BHEALTHE, LLC

PRIVACY POLICY

Effective Date: October 8th, 2026

This Privacy Policy describes how BHealthE, LLC, an Illinois limited liability company (“BHealthE,” “we” or “us”), collects, uses, discloses and protects personal information. Part I applies to visitors to [www.bhealthe.com] and any other website or online service on which this Policy is posted (the “Site”), including individuals who submit inquiries or apply to become Advisors. Part II is our Advisor Privacy Notice. This Policy does not apply to websites, enrollment portals or applications operated by the insurers, plan sponsors and administrators whose products and programs we market (“Program Sponsors”). We do not sell personal information.

PART I — WEBSITE PRIVACY POLICY

Information We Collect

Information You Provide. Contact and inquiry information (name, email address, telephone number, mailing address, state of residence and the content of any message or request you submit); [if the Site offers quote requests: the information the request form asks for, such as date of birth, household size and ZIP code;] Advisor application information (name, contact information, business name, insurance license numbers and states, National Producer Number and the other information the application requests); and records of your communications with us, including any consent you give to receive marketing communications.

Information Collected Automatically. When you use the Site we and our service providers automatically collect device and usage information, including IP address, browser type, operating system, device identifiers, referring and exit pages, pages viewed, dates and times of visits, and approximate location derived from IP address, using cookies, pixels, web beacons and log files as described in Section 5.

Information from Other Sources. Confirmation from Program Sponsors and their administrators that an enrollment submitted by an Advisor was accepted or cancelled, which we use to administer Advisor compensation; licensing information from databases such as the National Insurance Producer Registry; and information from service providers that assist with analytics, fraud prevention or communications.

Health Information

The Site does not request or collect information about your health, medical conditions, treatment, medications or health insurance claims. Please do not submit health information through the Site. If you enroll in a health benefit program, the Program Sponsor will collect any health information it requires through its own application and enrollment process, subject to its own privacy policy and applicable law.]

How We Use Information

We use the information we collect to respond to your inquiries and connect you with an Advisor licensed in your state; transmit your requests to the applicable Program Sponsor at your direction; evaluate Advisor applications and verify licensing; administer the Advisor program, including compensation, compliance and communications; operate, secure and improve the Site; send you information about our services and the products and programs we market where you have consented or where permitted by law; comply with legal, regulatory, licensing and tax obligations; detect and prevent fraud and security incidents; and enforce our Terms of Use and other agreements.

How We Share Information

Service Providers. We share information with service providers that perform services for us and are contractually restricted from using it for their own purposes, including payment processing (our payment gateway stores payment card information in tokenized form; BHealthE does not store card numbers on its own systems), hosting of our Advisor Back Office and enrollment and compensation systems, payment of Advisor compensation, compliance monitoring of public online content, website analytics, and email and customer-relationship management.

Advisors and Program Sponsors. If you request information about a product or program, we share your contact and request information with an Advisor licensed in your state so that the Advisor can respond and, at your direction, with the applicable Program Sponsor so that it can process your application or enrollment. Advisors are independent contractors bound by contractual confidentiality and data-handling obligations. Program Sponsors process your information under their own privacy policies.

Legal and Regulatory. We disclose information when required or permitted by law, including to state insurance regulators and other governmental authorities; in response to subpoenas, court orders or other legal process; to protect the rights, property or safety of BHealthE, our users or others; and to enforce our agreements.

Business Transfers. If BHealthE is involved in a merger, acquisition, financing or sale of all or part of its business, information may be transferred as part of that transaction, subject to this Policy.

With Your Consent. We share information for other purposes with your consent or at your direction.

No Sale. We do not sell personal information, do not share it with third parties for their own direct marketing purposes, and do not share it for cross-context behavioral advertising.

Mobile Messaging. We collect mobile phone numbers only from individuals who opt in through our web forms or by texting a keyword to our number. Mobile phone numbers and text-messaging opt-in data are used only to operate our messaging programs. They are not sold, rented or shared with third parties or affiliates for marketing or promotional purposes. They may be shared with service providers that deliver messages on our behalf, solely to provide that service. We do not place protected health information in text messages, analytics tags, URLs or tracking parameters.

Cookies and Tracking Technologies

Technologies. We use cookies, pixels, web beacons and log files to operate the Site, remember your preferences, analyze traffic and measure the effectiveness of our communications. Some are placed by our service providers.

Your Choices. Most browsers allow you to refuse or delete cookies through their settings; doing so may affect Site functionality. You may opt out of Google Analytics at https://tools.google.com/dlpage/gaoptout.

Do Not Track. The Site does not currently respond to “Do Not Track” signals or similar mechanisms.

Third-Party Collection. Our analytics and advertising service providers may collect information about your online activities over time and across different websites when you use the Site. We do not control their collection practices.

Security and Retention

We implement and maintain reasonable administrative, technical and physical safeguards designed to protect personal information from unauthorized access, acquisition, use, modification, disclosure and destruction, and we require our service providers to do the same by contract. No method of transmission or storage is completely secure, and we cannot guarantee absolute security; please do not send sensitive information by email or through unsecured forms. If a security incident affects your personal information we will notify you as applicable law requires. We retain personal information for as long as needed for the purposes described in this Policy and to meet legal, regulatory, tax, licensing and record-keeping obligations, after which we delete or de-identify it. [If biometric identity verification is used for Advisors: We collect biometric identifiers only as described in our Biometric Information Policy, available at [URL].]

Your Choices

You may opt out of marketing emails using the unsubscribe link in any email, and revoke consent to marketing calls or text messages at any time by replying STOP to any text or by contacting us. We may continue to send transactional and service communications. You may request access to or correction of the personal information we hold about you by contacting us at the address below; we may need to verify your identity.

California Residents

Online Privacy Protection Act. This Policy identifies the categories of personally identifiable information we collect through the Site (Section 1), the categories of third parties with whom we may share it (Section 4), how you may review and request changes to your information (Section 7), how we notify you of material changes (Section 12), the effective date (above), how we respond to Do Not Track signals (Section 5.3), and whether other parties may collect information about your online activities across sites (Section 5.4).

Shine the Light. We do not disclose personal information to third parties for their direct marketing purposes. [Include only if BHealthE has 20 or more employees.]

Consumer Privacy Act. BHealthE does not currently meet the thresholds that make a company a “business” subject to the California Consumer Privacy Act. If we become subject to it we will update this Policy to describe your rights and how to exercise them. In the meantime, California residents may contact us at the address below with any request regarding their personal information, and we will respond in accordance with applicable law. California residents under 18 who have posted content on the Site may request its removal by contacting us.

Residents of Other States

Residents of states with consumer privacy laws may have rights to confirm whether we process their personal information; to access, correct or delete it; to obtain a copy; and to opt out of its sale, targeted advertising or certain profiling, to the extent those laws apply to us. We do not sell personal information or engage in targeted advertising or profiling that produces legal or similarly significant effects. To exercise any right that applies to you, contact us at the address below. We will verify your request, respond within the time required by law and, if we decline a request, tell you how to appeal.

Children

The Site is not directed to children under 18, and we do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided personal information to us, contact us and we will delete it.

Financial Privacy Notice

If you become a customer of an insurance product through BHealthE, the collection, use and disclosure of your nonpublic personal financial and health information in connection with that product are also governed by the Gramm-Leach-Bliley Act and state insurance privacy regulations. [Our Insurance Customer Privacy Notice, which we deliver to customers as those laws require, is available at [URL].] Where that notice and this Policy differ as to insurance customer information, that notice controls.

Changes to This Policy

We may update this Policy by posting the revised Policy on the Site with a new effective date. If we make a material change in how we use personal information already collected, we will provide notice on the Site or by email before the change takes effect.

Contact Us

BHealthE, LLC, Attn: Privacy, 7431 East State Street #258, Rockford, Illinois 61108; [privacy@bhealthe.com]; [telephone].

PART II — ADVISOR PRIVACY NOTICE

This Part II applies to individuals who apply to become or who contract with BHealthE as independent Advisors, supplements Part I, and is the Advisor privacy notice referenced in the Independent Advisor Agreement.

Information We Collect About Advisors

In addition to the information described in Part I: identification, contact and business entity information; insurance license numbers, lines of authority, states, appointment status and licensing history obtained from licensing databases; Social Security number or taxpayer identification number and Form W-9 information, for tax reporting; payout account information, which is collected and held by our payout service provider; enrollment, sales and compensation records generated through the Advisor Back Office; records of your communications with us and with customers; and public marketing activity attributable to you, as described in Section 15.

Compliance Monitoring

We monitor publicly available online content, including websites, social media posts and advertisements, for statements about BHealthE, the products and programs we market, and the Advisor opportunity, using compliance monitoring services. We collect and retain content attributable to you that relates to your activities as an Advisor and use it to enforce our Marketing Guidelines and to meet insurance advertising and consumer protection requirements. We do not access private accounts or non-public content.

How We Use and Share Advisor Information

We use Advisor information to evaluate applications, verify licensing and appointments, administer the Advisor program and the Advisor Back Office, calculate and pay compensation, report compensation to tax authorities, monitor and enforce compliance, communicate with you, and comply with legal and regulatory obligations. We share it with our service providers; Program Sponsors and their administrators, to establish and maintain your authorization to market their products and to reconcile enrollments and compensation; licensing and appointment systems; tax authorities; insurance regulators and other governmental authorities as required by law; and other Advisors in your enrollment line, limited to your name, Advisor status and qualification information as the Compensation Plan requires.

Retention and Your Rights

We retain Advisor records for the term of your engagement and for the period required by insurance, tax and record-keeping laws thereafter, and in any event not less than the period stated in the Independent Advisor Agreement. You may update your contact and profile information through the Advisor Back Office and may exercise any rights available under applicable state privacy law by contacting us at the address in Part I, Section 13.