Privacy Policy

Website Privacy Policy

Version 1.1

Last revised on: November 22nd, 2023

Winston Health (the “Company”) is committed to maintaining robust privacy protections for its users.  Our Privacy Policy (“Privacy Policy”) is designed to help you understand how we collect, use and safeguard the information you provide to us and to assist you in making informed decisions when using our Service. For purposes of this Agreement, “Site” refers to the Company’s website, which can be accessed at or through our mobile application.

“Service” refers to the Company’s services accessed via the Site, in which users can track daily activity goals & rewards, redeem employer-sponsored wellness credits to linked financial institutions, link third-party health portals, and shop for healthcare services and their associated costs.

The terms “we,” “us,” and “our” refer to the Company. “You” refers to you, as a user of our Site or our Service.

By accessing our Site or our Service, you accept our Privacy Policy and Terms of Use (found here:, and you consent to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Policy.

      1. INFORMATION WE COLLECT: We collect “Non-Personal Information” and “Personal Information.” Non-Personal Information can include information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. Personal Information can include your email, name, address, contact information, employer name, medical insurance plan name, and financial institution information which you submit to us through the registration process at the Site.
        1. Information collected via Technology: To activate the Service you need to submit your first and last name, email address, and date of birth. To use the Service thereafter, you may need to submit further Personal Information, which may include your: address, medical insurance plan name, and financial institution information.
        2. Information collected via Portal Information and Portal Credentials: In order to fully benefit from our Services, you also must provide your third-party health portal credentials ("Portal Credentials") to allow us to access your health data at those other healthcare providers' organizations ("Portal Information") for your use. We collect and keep your medical information through the personal health record and sync your medical record information from your healthcare provider or another third-party source using our HealthRecord feature.
        3. Other information collected: In an effort to improve the quality of the Service, we track information provided to us by your browser or by our software application when you view or use the Service, such as the website you came from (known as the “referring URL”), the type of browser you use, the device from which you connected to the Service, the time and date of access, and other information that does not personally identify you. We track this information using cookies, or small text files which include an anonymous unique identifier. Cookies are sent to a user’s browser from our servers and are stored on the user’s computer hard drive. Sending a cookie to a user’s browser enables us to collect Non-Personal information about that user and keep a record of the user’s preferences when utilizing our services, both on an individual and aggregate basis. The Company may use both persistent and session cookies; persistent cookies remain on your computer after you close your session and until you delete them, while session cookies expire when you close your browser.
        4. Information you provide us by registering for an account: In addition to the information provided automatically by your browser when you visit the Site, to become a subscriber to the Service you will need to create a personal profile. You can create a profile by registering with the Service and entering your email address, and creating a password. By registering, you are authorizing us to collect, store and use your email address in accordance with this Privacy Policy.
        5. Consent for Use of Health Information: To ensure the protection of your health information, we require your express consent before accessing, exchanging, or using your health data. This consent is obtained separately from the general terms of service and privacy policy agreements. You will be explicitly asked to authorize any access or use of your health information, and we will clearly indicate the purposes for which it is being accessed or used. We commit to not sharing or selling your health information without your express consent, except as required by law or as necessary for business transactions such as mergers or acquisitions.
        6. Access to Information from Member's Device: We do not access any additional information from your device beyond what is necessary to provide our Service, unless explicitly authorized by you. If such authorization is given, we will clearly state what information is being accessed and for what purposes.
        7. Stopping Access to Information and Disposal of Member's Information: You have the right to cease access to your information at any time. To do so, please contact us at Upon receiving your request, we will promptly cease accessing your information. If you choose to delete your account, we will dispose of your personal and health information in accordance with our data retention policy. All personal information associated with your account will be deleted in a manner that ensures your privacy and the security of your data.
        8. Children’s Privacy: The Site and the Service are not directed to anyone under the age of 13. The Site does not knowingly collect or solicit information from anyone under the age of 13, or allow anyone under the age of 13 to sign up for the Service. In the event that we learn that we have gathered personal information from anyone under the age of 13 without the consent of a parent or guardian, we will delete that information as soon as possible. If you believe we have collected such information, please contact us at Minors under 18 years of age may have the personal information that they have provided to us through our website deleted by sending an email to requesting deletion.
        1. Personal Information:
          1. We may use the information we collect from you when you sign up, register, respond to a survey or marketing communication, surf our website, or use certain other features of the Services in the following ways:
            1. To personalize your experience on the website and to allow us to deliver content and product offerings that interest you.
            2. To allow us to better respond to your customer service requests.
            3. To quickly process your requested transactions.
            4. To administer a promotion, survey or other feature of our website.
          2. We will not sell, rent, license, or trade your personal information with third parties for their own direct marketing use unless you expressly tell us it is okay to do so. Unless you give us your permission, we will not share your personal information other than as stated in this Privacy Policy. Your personal information, including your health information, will not be shared or sold in the future, unless you give us your explicit permission.
          3. When you use our Service, you can decide whom you want to be able to see your medical information by using the data sharing options in your Account Settings. We do share Personal Information with vendors who are performing services for the Company, such as the servers for our email communications who are provided access to user’s email address for purposes of sending emails from us. Those vendors use your Personal Information only at our direction and in accordance with our Privacy Policy. In general, the Personal Information you provide to us is used to help us communicate with you. For example, we use Personal Information to contact users in response to questions, solicit feedback from users, provide technical support, and inform users about promotional offers. We may share Personal Information with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce applicable Terms of Service, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our users or the public as required or permitted by law.
        2. Non-Personal Information: In general, we use Non-Personal Information to help us improve the Service and customize the user experience. We also aggregate Non-Personal Information in order to track trends and analyze use patterns on the Site. This Privacy Policy does not limit in any way our use or disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-Personal Information to our partners, advertisers and other third parties at our discretion.
        3. Mergers & Acquisitions: In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy. If our information practices change at any time in the future, we will post the policy changes to the Site so that you may opt out of the new information practices. We suggest that you check the Site periodically if you are concerned about how your information is used.
      3. HOW WE PROTECT INFORMATION: We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use. We further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Service, you acknowledge that you understand and agree to assume these risks.
      4. YOUR RIGHTS REGARDING THE USE OF YOUR PERSONAL INFORMATION: You have the right at any time to prevent us from contacting you for marketing purposes.  When we send a promotional communication to a user, the user can opt out of further promotional communications by following the unsubscribe instructions provided in each promotional e-mail. You can also indicate that you do not wish to receive marketing communications from us in the "Settings” section of the Site. Please note that notwithstanding the promotional preferences you indicate by either unsubscribing or opting out in the "Settings" section of the Site, we may continue to send you administrative emails including, for example, periodic updates to our Privacy Policy.
      5. YOUR RIGHTS REGARDING CHANGING OR DELETING YOUR INFORMATION: You may review and request changes to your personal information that we have collected. You may also request deletion of your personal information from our databases in order to close your account and prevent receipt of future communications. When you choose to delete your account, all of your personal information associated with the account is deleted immediately, and is no longer accessible by you or Winston Health. You may submit requests to change or delete your personal information using either of the following options:

        You can send your request via email to

        You can mail your request to the following postal address:
        Winston Health LLC
        410 Spring Drive,
        Millersville, PA 17551

      6. LINKS TO OTHER WEBSITES: As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Privacy Policy applies solely to information collected by us through the Site and the Service. Therefore, this Privacy Policy does not apply to your use of a third party website accessed by selecting a link on our Site or via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites before proceeding to use them.
      7. CHANGES TO OUR PRIVACY POLICY: The Company reserves the right to change this policy and our Terms of Use at any time.  We will notify you of significant changes to our Privacy Policy by sending a notice to the primary email address specified in your account or by placing a prominent notice on our site. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Site and this privacy page for updates.
      8. CONTACT US: If you have any questions regarding this Privacy Policy or the practices of this Site, please contact us by sending an email to