1. Information We Collect

Contact information. When you request an intake call, contact us, or provide information through a form, we collect information such as your name, email address, and phone number.

Health-related and service information. If you proceed through intake, we collect information you choose to provide about your health history, service history, symptoms, and related records, so that clinical intake, the Clinical Baseline and Care Advocacy can occur. Clinical documentation produced by independent clinicians during a membership is governed by the Member Service Agreement.

Records we gather for you. With your written authorization, we request records about you from other sources to build your record, such as the Department of Veterans Affairs (including your claims file, or C-File, your service treatment records and your VA Blue Button records), community care providers, private doctors and pharmacies.

Payment and financing information. If you become a member, we collect the information needed to bill you. Card payments are handled by our payment processor. If you choose to finance your membership, your application is handled by the third-party lender you choose, under its own privacy policy.

Communications. If you communicate with our team by phone, calls with VHN's care team may be recorded for service delivery, compliance documentation, training, and dispute resolution, consistent with the consent provisions of the Member Service Agreement for members and applicable law for all callers. Visits with clinicians are not recorded. If a visit is ever to be recorded, you will be told first and may opt out.

Usage and device data. Our hosting infrastructure automatically logs basic technical information such as IP address, browser type, pages requested, and timestamps, used for security and site operation. Measurement tools are described in section 8.

2. How We Use Information

We use the information we collect to:

• Respond to your inquiries and schedule and conduct intake conversations.
• Deliver the Clinical Baseline, Care Advocacy, pay-per-visit network visits and record delivery for members.
• Administer memberships, the Clinical Baseline Guarantee, billing, and financing.
• Communicate with you about your intake, scheduling, and Care Advocacy, including by text message where you have consented.
• Operate, secure, and improve the Site.
• Comply with legal obligations and enforce our agreements.

We do not sell your health information or use it to market to you. We do not use health information you give us to target advertising, and we do not share it with advertising platforms. We collect and share consumer health data only with your consent or as needed to provide a service you asked for, as described in the Consumer Health Data Privacy Notice. We do not set up geofences around health care facilities to message or track people.

3. How Information Is Shared

VHN shares personal information only as described here. VHN does not sell personal information.

Independent clinicians. Information you provide through intake, including health-related information, is shared with the independent licensed clinicians who provide your care through VHN for the purpose of clinical evaluation, documentation, and continuity of care.

People you choose. Your clinical records are yours. We share them with anyone else, including a VA-accredited representative or Veterans Service Organization, only at your direction and with your written authorization, which you may revoke at any time as provided in the Member Service Agreement.

Your VA care team. With your consent, we send your Clinical Baseline to your VA care team. We never submit anything to the Department of Veterans Affairs for a claim.

Advertising platforms. Our advertising landing pages use the Meta Pixel, and our forms may send a lead event to Meta through the Meta Conversions API, as described in section 8, including how to opt out. This may be treated as "sharing" for cross-context behavioral advertising. It never includes your health information, intake answers or tool results.

Service vendors. We use third-party vendors for functions such as website hosting, scheduling, communications, secure record storage, payment processing, and AI-assisted documentation and operations tools. Vendors receive only the information needed to perform their function and are not permitted to use it for their own marketing.

Third-party lenders. If you choose to finance your membership, the third-party lender you choose receives the information needed to process your application and any refund, and handles it under its own privacy policy.

Legal requirements. We may disclose information where required by law, subpoena, or legal process, or where necessary to protect rights, safety, or the integrity of our services.

Corporate events. If VHN is involved in a merger, acquisition, or sale of assets, information may be transferred as part of that transaction, subject to this Policy.

4. Text Messaging (SMS) Data

If you provide your mobile number, we use it to send informational messages related to your inquiry, intake, scheduling, appointment reminders, billing, and Care Advocacy. We send marketing texts only with your prior express written consent, as described in the Terms of Service. Message frequency varies. Message and data rates may apply. You may opt out at any time by any reasonable means, such as replying STOP or another opt-out word, replying in your own words, or emailing legal@myvhn.org; we honor opt-outs as soon as practicable and no later than 10 business days after receiving them. Reply HELP for help. Consent to receive text messages is not a condition of purchasing any service.

Mobile opt-in information, including phone numbers and consent status, is not shared with third parties or affiliates for their marketing or promotional purposes. Text messaging originator opt-in data and consent are used solely to deliver the messages described above.

5. Data Retention

We retain personal information for as long as needed to provide the services, comply with legal, regulatory, and contractual obligations, resolve disputes, administer the Clinical Baseline Guarantee, and enforce agreements. You own your record. Clinical records belong to the member; retention and delivery of member clinical records are governed by the Member Service Agreement. When information is no longer needed, we delete it or de-identify it. We keep each category for no longer than reasonably necessary:

• Contact information from people who do not enroll: 3 years after our last contact with you.
• Member account, billing and membership records, including records of your consent to renewal terms: the length of the membership plus 7 years, and consent records for at least 3 years.
• Health records: as long as the law requires medical records to be kept in the state where you received care.
• Recorded calls: 2 years.
• Website usage data: 14 months.

6. Data Security

We use administrative, technical, and organizational safeguards designed to protect personal information, including access controls and encryption in transit. We keep member information in secure third-party platforms, such as Hint, used to store and protect it. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If a breach affecting your personal information occurs, we will notify you as required by applicable law.

7. Your Rights and Choices

Subject to applicable law, you may:

• Request access to the personal information we hold about you.
• Request correction of inaccurate information.
• Request deletion of your information, subject to legal and contractual retention requirements.
• Revoke an authorization to share your records, as provided in the Member Service Agreement.
• Opt out of text messages at any time by replying STOP.

To exercise any of these rights, email legal@myvhn.org or call (317) 648-9563. We will verify your identity before acting on a request. We respond within 45 days. If we need more time, we may extend that once by up to 45 more days and will tell you why within the first 45 days. If we deny your request, we will explain why, and you may appeal by writing to legal@myvhn.org with "Privacy appeal" in the subject line. We will respond to an appeal within 45 days and, if we deny it, tell you how to contact your state attorney general.

8. Cookies and Tracking

The Site uses Google Tag Manager, Google Analytics 4 and Humblytics to measure how pages are used, such as page visits and button clicks. Our advertising landing page also uses the Meta Pixel, provided by Meta Platforms, Inc., to measure the effectiveness of our advertising. These tools may set cookies and receive device and usage information, such as IP address, browser information and the pages you visit, subject to each provider's own privacy policy. We set them up so they do not receive your name, health information, intake answers or tool results.

We may use HubSpot to provide some forms on the Site. If we do, HubSpot may set a tracking cookie to recognize your browser and connect your form submission to your later visits. When you submit a form, we may also send a lead event to Meta through the Meta Conversions API to measure the effectiveness of our advertising. Where we use these tools, they are set up so they do not send your health information, intake answers or tool results.

Your choices for measurement and advertising tools. On our main website, Google Tag Manager, Google Analytics, Humblytics, the Meta Pixel and the Meta Conversions API lead event run only after you choose "Accept" in our cookie banner. On our advertising landing pages, which are the pages people reach from our ads, a notice at the bottom of the page says that we use cookies and the Meta Pixel to measure our ads, and these tools run unless you opt out. You can opt out on any page, at any time, through the "Your Privacy Choices" link at the bottom of the page. If your browser sends a Global Privacy Control signal, we treat it as an opt-out and these tools do not run.

Global Privacy Control. If your browser sends a Global Privacy Control (GPC) signal, we treat it as a valid request to opt out of the sale and sharing of your personal information, and of targeted advertising, for that browser. We do this without asking you to log in or give more information, and the signal overrides any earlier consent you gave in that browser. If we know who you are, we apply the opt-out to your account as well.

You can also limit measurement through your browser's cookie controls, browser extensions that block trackers, and Meta's own advertising preferences (available in your Meta account settings). You may also contact legal@myvhn.org with questions or opt-out requests.

If additional measurement tools are added, this section will be updated before or at the time they become active, including any consent mechanisms required by applicable law.

9. Children's Privacy

The Site and VHN's services are not directed at children and are intended for adults 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us personal information, contact legal@myvhn.org and we will delete it.

10. Visitors From the EU and UK

VHN is a United States service, offered exclusively to U.S. Veterans. VHN has no establishment in the European Union or the United Kingdom and does not target or intentionally offer services to EU or UK residents. As a result, VHN does not expect the EU or UK General Data Protection Regulation (GDPR) to apply to its processing.

If you nevertheless access the Site from the EU or UK and provide personal data, we will honor the following on request: access to your data, rectification, erasure, restriction of processing, data portability, and objection to processing. Where processing occurs, its legal bases are your consent, performance of a contract or steps taken at your request before entering a contract, and our legitimate interests in operating and securing the Site. Requests may be sent to legal@myvhn.org.

11. U.S. State Privacy Rights

State privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA) and similar laws in Colorado, Connecticut, Virginia, Oregon, Texas and other states, give residents rights over their personal information. VHN extends these rights to every person, wherever they live.

What we collect and disclose. In the past 12 months we collected these categories: identifiers (such as name, email, phone number and IP address); customer records and payment information; characteristics such as Veteran status; health information (a sensitive category); internet and device activity; audio recordings of calls with our care team; and inferences drawn from them. We disclosed them for business purposes to the recipients described in section 3. We have not sold personal information. On our advertising landing pages unless you opt out, and on our main website only if you accept our cookie banner, we may "share" identifiers and internet activity with Meta for advertising measurement. We do not sell or share the personal information of anyone we know to be under 16.

Sensitive information. We use health information and other sensitive personal information only to provide the services you request and for other purposes the law permits, and only with your consent where the law requires it. We do not use it to infer characteristics about you for other purposes.

Subject to verification and applicable exceptions, your rights include:

• The right to know the categories and specific pieces of personal information we collect, use, and disclose.
• The right to delete personal information.
• The right to correct inaccurate personal information.
• The right to opt out of the sale or sharing of personal information, and of targeted advertising. VHN does not sell personal information. Our advertising landing pages use the Meta Pixel, and our forms may send a lead event through the Meta Conversions API, for advertising measurement, as described in section 8; this may be treated as "sharing" for cross-context behavioral advertising. You can opt out through the "Your Privacy Choices" link at the bottom of every page, by sending a Global Privacy Control signal, or by contacting legal@myvhn.org.
• The right to withdraw consent you gave for processing sensitive information or consumer health data.
• The right to obtain a list of the specific third parties to which we have disclosed your personal information, where state law provides it.
• The right to appeal a decision about your request, as described in section 7.
• The right not to be discriminated against for exercising any privacy right. We do not offer financial incentives for personal information.

You may designate an authorized agent to make requests on your behalf. We may ask the agent for proof of your signed permission and ask you to verify your identity. To exercise any right, email legal@myvhn.org or call (317) 648-9563. We respond within the times described in section 7.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The Effective Date reflects the most recent revision. Material changes will be posted on this page before they take effect. We will not use personal information or consumer health data for a materially different purpose than the one described when we collected it without first getting your consent.

13. Contact

Privacy questions and requests may be directed to:

• Veteran Health Network LLC
• 6417 W County Rd. 250, Danville, IN 46122
• legal@myvhn.org

14. Effective Date

This Privacy Policy is effective as of October 26, 2026.