email address to communicate with you about our services, third-party products or services, or send you periodic emails on other topics. If at any time you would like to unsubscribe from receiving future emails, you may unsubscribe at the bottom of each email.

If you provide us with feedback or contact us for support or to ask us questions, we will collect your name, address, telephone number, email address, and other information needed to respond to your feedback, or request for support, or to answer your question.

Note that this Policy does not apply to information, content, ideas, concepts, or inventions that you send to Higi by email. If you want to keep such information, content, ideas, concepts, or inventions private or proprietary, do not send them in an email or any other correspondence to Higi.

Research and Measurement Activities

From time to time, Higi may conduct online research surveys, ask you to enter personal information, and combine your personal information with other information available to Higi through third parties for research and measurement purposes (as further described in the table under “Categories of Personal Information and Purpose for Collection”). We do not knowingly accept participants under the age of 18 when we partake in such research and measurement activities. If you are under the age of 18, please do not respond to any Higi online research survey. Online research surveys conducted by or on behalf of Higi will contain a link to this Policy.

Consent to Processing and International Transfers

Higi is a U.S.-based business and may process, transfer, and store personal information on servers located in a number of countries, including the United States. As a result, your data may be subject to data protection and other laws that may differ from your country of residence. Your data may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate. By using the Service, or by providing us with any personal information, you consent to the collection, processing, maintenance, and transfer of such data in and to the United States where the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside or are a citizen.

Special Notice for California Residents

If you would like to submit a Consumer Request, you can contact us at privacy@higi.com, or (866)-818-8793. If you choose to submit a Consumer Request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information if we cannot verify that the person making the Consumer Request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

“Personal information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. “Personal information” does not include publicly available information.

Request to Correct. You may correct or update your personal information at any time by logging into your account or by contacting us.

Request to Access. You may submit a Consumer Request to obtain a copy of or access to the personal information that we have collected on you.

Request to Know. You may submit a Consumer Request to receive information about our data collection practices.
- Right to Know what Personal Information is being Collected. You may request information on the categories of personal information we have collected about you; the categories of sources from which the personal information is collected; our business or commercial purpose for collecting, selling, or sharing personal information; the categories of third parties to whom we have disclosed personal information, if any; and the specific pieces of personal information we have collected about you.
- Right to Know what Personal Information is Sold or Shared and to Whom. You may also request the categories of personal information that we have collected about you; the categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared, and the categories of personal information that we have disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.
- Please note that the categories of personal information, sources, and disclosure will not exceed what is contained in this Policy. Additionally, we are not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. We are also not required to reidentify personal information if it is not stored in that manner already, nor is it required to provide the personal information to you more than twice in a twelve-month period.

Request to Limit the Use of Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may request that we limit the use or disclosure of your sensitive personal information.

Request to Delete. You may request that we delete personal information we have collected from you. Subject to certain exceptions set out below we will, on receipt of a verifiable Consumer Request, delete your personal information from our records, direct any service providers to do the same, and notify all third-parties to whom we have shared your personal information to delete it unless this proves impossible or involves disproportionate effort. Please note that we may not delete your personal information if it is necessary to:
- Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated by the consumer within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
- Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
- Debug to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if the consumer has provided informed consent.
- To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information.
- Comply with a legal obligation.

Right to Access Information About Automatic Decision-Making. We do not currently engage in automated individual decision-making. However, in the event we ever do so, we will inform you of such change and you may request information about and opt out of such automated decision-making.

Right to Data Portability. You may also request that we transfer your personal information to another entity, to the extent such transfer is technically feasible.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your personal information.

Special Notice for Colorado Residents

Personal information or “personal data” means “information that is linked or reasonably linkable to an identified or identifiable individual.” “Personal data” does not include de-identified or publicly available information.

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data we have collected on you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising or consumer profiling. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling.

Right to Data Portability. You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Colorado Attorney General.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

If you would like to submit a Consumer Request, you can contact us at privacy@higi.com, or (866)-818-8793 to submit a Consumer Request. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Connecticut Residents

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data we have collected on you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising or consumer profiling. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling.

Right to Data Portability. You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Connecticut Attorney General or submit a complaint online at https://portal.ct.gov/AG/Common/Complaint-Form-Landing-page.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Delaware Residents

Personal information or “personal data” means “information that is linked or reasonably linkable to an identified individual or an identifiable individual.” “Personal data” does not include deidentified data or publicly available information.

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.
Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising, consumer profiling, or automated decision making.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Delaware Attorney General.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Florida Residents

Personal information or “personal data” means “information that is linked or reasonably linkable to an identified individual or an identifiable individual” and includes pseudonymous data when such data is used with additional information. “Personal data” does not include deidentified data or publicly available information.

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Requests to Opt-Out. You may submit a request to opt out of the sale of your personal data; however, we do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to any use or disclosure of your sensitive data and opt-out of the collection and processing of such sensitive data. We further do not collect personal data through the operation of a voice recognition or facial recognition feature; however, you may also opt out of such collection in the event we do use such features.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Florida Attorney General.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Indiana Residents

Request to Access. You may submit a request to confirm or to obtain a copy or representative summary of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising or consumer profiling.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Indiana Attorney General.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Iowa Residents

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. We do not sell, rent, or lease your personal data to third parties and do not process your personal data for targeted advertising.

Appeal. If we notify you that no action is to be taken in response to your request to access, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Iowa Attorney General.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Kentucky Residents

Personal information or “personal data” means “any information that is linked or reasonably linkable to an identified or identifiable natural person.” “Personal data” does not include de- identified data or publicly available information.

Request to Access. You may submit a request to confirm whether we are processing your personal data or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data provided by or obtained about you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.
Request to Opt-Out. You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising or consumer profiling. We do not sell, rent, or lease your personal data to third-parties and do not process your personal data for targeted advertising or consumer profiling.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Kentucky Attorney General or submit a complaint online at https://www.ag.ky.gov/about/Office- Divisions/OCP/Pages/default.aspx.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

If you would like to submit a Consumer Request, you can contact us at privacy@higi.com, or (866)-818-8793 to submit a Consumer Request. If you choose to submit a request, you must provide us with enough information to identify you and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Maryland Residents

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.
Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

 Request to Delete. You may request that we delete the personal data we have collected on you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising or consumer profiling. We do not sell, rent, or lease your personal data to third-parties and do not process your personal data for targeted advertising or consumer profiling.

Right to Data Portability. You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.
Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Maryland Attorney General.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

If you would like to submit a Consumer Request, you can contact us privacy@higi.com, or (866)- 818-8793 to submit a Consumer Request. If you choose to submit a request, you must provide us with enough information to identify you and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Minnesota Residents

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data provided by or obtained about you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.
Request to Opt-Out. You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising or consumer profiling. We do not sell, rent, or lease your personal data to third-parties and do not process your personal data for targeted advertising or consumer profiling.

Right to Data Portability. You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Minnesota Attorney General or submit a complaint online at https://www.ag.state.mn.us/Office/Complaint.asp.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

If you would like to submit a Consumer Request, you can contact us at privacy@higi.com, or (866)-818-8793 to submit a Consumer Request. If you choose to submit a request, you must provide us with enough information to identify you and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Montana Residents

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. We do not sell, rent, or lease your personal data to third-parties and do not process your personal data for targeted advertising or consumer profiling.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Montana Attorney General.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Nebraska Residents

Personal information or “personal data” means “any information, including sensitive data, that is linked or reasonably linkable to an identified or identifiable individual, and includes pseudonymous data when the data is used by a controller or processor in conjunction with additional information that reasonably links the data to an identified or identifiable individual.” “Personal data” does not include de-identified or publicly available information.

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data we have collected on you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising or consumer profiling. We do not sell, rent, or lease your personal data to third-parties and do not process your personal data for targeted advertising or consumer profiling.

Right to Data Portability. You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Nebraska Attorney General.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Nevada Residents

We do not sell, rent, or lease your personally identifiable information to third-parties. However, if you are a resident of Nevada and would like to submit a request not to sell your personally identifiable information, you can contact us at privacy@higi.com, or (866)-818-8793 to submit a Consumer Request.

If you choose to submit a request, you must provide us with enough information to identify you and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data we have collected on you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Special Notice for New Hampshire Residents

Personal information or “personal data” means “any information that is linked or reasonably linkable to an identified or identifiable individual.” “Personal data” does not include de-identified or publicly available information.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising or consumer profiling. We do not sell, rent, or lease your personal data to third-parties and do not process your personal data for targeted advertising or consumer profiling.
Right to Data Portability. You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the New Hampshire Attorney General or submit a complaint online at https://www.doj.nh.gov/consumer/complaints/.
Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for New Jersey Residents

Personal information or “personal data” means “any information that is linked or reasonably linkable to an identified or identifiable person.” “Personal data” does not include de-identified or publicly available information.

 Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data we have collected on you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising or consumer profiling. We do not sell, rent, or lease your personal data to third-parties and do not process your personal data for targeted advertising or consumer profiling.
Right to Data Portability. You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.
Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the New Jersey Attorney General or submit a complaint online at: https://www.njconsumeraffairs.gov/Pages/Consumer- Complaints.aspx
Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

If you would like to submit a Consumer Request, you can contact us at privacy@higi.com, or (866)-818-8793 to submit a Consumer Request. If you choose to submit a request, you must provide us with enough information to identify you and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Oregon Residents

Personal information or “personal data” means “data, derived data or a unique identifier that is linked to or is reasonably linkable to a consumer or to a device that identifies, is linked to or is reasonably linkable to one or more consumers.” “Personal data” does not include deidentified data or publicly available information.

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. We do not sell, rent, or lease your personal data to third-parties and do not process your personal data for targeted advertising or consumer profiling.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Oregon Attorney General.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Rhode Island Residents

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data provided by or obtained about you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.
Request to Opt-Out. You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising or consumer profiling. We do not sell, rent, or lease your personal data to third-parties and do not process your personal data for targeted advertising or consumer profiling.

Right to Data Portability. You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Rhode Island Attorney General or submit a complaint online at https://riag.ri.gov/forms/consumer-complaint.
Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

If you would like to submit a Consumer Request, you can contact us at privacy@higi.com, or (866)-818-8793 to submit a Consumer Request. If you choose to submit a request, you must provide us with enough information to identify you and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

Special Notice for Tennessee Residents

“Personal information” means “information that is linked or reasonably linkable to an identified individual or an identifiable individual.” Personal information does not include deidentified data, aggregated data, or publicly available information.

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal information that we have collected on you including what the information is, how it’s been used, whether it’s been sold, and who it’s been disclosed to. Your personal information may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal information at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal information that you have provided to us. We will delete your personal information from our records and direct any service providers to do the same unless retention is required by law.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal information. We do not sell, rent, or lease your personal data to third-parties and do not process your personal information for targeted advertising or consumer profiling.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Tennessee Attorney General.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

If you would like to submit a Consumer Request, you can contact us privacy@higi.com, or (866)- 818-8793 to submit a Consumer Request. If you choose to submit a request, you must provide us with enough information to identify you (e.g., your first and last name, email address, and telephone number) and enough specificity on the requested data. We will only use the information we receive to respond to your request. We will not be able to disclose information or comply with your request if we cannot verify that the person making the request is the person about whom we collected information, or someone authorized to act on such person’s behalf. We will verify your request by comparing the information you provide with the information we have on you and, if your request is submitted by an authorized agent, we will require you to provide signed, written permission for such agent to act on your behalf.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Texas Residents

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal data. We do not sell, rent, or lease your personal data to third-parties and do not process your personal data for targeted advertising or consumer profiling.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Texas Attorney General.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Utah Residents

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data that you have provided to us. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Right to Data Portability. You may also request that we transfer your personal information to you or another entity, to the extent such transfer is technically feasible.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal

data as well as its processing for targeted advertising. We do not sell, rent, or lease your personal data to third-parties and do not process your personal data for targeted advertising.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Special Notice for Virginia Residents

Request to Access. You may submit a request to confirm or to obtain a copy of or access to the personal data that we have collected on you including what the data is, how it’s been used, and who it’s been disclosed to. Your personal data may no longer be available because it has been destroyed, erased, or made anonymous in accordance with our data retention policies in which case we will provide you with the reasons why the personal data no longer exists where possible.

Request to Correct. You may correct or update your personal data at any time by logging into your account or by contacting us.

Request to Delete. You may request that we delete the personal data provided by or obtained about you. We will delete your personal data from our records and direct any service providers to do the same unless retention is required by law.

Request to Opt-Out. You may submit a request to opt out of the sale of your personal data as well as its processing for targeted advertising or consumer profiling. We do not sell, rent, or lease your personal data to third-parties and do not process your personal data for targeted advertising or consumer profiling.

Appeal. If we notify you that no action is to be taken in response to your request to access, correct, delete, or opt-out, you may appeal this decision by contacting us within 30 days with the reason why you believe further action should be taken. If you are not satisfied with the result of the appeal, you may contact the Virginia Attorney General or submit a complaint online at https://www.oag.state.va.us/consumer-protection/index.php/file-a- complaint.

Withdraw Consent for Your Sensitive Personal Information. We only collect, use, or disclose your sensitive personal information for purposes reasonably necessary to carry out the services which you request from Higi. However, you may withdraw your consent to the use or disclosure of your sensitive personal information.

We may not, and will not, treat you differently because of your Consumer Request activity. As a result of your Consumer Request activity, we may not and will not deny goods or services to you; charge different rates for goods or services; provide a different level quality of goods or services; or suggest any of the preceding will occur. However, we can and may offer a different price, rate, level, quality, or selection of goods or services to you.

Changes to Our Privacy Policy

We reserve the right to change or modify this Policy or any of our tools or services at any time, and any changes are effective upon being posted unless we advise otherwise. If we make any material changes to this Policy, we will notify you by email or post notice on this website before the change becomes effective.

We encourage you to frequently review this website for the latest information on our privacy practices. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. You are bound by any changes to our Privacy Policy when you use the Service after such changes have been first posted. If you do not accept the terms of our Privacy Policy, we ask that you do not register with us and that you do not use Higi. Please exit Higi immediately if you do not agree to the terms of this Privacy Policy.

Reasonable Fees

Subject to applicable law, Higi may charge a reasonable fee for the administrative costs of any request that is manifestly unfounded or excessive.

How to Contact Us

If you have any questions about this Policy, you may contact us by using the “Contact us” link at the bottom of every page of our Site, by email at privacy@higi.com, or by mail at:

Higi SH LLC
Attn: Privacy Officer
100 S. Wacker Drive, Suite 1600, Chicago, IL 60606

Our Data Protection Officer may be contacted at:

Higi Data Protection Officer

privacy@higi.com