Privacy Policy

Last Updated: October 6, 2026

 

1. Overview

This Privacy Policy describes the various ways InterWell Health Partners, Inc. and its affiliated companies (“Interwell,” “we,” or “us”) collects, uses, discloses, and otherwise processes information about you when you access or use our website located at https://www.interwellhealth.com/ (the “Website”). This Privacy Policy does not apply to any other Interwell website, service, or application, or any websites, services, or applications linked to or from the Website.

This Privacy Policy is incorporated into and forms part of our Terms of Use .

THIS PRIVACY IS A LEGALLY BINDING AGREEMENT BETWEEN INTERWELL AND YOU, SO PLEASE READ IT CAREFULLY. By accessing or using the Website, you acknowledge that you have read and understand this Privacy Policy.

2. Rights of California Residents

If you are a California resident, please click here to learn about your rights under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”).

Under California's "Shine the Light" law, California residents who provide Personal Information in obtaining products or services for personal, family or household use are entitled to request and obtain from us, once a calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

To obtain this information, please provide your name and address to privacy@interwellhealth.com, with "California Shine the Light Inquiry” in the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response.

3. Important Note about Health Information

3.1 HIPAA and PHI. Interwell Medical Group (“IMG”), as a telehealth provider for people with chronic kidney disease (“CKD”) stages 3-5 who need additional medical support beyond their existing healthcare, is a “covered entity” under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). If IMG creates, receives, maintains, or transmits “protected health information” (“PHI”), IMG’s use and disclosure of that PHI will be subject to IMG’s Notice of Privacy Practices . If there is any conflict between this Privacy Policy and IMG’s Notice of Privacy Practices with respect to the PHI, the Notice of Privacy Practices will control. In addition, in certain circumstances, Interwell may act as a “business associate” to a healthcare provider, practice, or health insurer. If Interwell creates, receives, maintains, or transmits PHI on behalf of a provider, practice, or health insurer in a manner subject to HIPAA, our use and disclosure of that PHI will be governed by the applicable Business Associate Agreement (“BAA”) between Interwell and the applicable provider, practice, or health insurer (and by any applicable law). If there is any conflict between this Privacy Policy and the applicable BAA with respect to the PHI, the BAA will control.

4. The Information We Collect

We collect two types of information. The first type is information that identifies an individual (called “Personal Information”). The second type is information that does not identify, and cannot reasonably be used to identify, an individual (called “Anonymous Information”). We collect the following particular Personal and Anonymous Information during your use of the Website in three primary ways: (a) information that you voluntarily choose to provide to us (such as when you submit a web form); (b) information that we collect automatically, such as through certain technology we use on our Website; and (c) information we obtain from third parties.

  • Information you provide. Information you provide to us, such as through completion of a web form on the Website (such as your completion of the “Contact Us” web form, the webinar registration web forms, or use of any other interactive portions of the Website) (e.g., name, email address, and phone number, and any messages, inquiries, or content you submit via the Website).
  • Information collected automatically. Device and usage information (e.g., IP address, device identifiers, browser type, operating system, language preferences, referring/exit pages, time/date stamps, clickstream data, and interactions with the Website); log and diagnostic information (e.g., performance data, crash reports, and other technical information to help us maintain and secure the Website); and any other information collected via cookies and similar technologies (e.g., location data).
  • Information from third parties. Information we obtain from a third party, such as a site or platform provider about use of the Website on third-party platforms or devices, or our business partners, subsidiaries, or affiliates.
5. How We Collect Your Information

As stated above, we collect information in the following ways:

  • We collect information directly from you when you voluntarily provide it to us, such as when you contact us on the Website or complete another web form.
  • We collect information automatically through your use of the Website via cookies, web beacons, and other similar technologies.
  • We receive information from our business partners, subsidiaries, affiliates, service providers, and third parties that help operate and secure the Website (e.g., Website performance data from hosting, communications, security, and analytics providers).

You are not required to voluntarily submit Personal Information to us in order to access or use the Website.

6. How We Use Your Information

Consistent with applicable law and any applicable choices and controls that may be available to you, we may use information collected from you, or from devices associated with you, to:

  • Provide, operate, and maintain the Website, including enabling the functions and services you request, view, or engage with;
  • Communicate with you, including responding to inquiries, sending administrative messages (e.g., updates, security alerts), and providing customer support (e.g., by providing a telephone number, you authorize Interwell (and those acting on Interwell’s behalf) to contact you at the number(s) you provide, including through calls and text messages (SMS/MMS), for purposes related to the Website and our services, as explained in our Terms of Use);
  • Improve and develop the Website, including debugging, testing, research, analytics, and product development;
  • Personalize user experience, including remembering preferences and tailoring Website content and functionality;
  • Security and fraud prevention, including protecting users, the Website, and our business from unauthorized access, misuse, and other threats; and
  • Legal and compliance purposes, including responding to lawful requests, enforcing our Terms of Use, and complying with applicable laws.

We may create aggregated or de-identified information from Personal Information. Aggregated or de-identified information does not identify you and may be used for business purposes, including analytics and improving the Website, to the extent permitted by applicable law.

7. How We Disclose Your Information

We do not sell or rent your Personal Information to third parties for money. We may disclose information in the following circumstances:

  • Service providers and vendors. We disclose information to third parties that perform services on our behalf (e.g., hosting, communications, customer support, security, and analytics). These parties are permitted to access and use information only as needed to perform services for us, subject to appropriate confidentiality and security obligations.
  • Subsidiaries and Affiliates. We may disclose information to our subsidiaries and affiliates for purposes consistent with this Privacy Policy.
  • Legal process, safety, and rights. We may disclose information if we believe in good faith that disclosure is necessary to comply with the law; respond to lawful requests; protect the rights, property, or safety of Interwell, users, or others; or enforce our Terms of Use.
  • Business transactions. We may disclose or transfer information in connection with a merger, acquisition, financing, reorganization, bankruptcy, dissolution, or sale of all or a portion of our assets. If such a transaction occurs, we will use reasonable efforts to require the recipient to honor this Privacy Policy (or provide notice of material changes).
  • With your consent. We may disclose information for any other purpose you expressly consent to.
8. Cookies and Analytics; Your Choices

8.1 Cookies and similar technologies. Cookies are small text files placed on your device when you visit a website. We may use cookies and similar technologies for functional purposes (to make the Website work), for security, and for analytics. Some cookies may be placed by third parties that provide services to us. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. If you remove or reject cookies, some features may not work as intended.

8.2 Your cookie choices. When you first visit our website (and periodically thereafter), you will be presented with a cookie banner that provides the following options:

  • Accept all: If you click “Accept all,” we will place and/or read all cookies and similar technologies described in our Cookie Policy, including non-essential cookies (e.g., analytics, functional preference, and advertising cookies).
  • Reject all: If you click “Reject all,” we will not place and/or read non-essential cookies and similar technologies. We will only use cookies that are strictly necessary for the Website to work or to provide a service you request.
  • Cookie settings: If you click “Cookie settings,” you can choose which categories of non-essential cookies to allow and then save your preferences.

For more information regarding the types of cookies enabled on the Website, please see our Cookie Policy. By continuing to browse our Website, you consent to the use of these cookies as outlined in this Privacy Policy.

8.3 Analytics. We may use analytics services to help us understand how users interact with the Website. These services may collect information such as your IP address, device identifiers, and usage events, and may use cookies or similar technologies. We use analytics information to operate, maintain, and improve the Website.

Interwell may use Google Analytics cookies and a session cookie as the sources for its website usage data. For further information on how Google Analytics collects and uses data, see www.google.com/policies/privacy/partners/. The session cookie only stores a temporary random value session ID number. You may opt-out of receiving cookies or delete any prior cookies by changing your specific internet browser settings. Otherwise, you agree to cookies being used by continuing to use our Website in accordance with your cookie banner selections.

8.4 Marketing communications. If we send you promotional emails, you can opt out by following the unsubscribe instructions in those messages. Even if you opt out of promotional communications, we may continue to send non-promotional messages (e.g., account, security, or support messages).

9. Third Party Sites

Interwell may include or offer links to certain external resources, including websites, apps, or platforms unaffiliated with or not controlled by Interwell (“External Sites”). This Privacy Policy does not apply to External Sites and we are not responsible for the privacy policies or practices of External Sites or your use of the External Sites. Please read the policies and practices of External Sites before accessing or using them.

10. “Do Not Track” Signals

Some web browsers may transmit “do not track” signals to the websites with which the browser communicates. At this time, we do not respond to “do not track” signals.

11. Children’s Privacy

We do not knowingly collect the Personal Information of consumers under eighteen (18) years of age. If you are under eighteen (18) years of age, please do not attempt to send us any Personal Information. If you have reason to believe that we have collected any Personal Information from someone under eighteen (18) years of age, please have the child’s parent or guardian contact us as directed in Section 15 below.

12. International Visitors

This Website is intended for use in the United States. We do not target, market to, or offer our products or services to consumers outside of the United States. If you access the Website from outside the United States, you understand that your information may be transferred to, processed in, and stored in the United States or other areas where we or our service providers operate, and that data protection laws may differ from those in your area.

13. How We Protect and Retain the Information that We Collect

The security of your information is important to us. We have implemented commercially reasonable security measures that are designed to protect your information from unauthorized access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our efforts, no measures are perfect or 100% secure.

Interwell will retain your Personal Information for as long as needed to fulfill the purposes outlined in this Privacy Policy and the Terms of Use, unless a longer retention period is required or permitted by law. When your Personal Information is no longer required by Interwell, we will delete your Personal Information.

14. Changes to Our Privacy Policy

We may update this Privacy Policy from time to time, without advance notice. The “Last Updated” date at the top of this Privacy Policy indicates when it was last revised. Your continued use of the Website after the effective date of an updated Privacy Policy constitutes your acceptance of the changes. Please review the Privacy Policy periodically for any changes or modifications.

15. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at privacy@interwellhealth.com or

Attn: Interwell Health
68 Harrison Ave #605 PMB 39516
Boston, Massachusetts 02111