GAINWELL TECHNOLOGIES LLC PRIVACY POLICY
Gainwell Technologies LLC. (“Gainwell” “us” or “we”) is committed to protecting yourprivacy. This Privacy Policy describes how we collect, use, and disclose information throughour website that we operate on behalf of the Maine Department of Health and Human Services(the “Website”).
Please note that we also operate certain online services on behalf of Maine Department of Healthand Human Services via the “Secure Website Services,” (collectively, with the Website, the“Services”) which are separately governed by the terms of your Trading Partner Account or, ifyou are a Maine Medicaid member, your applicable Notice of Privacy Policies as set forthbelow.
I.

CONSENT

Please read this Privacy Policy carefully. By accessing, downloading, or using any of theServices, you agree that you are bound by this Privacy Policy and the Gainwell Site Terms. IF
YOUDO NOT AGREE TO THE GAINWELL SITE TERMS AND THIS PRIVACYPOLICY, INCLUDING ANY CHANGES THERETO, THEN YOU MUST NOT ACCESSAND USETHE SERVICES.
II.

COLLECTION AND USE OF PERSONAL INFORMATION
Public Websites

When you visit the portions of the Website that do not require an account login, nopersonal information—such as your name, date of birth or telephone number (“PersonalInformation”) is collected, unless you provide us with that information voluntarily. Gainwellwill not sell, license, transmit or disclose this information outside of Gainwell and its affiliatedcompanies unless (a) expressly authorized by you, (b) necessary to enable Gainwell’scontractors or agents to perform certain functions for us, or (c) required or permitted by law. In
all cases, we will disclose the information consistent with applicable laws and regulations and wewill require the recipient to protect the information and use it only for the purpose it wasprovided.
Secure Website Services
Gainwell also operates certain online services via the Secure Website Services that
require a password and account to access. When using such sites, you may disclose Personal
Information to us. We may collect your Personal Information to provide services on behalf of theMaine Medicaid for the following:•The Secure Website Services require you to create an account and password to log in
before accessing information, thus you may need to provide certain Personal Information
so that we may verify your identity;•To use and share your Personal Information to facilitate access to your healthcare
benefits; and;•To respond to requests via email or any type of communication provided via the SecureWebsite Services.

We comply with applicable requirements under the Health Insurance Portability andAccountability Act (HIPAA).
Users of the Secure Website Services understand that the confidentiality of Personal
Information is protected by federal and state law. By using the Secure Website Services, yourepresent that you are either (i) the individual to whom this account pertains, or (ii) legallyauthorized under applicable law to receive health care information regarding, and to makehealthcare decisions for, the individual to whom this account pertains (for example, as the parent,legal guardian, or legal custodian of such individual).
When you use the Website, we may collect certain information, including the following:•Use of the Website. When you use the Website, we may collect certain information
about such use, which provides us with "usage data," such as the number of visitors we
receive or what pages are visited most often. This data helps us to analyze and improvethe usefulness of the information we provide on these websites.

•Unique Identifiers. We may collect certain information through unique identifiers suchas IP address when you are using the Website.

•Cookies. We may use “cookies” and other technologies to collect data that enable us tobetter understand and improve the usability, performance and effectiveness of ourWebsite. For instance, we may use session cookies (which expire once you close yourbrowser) or and persistent cookies (which stay on your mobile device until you deletethem) to provide you with a more personal and interactive experience on our Website.

•Third-Party Analytics. We use third parties’ analytic and tracking tools to better
understand who is using the Website, how people are using the Website and how toimprove the effectiveness of the Website and its content, and to help those parties serve
more targeted advertising to you across the Internet or help us serve more targeted
advertising to you. Those third-party companies may use cookies, pixel tags or othertechnologies to collect and store anonymous information such as time of visit, pages
visited, time spent using the Website, device identifiers, type of operating system used
and other website(s) you may have visited. They might combine information they collectfrom your interaction with the Website with Personal Information they collect from othersources. We do not have access to, nor control over, third parties’ use of cookies or othertracking technologies.

•Geo-Location. We do not collect any information regarding your real-time geo-location
while using the Website. We may, however, do so at some point in the future. We will
request your permission before collecting such information.

•DNT. Do Not Track (DNT) is a privacy preference that users can set in some webbrowsers, allowing users to opt out of tracking by websites and online services. Gainwelland the Website do not recognize DNT.

Gainwell may use your information for the following purposes:•

To provide you with the Services.

•

To communicate with you about your account or transactions with us and send you
information about features of the Services or changes to our policies.

•To personalize content and experiences and advertising.

•To detect, investigate and prevent activities that may violate our policies or be illegal.

•To optimize or improve the content, products, services, and features of the Services.

•To personalize and improve the Services and user experiences, to increase thefunctionality and user friendliness of the Services, to deliver content or features thatmatch user profiles or interests.

•To monitor and analyze the Services usage and trends and otherwise measure theeffectiveness of the Services.

III.

HOW WE SHARE YOUR INFORMATION

We will not share your Personal Information with third parties except as described in thisPrivacy Policy. We may share your Personal Information:•When you allow us to share your Personal Information with another company, such as
directing us to share your Personal Information with third-party sites or platforms.

•When we contract or partner with a third party to provide services on our behalf,
including to assist us in the development, operation, and maintenance of the Services.
We require all such third parties to process your data in accordance with this Privacy
Policy.

•When we share Personal Information with third parties in connection with the sale of abusiness (including merger, acquisition, or sale of all or a material portion of its assets,change in corporate control, or insolvency or bankruptcy proceedings), to enforce ourGainwell Site Terms or rules, to ensure the safety and security of our users and thirdparties,to protect our rights and property and the rights and property of our users andthird parties, to comply with legal process, including judicial warrant, rule, order or
subpoenaor in other cases if we believe in good faith that disclosure is required by lawor regulation.

In addition, we may share aggregate information with third parties, however such aggregate
information will not contain Personal Information.

IV.

YOUR CONTROLS AND CHOICES

You may exercise certain controls and choices regarding our collection, use and sharing of yourinformation, or request access to your Personal Information, by modifying your profile. Please
be aware that, if you do not allow us to collect Personal Information from you, we may not beable to deliver certain products and services to you, and some of our services may not be able totake account of your interests and preferences.
V.

THIRD PARTY WEBSITES / LINKS

Our Website may contain links to other sites operated by third parties. Gainwell does not control
such other sites and is not responsible for their content, their privacy policies, or their use ofPersonal Information. Gainwell’s inclusion of such links does not, by itself, imply anyendorsement of the content on such sites or of their owners or operators except as disclosed on
the Website. Gainwell expressly disclaims any and all liability for the actions of third parties,including but without limitation to actions relating to the use and/or disclosure of PersonalInformation by third parties. Any information submitted by you directly to these third parties issubject to that third party’s privacy policy.
VI.

DATA SECURITY, INTEGRITY AND RETENTION

The security, integrity and confidentiality of your information are important to us. We have
implemented technical, administrative, and physical security measures that are designed toprotect user information from unauthorized access, disclosure, use and modification. From time
to time, we review our security procedures to consider appropriate new technology and methods.
Please be aware though that, despite our best efforts, no security measures are perfect orimpenetrable. We will retain your Personal Information for the length of time needed to fulfill
the purposes outlined in this Privacy Policy unless a longer retention period is required, or for theestablishment, exercise, or defense of legal claims, or for legitimate businesses purposes, or as
provided by law.
VII.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy to reflect changes to our information practices. If we make any
material changes we will notify you by email (sent to the e-mail address specified in your account)or by means of a notice on the Website prior to the change becoming effective, and by updating
the Last Revised date at the top of this Privacy Policy. We encourage you to periodically review
this page for the latest information on our privacy practices.
VIII. NOT A SUBSTITUTE FOR PROFESSIONAL HEALTH CARE OR ADVICE
The information contained on the Website is general in nature and is intended for educational
purposes only. It is not a substitute for the advice of health care professionals. If you havespecific health care needs, or for complete health information, please see a doctor or other healthcare provider.
IX.

USERS OUTSIDE THE UNITED STATESThe Website and the servers upon which the Website is hosted are located in the United States
and are intended only to be used by individuals in the United States. Personal Information yousubmit using the Website will be transferred to and stored in the United States. By using theWebsite and submitting Personal Information, you authorize this transfer.
X.

CONTACT INFORMATION
45 Commerce Drive
Suite 7
Augusta, Maine04333