Teladoc Health Notice of Privacy Practices for US Employees’ Personal Information

Effective Date: 4/15/2024

1. Introduction

Teladoc respects your privacy and is committed to maintaining the confidentiality and security of your Personal Information.In furtherance of your employment relationship with Teladoc, we collect Personal Information responsibly and in accordancewith applicable data privacy laws, including but not limited to, California Privacy Rights Act (CPRA). For purposes of thisNotice, Personal Information is defined as: any information or set of information relating to you, including (a) all information that identifies you or could reasonably be used to identify you, and (b) all information that any Applicable Law treats as Personal Information.

The purpose of this Notice of Privacy Practices for US Employees’ Personal Information (“Notice”) is to provide notification to potential, former, and current full-time and part- time employees, volunteers, contractors, and interns (collectively referredto throughout this Notice as “you”, “your”, “their”, or “Employees”) as to how Teladoc Health, Inc. uses and discloses yourPersonal Information. For the purposes of this Notice, “Employee” also refers to consultants and contractors engaged by Teladoc, even though they are not otherwise employees.

It is important that you read and understand this Privacy Notice. If you have questions or do not understand it fully, please seek additional information by contacting the Privacy Officer at [email protected] or by contacting your HR Representative.

This Privacy Notice is not a contract and does not create any contract of employment or other rights or obligations.

2. Scope

Teladoc Health, Inc. is made up of different legal entities, including U.S. and international subsidiaries listed in Teladoc Health Subsidiaries and Affiliates. When we mention “Teladoc”, “we”, “us” or “our” in this Notice, we are referring to the relevant legal entity of Teladoc Health, Inc. that is responsible for processing your Personal Information as your employer.This Notice applies to how Teladoc collects and uses your Personal Information as part of your employment relationship with Teladoc.

To the extent that you use any of Teladoc’s suite of medical services, such as telehealth, chronic condition management, or expert medical services, or Teladoc’s websites, this Notice does not apply to the information that is collected during your use of those services. To avoid doubt, the information collected during your use of those services, if any, will not be accessed orused for employment purposes. Refer to the Notice of Privacy Practices that is applicable for the services you are using in order to understand what Personal Information is collected and processed by Teladoc during the course of your use of those services.

3. Categories of Personal Information We Collect

We may collect the following categories of Personal Information about you:

Category	Examples
Identifiers	Real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, telephone numbers, date of birth, other similar identifiers.
Categories of Personal Information described inSection 1798.80(e) of the California Civil Code	Name, signature, social security number, physical characteristics or description,address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, financial information, medical information, health insurance information.
Characteristics of protected classifications under California or federal law	Age, race, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancyor childbirth and related medical conditions), sexual orientation, veteran, or military status.
Categories of Sensitive Personal Information under California Privacy Rights Act (CPRA)	Social Security, driver’s license, state identification card, passport number, financial account information, precise geolocation, racial or ethnic origin, or health information
Biometric Information	Fingerprint, voice recording.
Internet or other electronic network activity information	Your access to and use of Teladoc’s communication systems, applications, and software including your access to and modification of the information contained therein (e.g. corporate, client, and member information). This includes your Teladoc email account, and applies whether you access such information, systems, applications, software, and communication systems through company issued equipment or your personal device. User logs and access control related information, including physical access to Teladoc’s premises. CCTV footage and other information obtained through electronic means such as swipe card records. Location information, including through GPS tracking technology on Teladoc-owned devices (e.g., laptops to locate and/or wipe lost or stolen laptops), or other devices owned by you which you use in connection with your employment with Teladoc. Browsing history, search history, and information regarding interaction with an Internet website, application, or advertisements on Teladoc-provided devices.
Geographic data	GPS tracking on Teladoc-provided devices as well as through swipe card records.
Audio, electronic, visual, thermal, olfactory, or similar information	Photograph, temperature, CCTV footage, voice recording.
Professional or employment-related information	Title(s), position description(s), working location(s), years of service, salary, work hours, vacation, and absences; copy of driving license (if relevant for your position); copy of passport or identity card, and information related to immigration and right-to-work (e.g., work permit / visa application information); travelling and travel expenses data; termination date and reason for termination. CV/resume details, employment history, and any information you provide to us on an application and during interviews, as well as information we gather from reference persons whose contact details you have provided to us, written or verbally, and background check reports. Information required for payroll purposes (e.g., bank account details, tax information); Information related to benefit entitlements and schemes such as insurance and stock options, e.g., details of participation and contributions made. Benefits information, compensation information. Emergency contact information, and names of dependents. Performance related information (e.g., assessments of your performance, objectives and goals, feedback, and tests results); information relating to misconduct, investigations, and disciplinary actions; attendance; qualifications and personal development information, and competence assessments; learning and development records, certificates, licenses, and vocational records; records of career and succession planning; ongoing background check reports and security data.
Education information	Degrees, schools attended, certificates, licenses, spoken languages, vocational records, and professional qualifications.
Inferences	Inferences drawn from any of the above types of information that may reflect your characteristics, behavior, intelligence, abilities, and aptitudes related to the purposes outlined in Section 4 below.
Personal Information that you provide directly to us either verbally or in writing.

4. Purposes for which Personal Information is Used

As an employer, Teladoc collects, uses, and discloses your Personal Information in connection with your working relationship with us and in order to comply with Teladoc’s legal obligations. We use, and may disclose to third parties who assist us with these functions, Personal Information for the following purposes:

Recruitment, interviewing, and vetting of candidates for employment;
Background checks for employment and client engagement services;
Performing ongoing sanction and exclusion checks, including those required by the Office of the Inspector General;
Onboarding and decisions about continued employment or engagement;
Managing and documenting your employment, attendance, and job performance
Providing you with equipment, training, and support to carry out your duties and responsibilities;
Payroll and other compensation;
Administering and managing compensation and benefits;
Organization management and administration, including staffing management, financial planning, internal audits, and other administration;
Administration of absences in accordance with company and statutory leave programs;
Traveling and expense reimbursement;
Responding to employment verification inquiries;
Communicating with you. This may include facilitating communications to and between employees and contractors, and communications with other bodies (e.g., regulatory authorities). This also includes use of yourphotograph on internal methods of communication including email communications, ID cards, and through other global employee development activities such as on the Teladoc Intranet, during town hall meetings, and department meetings;
External marketing activities, including marketing photos, brochures, website content, videos, social media posts, and other related marketing activities;
Complying with legal obligations, including responding to requests from government agencies;
Reporting to appropriate government entities, including tax authorities and other governmental and regulatory agencies;
Ensuring network and information security, including preventing unauthorized access to our computer and electronic communications systems and physical locations
Administering our applications, software, and systems;
• Preventing fraud, responding to legal process, and complying with federal, state, and local laws, as well as regulatory requirements;
Statistical, research, and analytical purposes to understand and improve worker satisfaction, improve products & services, and performance as necessary;
To support Teladoc Health’s Diversity, Equity & Inclusion (DEI) initiatives, which could include reviewing aggregate reporting to ensure equitable and inclusive practices, monitor trends and achieve organizational targets;
Any other purpose with your consent.

5. Your Rights Regarding Your Personal Information

You have the following rights regarding your Personal Information maintained by Teladoc:

Right to Know

You have the right to know about the Personal Information that the Teladoc collects about you. You can request that we disclose to you:

Categories of Personal Information that Teladoc has collected about you, disclosed about you for a business purpose, or sold;
Categories of sources from which the Personal Information is collected;
Categories of third parties with whom Teladoc shares or to whom Teladoc sells Personal Information;
The business or commercial purpose for collecting and selling Personal Information; and
Specific pieces of Personal Information that Teladoc has collected about you.