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LEGAL

Privacy Policy

Last Updated April 2026

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1. Introduction and Acceptance

WON Direct Primary Care, LLC ("WON DPC," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy ("Policy") explains how we collect, use, disclose, and safeguard information you provide when you visit our website, landing page, or otherwise interact with our online presence.

By accessing or using our website and related services (collectively, the "WON DPC Services"), you agree to be bound by this Policy. By using the WON DPC Services and/or submitting personal data, you expressly consent to our practices surrounding the collection, use, and sharing of your personal information as described herein.

IF YOU DO NOT CONSENT AND AGREE WITH THE TERMS OF THIS PRIVACY POLICY, YOU CANNOT, AND WE DO NOT AUTHORIZE YOU TO, ACCESS, BROWSE, OR USE THE WON DPC SERVICES.

2. About WON DPC and HIPAA

WON Direct Primary Care, LLC operates as a Direct Primary Care (DPC) practice under a direct-pay membership model. DPC practices that do not submit claims to health insurers may not qualify as a "covered entity" under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). However, WON DPC voluntarily applies privacy protections consistent with HIPAA standards and complies fully with HIPAA to the extent it applies to our operations.

Information submitted through our website contact or interest forms (such as your name, email address, and phone number) is pre-membership contact information, not clinical health information, and is governed by this Policy.

3. Applicable Privacy Laws

Our processing of personal information will be undertaken consistent with applicable privacy laws, including but not limited to:

- Georgia Computer Systems Protection Act (O.C.G.A. § 16-9-90 et seq.) and Georgia data breach notification law (O.C.G.A. § 10-1-910 et seq.)

California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)

- Virginia Consumer Data Protection Act (VCDPA)

- Colorado Privacy Act (CPA)

- Texas Data Privacy and Security Act (TDPSA)

- Connecticut Data Privacy Act, Montana Consumer Data Privacy Act, Tennessee Information Protection Act, Iowa Consumer Data Protection Act, Delaware Personal Data Privacy Act, Nebraska Data Privacy Act, New Hampshire Privacy Act, New Jersey Data Privacy Act, Oregon Consumer Privacy Act, and Utah Consumer Privacy Act

- EU General Data Protection Regulation (GDPR) and UK GDPR, to the extent applicable

- Canadian Personal Information Protection and Electronic Documents Act (PIPEDA), to the extent applicable

- CAN-SPAM Act and Telephone Consumer Protection Act (TCPA)

4. Information We Collect

4.1 Information You Voluntarily Provide

When you submit an interest or contact form on our website or landing page, we may collect:

- Your full name

- Email address

- Phone number

- Any message or inquiry you choose to include

4.2 Information Collected Automatically

When you visit our website, certain information may be collected automatically through cookies and similar technologies, including:

- IP address and general geographic location

- Browser type, version, and operating system

- Pages visited, time spent on each page, and navigation paths

- Referring website or search engine

- Domain name of any website from which you navigated to the WON DPC Services

- Device type and mobile device identifiers

- Frequency of visits and other usage statistics (collectively, "Traffic Data")

4.3 Information You Provide When Joining

If you become a member by following a link from our website to our Electronic Health Record (EHR) platform, information you provide through that platform is subject to the EHR platform's own privacy policy and terms, as well as our Membership Agreement and Notice of Privacy Practices. Please review those documents carefully.

5. Tracking Tools, Cookies, and Opt-Out Options

5.1 Types of Cookies We Use

We may use the following types of cookies and tracking tools:

- Absolutely Necessary Cookies: Essential to enable core website functionality. Without these, services you have requested cannot be provided.

- Performance Cookies: Collect anonymized, aggregated information about how you use the WON DPC Services (browsers used, pages visited, visit duration) to improve user experience. These do not personally identify you.

- Functionality Cookies: Allow the website to remember choices you make (such as language or region preferences) to provide enhanced, personalized features. These cannot track your browsing on other websites.

- Web Beacons / Pixel Tags: Tiny graphic files embedded in web pages or emails used to analyze usage patterns and email engagement.

- Web Service Analytics: Third-party analytics tools that may record mouse clicks, scrolling activity, and navigation behavior to help us improve the WON DPC Services. These generally do not collect personal information unless you voluntarily provide it.

5.2 Managing Cookies

You may control cookie settings through your browser (e.g., Chrome, Safari, Firefox, Edge). Disabling certain cookies may affect the functionality of parts of our website. You may also opt out of certain interest-based advertising cookies by visiting the Network Advertising Initiative (NAI) opt-out page or the Digital Advertising Alliance (DAA) opt-out page.

5.3 Do Not Track and Global Privacy Control

Some browsers incorporate a "Do Not Track" (DNT) feature. Because there is no current industry consensus on what constitutes a DNT signal, we do not proactively respond to DNT signals at this time. However, we do recognize and honor Global Privacy Control (GPC) signals, which communicate a user's request to opt out of the sale or sharing of personal information, as required by applicable law.

6. How We Use Your Information

We use the information collected through our website solely for the following purposes:

- To respond to your inquiries about our practice and membership

- To provide you with information about our services, pricing, and membership options

- To contact you via email, phone, or SMS regarding your interest in or membership with WON DPC (subject to your consent where required)

- To send appointment reminders or practice updates if you have opted in

- To improve our website and communications

- To detect, prevent, and investigate security incidents or fraudulent activity

- To comply with applicable legal obligations

We do not use your contact information for general third-party marketing, sell it to advertisers, or use it for purposes unrelated to your inquiry or membership.

7. SMS and Email Communications

By submitting your phone number and checking a consent box, clicking a submission button, or taking another affirmative action on our website, you consent to receive emails and/or calls and text messages, including live, prerecorded, and/or automated calls and messages, to that email or phone number from WON DPC.

- Consent: By opting in via website form, scheduling platform, or SMS keyword, you give explicit written consent to receive SMS messages from WON DPC.

- Frequency: Message frequency may vary.

- Opt-Out: You may opt out at any time by replying STOP to any SMS message. Reply HELP for assistance.

- Fees: Normal message and data rates may apply based on your mobile plan. Neither WON DPC nor participating carriers guarantee message delivery.

- A2P Compliance: We use compliant messaging platforms and follow A2P 10DLC regulations to ensure deliverability and security.

This consent is not a condition of membership or the purchase of any service.

8. How We Share Your Information

WON DPC does not sell, rent, or trade your personal information. We may share your information only in the following limited circumstances:

- Service Providers: Trusted vendors who assist in operating our website, managing communications, or providing administrative services (e.g., email platforms, website hosting, analytics). These vendors are contractually obligated to protect your information and use it only as directed by us.

- EHR Platform: If you initiate enrollment, your information will be shared with our EHR platform provider to facilitate account creation and membership management.

- Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred, subject to the same privacy protections. We will make reasonable efforts to notify you before your information becomes subject to different privacy practices.

- Legal Requirements: We may disclose information if required by law, court order, or governmental authority, or to protect the rights, safety, or property of WON DPC or others, enforce this Policy, or respond to claims that content violates third-party rights.

9. Artificial Intelligence and Automated Processing

To the extent we employ AI or automated processing technologies in connection with the WON DPC Services, we are committed to using such technologies responsibly and transparently. Any automated processing we use may analyze usage patterns and preferences to improve service delivery. We do not make legally significant automated decisions about you without human oversight.

You have the right to obtain an explanation of any automated decision, challenge its basis, and request human review. Contact us at [email protected] with any concerns about automated processing.

10. Georgia-Specific Privacy Rights

Georgia residents have rights under the Georgia Computer Systems Protection Act (O.C.G.A. § 16-9-90 et seq.). In the event of a data breach involving your personal information, we will notify you as required under Georgia's data breach notification law (O.C.G.A. § 10-1-910 et seq.) within the timeframes prescribed by statute.

11. Rights Under U.S. State Privacy Laws

Depending on your state of residence, you may have additional rights including:

- Right to know what personal information we collect, use, share, or sell

- Right to access and receive a copy of your personal information

- Right to correct inaccurate personal information

- Right to delete your personal information, subject to legal obligations

- Right to opt out of the sale or sharing of personal information (we do not sell personal information)

- Right to non-discrimination for exercising your privacy rights. We will not deny you services, charge different prices, or provide a different level of service for exercising these rights

To exercise any of these rights, contact us using the information in Section 18.

12. Rights Under GDPR, UK GDPR, and PIPEDA

If our processing of your personal information is subject to GDPR, UK GDPR, or PIPEDA, you may have the following additional rights:

- Right of Access: View and request copies of your personal information

- Right to Rectification: Request correction of inaccurate or outdated information

- Right to Erasure (Right to be Forgotten): Request deletion of your personal data upon verified request

- Right to Restrict Processing: Request restriction or suppression of processing

- Right to Data Portability: Request transfer of your data to you or another controller

- Right to Withdraw Consent: Withdraw previously given consent at any time

- Right to Object: Object to processing of your personal information

- Right to Object to Automated Processing: Object to decisions based solely on automated processing or profiling

We will verify your identity before processing these requests and may deny requests where identity cannot be verified. Government or other identification may be required.

If your personal data is subject to GDPR or UK GDPR, we transfer personal data from the EEA only pursuant to a documented adequacy determination or adequate privacy protections. The data controller for GDPR/UK GDPR/PIPEDA purposes is WON Direct Primary Care, LLC.

13. Data Security

We implement reasonable and appropriate administrative, technical, and physical security measures, including encryption and secure forms, to protect the information we collect from unauthorized access, disclosure, alteration, or destruction. However, no method of electronic transmission or storage is 100% secure. We recommend you do not use unsecured channels to communicate sensitive information to us. Any information transmitted is done so at your own risk.

14. Data Retention

We retain personal information for as long as necessary to provide you the WON DPC Services, fulfill the purposes described in this Policy, or comply with our legal obligations. Afterwards, we retain some information in de-identified and/or aggregated form that does not identify you personally. Pre-membership contact information is not retained longer than necessary for membership inquiry follow-up.

15. Children's Privacy

Our website is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children under 18 without verifiable parental or guardian consent. By accessing or using the WON DPC Services, you represent that you are at least 18 years of age.

If you are a parent or legal guardian of a minor child, you may use the WON DPC Services on the minor child's behalf in compliance with this Policy. If you believe a child has submitted information to us, please contact us immediately so we can delete it.

16. Third-Party Links

Our website may contain links to third-party websites and platforms, including our EHR enrollment platform. WON DPC is not responsible for the privacy practices, content, or accuracy of any third-party site. We encourage you to review the privacy policies of any third-party sites you visit. A link to a third-party website does not constitute our endorsement.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the Effective Date at the top of this page and post the updated Policy. Your continued use of our website after any changes constitutes your acceptance of the updated Policy.

IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING THE WON DPC SERVICES AFTER THE EFFECTIVE DATE OF SUCH CHANGES.

18. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us:

WON Direct Primary Care, LLC Attn: Privacy Officer 1605 Church St STE 610-110 Decatur, GA 30033. Email: [email protected]. Phone: 770-758-3230

WON Direct Primary Care

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