Privacy Policy

Last updated: August 2, 2025

Nutrible, Inc., doing business as ThriveLink (“ThriveLink,” “us,” or “we”), takes your privacy very seriously. We created this Privacy Policy to provide important information about our privacy practices for the services we offer through the ThriveLink website at https://mythrivelink.com (the “Website”). Our Services include application assistance for numerous programs (such as Medicaid, SNAP, and utility assistance) as well as related services like job application support and bank account setup (collectively, the “Services”). This Privacy Policy describes how we collect, protect, use, disclose, and store information collected through the Services.

BY DOWNLOADING, ACCESSING, OR USING THE WEBSITE OR SERVICES, AND/OR BY REGISTERING WITH US OR PROVIDING INFORMATION TO US IN CONNECTION WITH THE SERVICES, YOU ACCEPT THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY, AND YOU HEREBY CONSENT THAT WE WILL COLLECT, USE, AND SHARE YOUR INFORMATION AS SET FORTH IN THIS PRIVACY POLICY. IF YOU ARE REGISTERING AN ACCOUNT OR USING THE SERVICES ON BEHALF OF AN INDIVIDUAL OTHER THAN YOURSELF, YOU REPRESENT THAT YOU ARE AUTHORIZED TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S BEHALF.

Your use of the Services is also subject to our Terms of Service, which are available on our Website.

COLLECTION, USE, AND DISCLOSURE OF INFORMATION

What is Personal Information?

“Personal Information” is any information relating to a natural person who is, or can be, identified either directly or indirectly from such information. It includes details such as a user’s name, address, telephone number, email address, Internet activity (such as browsing history), or other information directly linked to that person. Personal Information that we collect also includes personal medical information that users provide to us through the Services. You are not legally required to provide Personal Information to us, but if you choose not to provide certain information, we may not be able to register you to use the Services or fulfill some aspects of the Services.

Information that We Collect

ThriveLink collects Personal Information from users (or their legal guardians) when they register for and use the Services. You don’t have to use the Website and Services, but if you do, you acknowledge that ThriveLink collects and uses your Personal Information for the legitimate interests and purposes described in this Privacy Policy. ThriveLink collects the following types of Personal Information that you provide to us:

  • Basic registration information: for example, name, contact information, and language preference;

  • Financial-related information: such as income or other financial details needed for program applications;

  • Demographic information: such as your date of birth, citizenship status, and household information;

  • Correspondence records: including records and copies of your communications with us (email addresses, phone calls, etc.) if you contact us; and

  • Transactional information: details of any transactions or interactions you carry out through our Website or Services.

In addition, from time to time, we may use or augment the Personal Information we have about you with information obtained from other sources, such as your treating providers, your health plan, government agencies, and other third parties.

In addition to collecting Personal Information that you provide to us, we may automatically collect certain information when you access the Website. This can include your IP address, browser type, device information, operating system, and other similar details. (IP addresses are identification numbers for the location of your computer or network on the Internet. Log files record the traffic to and from a server.) ThriveLink servers log IP addresses for systems administration and troubleshooting purposes. We track page hits in aggregate to gauge the popularity of pages on our Website, and we use that information to improve the quality of our Services. We may also use, or allow third parties to use, web beacons on our Website to monitor the effectiveness of certain communications or features. Web beacons are small graphic images on web pages or in email messages that allow us or third parties to determine whether you have visited a particular page or opened an email. Web beacons collect information such as the IP address of the device that accessed the beacon, the URL of the page where the beacon is located, and the time the beacon was viewed. Web beacons may be linked to your Personal Information. We may also use third-party tools, services, or email communications (which can include cookies, web beacons, or similar technology) to deliver surveys or additional Services to you, and these tools may collect information about your visits to our Website in order to present content that may be of interest to you.

How We May Use Personal Information

We, and our third-party service providers, may use Personal Information in order to:

  • Provide and improve our Services: For example, to respond to your inquiries and fulfill the purposes for which the information was provided; to assist with your applications or requests; and to personalize your experience on the Website.

  • Communicate with third parties on your behalf: We may communicate with your health plan, the state Medicaid agency, or your health care providers regarding the status of your Medicaid eligibility and/or enrollment (or similar programs you ask us to help with).

  • Send administrative information: We will send you information regarding the Services – for example, confirmations, technical notices, updates, security alerts, or changes to our terms, conditions, and policies.

  • Send marketing communications: We may send you marketing or promotional communications that we believe may be of interest to you. You can opt out of these communications as described in those messages.

  • Further our business purposes: This includes activities such as quality assessment, data analysis, audits, developing new products or features, enhancing the Website, and improving our Services. We also analyze usage trends (for example, to inform members of the ThriveLink community which aspects of the Services might be most useful to them) and determine the effectiveness of our promotional campaigns; and

  • Act under certain circumstances: We may act as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process or regulatory requirements; (c) to respond to requests from public or government authorities; (d) to enforce our Terms of Service; (e) to protect our operations or those of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; (g) under emergency circumstances, at our discretion, to notify emergency services or your family members, personal representative, or other individuals involved in your care of your location and condition; or (h) to allow us to pursue available remedies or limit the damages that we may sustain.

Our use of your Personal Information may also be subject to certain restrictions set forth in an agreement between us and a partner or provider (for example, if your health care provider or insurer has arranged for your use of our Services, our contract with them may limit how we can use your data in specific ways).

We may also use aggregate data or de-identified information (information that is not personally identifiable to you) for any legally permissible purpose without restriction. This kind of data does not identify individual users and may be used, for instance, to improve our Services or develop new offerings.

How Personal Information May Be Disclosed

We may disclose your Personal Information in the following ways or to the following parties, only as necessary and as permitted by law:

  • Service providers: To our trusted third-party service providers that perform services on our behalf, such as website hosting, data analysis, information technology and infrastructure, customer service, email delivery, auditing, and other similar services. These parties are contractually bound to safeguard your information and only use it for the purposes we specify.

  • Affiliates: To our corporate affiliates (entities under common ownership or control with ThriveLink) for the purposes described in this Privacy Policy, including for them to market their own products and services to you (if you have not opted out of such communications).

  • Marketing partners: To third parties, in order to permit them to send you marketing communications regarding our Services. (For example, if we partner with another organization on a program that you enroll in through ThriveLink, we might share your contact information with that partner to facilitate the program or allow them to reach out to you about related services.)

  • For treatment or program purposes: In certain cases, for other treatment, payment, or health-care-related purposes of your health care providers or health plan, if applicable (for instance, coordinating with your doctor or clinic to assist in your care, or with an agency to process your benefits application).

  • Business transactions: To a third party in the event of a reorganization, merger, sale, joint venture, assignment or other transfer of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings). If our company or Services are acquired or merged with another company, your information may be transferred to the successor entity under the same terms of this Privacy Policy.

  • Legal and safety purposes: To third parties as we believe to be necessary or appropriate: (a) under applicable law or regulation (including laws outside your country of residence); (b) to comply with legal process, court orders, or subpoenas; (c) to respond to requests from public or government authorities (including for meeting national security or law enforcement requirements); (d) to enforce our Terms of Service or other agreements; (e) to protect our operations or those of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you, or others; (g) under emergency circumstances, at our discretion, to notify emergency services or your family members, personal representative or other individuals involved in your care of your location and condition; or (h) to allow us to pursue available remedies or limit the damage we may sustain.

ThriveLink does not sell or rent Personal Information that we collect about you to any third party for any purpose. Accordingly, we do not offer a “opt-out” for the sale of Personal Information, since we do not engage in that practice.

We may, however, disclose to third parties aggregate or de-identified data (data that does not identify you personally) for legally permissible purposes without restriction. For example, we might share statistics about how many users applied for a certain benefit through our platform, as long as that information does not identify any individual.

All of the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties. (In other words, if you provide your phone number and consent to receive text messages from us, that consent information will not be disclosed to outside parties.)

COOKIES

A “cookie” is a small piece of information that a website can store on your computer or device and retrieve later. Cookies are commonly used to enhance your experience by remembering your preferences or login status. In the future, we may use cookies to improve the user experience of our Website. For example, a “session” cookie might track that you are logged in as you navigate the site (and would expire once you close your browser), while a “persistent” cookie could save your preferences so they are remembered for your next visit. You can adjust your web browser settings to reject or delete cookies if you prefer. However, please note that some cookies which are strictly necessary for site operation cannot be disabled without affecting the functionality of the site.

Some of our business partners (for example, analytics or service providers that help us deliver the Services) may use their own cookies on our Website. Although we do not have direct access to or control over the cookies that they set, this Privacy Policy governs the use of cookies by us and by those business partners when they are acting on our behalf on our Website. We recommend you review the privacy policies of any third-party services for more information on their cookie usage.

THIRD PARTIES

This Privacy Policy addresses only the use and disclosure of information by ThriveLink through the Services. It does not cover, and we are not responsible for, the privacy, information, or other practices of any third parties that we do not own or control. This includes third-party websites or services that may be linked through our Website, as well as the manufacturer of your device or software. For example, if our Website contains a link to another website, or if you navigate to ThriveLink from a social media platform, this Privacy Policy does not govern those external sites. We encourage you to review the privacy policies of any other websites, applications, or services you visit or use to understand how those parties collect and use your information.

HIPAA

ThriveLink may contract with health plans and health care providers to provide our Services to their members or patients. In such cases, ThriveLink may be regulated as a “business associate” under the Health Insurance Portability and Accountability Act (“HIPAA”). This means that when we handle protected health information (“PHI”) on behalf of those partners, we do so in compliance with HIPAA and the applicable business associate agreements. Any uses and disclosures of PHI that we collect or receive through these relationships will be governed by HIPAA as well as by our agreements with the health plan or provider, as applicable.

ThriveLink may require certain health-related information about you (which may be considered PHI) in order to provide you with the Services. As part of providing our Services, you and ThriveLink may need to transmit PHI to one another. You acknowledge and agree that ThriveLink may send Personal Information constituting PHI to you via phone, email, or text message, which are not secure methods of communication. These methods carry some risk (for example, emails and texts may not be encrypted, and phone calls could be overheard or intercepted). Please notify us before using our Services if you do not wish us to transmit or receive PHI through phone, email, or text, and we will work with you to arrange an alternative secure method of communication. (For instance, we may be able to use a secure messaging portal or another encrypted method if necessary.) You may also send PHI to ThriveLink through any secure chat or messaging functionality provided on our Website, which is designed to protect your privacy.

CHILDREN’S PRIVACY

ThriveLink is concerned about the safety and privacy of children online. We comply with the Children’s Online Privacy Protection Act of 1998 (“COPPA”) and related regulations, which establish U.S. federal law protecting the privacy of children under 13 using the internet. Our Website and Services are not intended for minors (individuals under the age of 18), and we do not knowingly allow children under 13 to use our Services without parental consent. If we learn that we have collected or received Personal Information from a child under 13 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our records. If you believe that a minor (including a child under 13) may have provided us Personal Information without proper consent, please contact us at wellness@mythrivelink.com so that we can take appropriate action.

SECURITY

We take reasonable physical, technical, and administrative measures to protect the Personal Information under our control from loss, misuse, unauthorized access, alteration, or destruction. These measures are designed to safeguard your data while it is in our possession. However, please understand that no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot ensure or warrant the absolute security of any information you transmit to us or that we store.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised or you suspect a data breach), please immediately notify us of the problem by contacting us as described in the “Contacting Us” section below. We will work with you to address your concerns and take any necessary steps to protect your information.

STORAGE OF DATA

We will retain your Personal Information only for as long as necessary to fulfill the purposes for which it was collected, or as required or permitted by law. This means we may keep your information for a certain period of time even after you stop using the Services, if it is needed for legal, accounting, or operational purposes. The length of time we retain data will vary depending on the nature of the information and the purposes for which it was collected. For example, information related to an application you submitted through ThriveLink may be kept for a period of years to comply with record-keeping laws or our contractual obligations. Once Personal Information is no longer needed, we will securely destroy or de-identify it in accordance with our data retention policies and applicable law.

UPDATES TO THIS PRIVACY POLICY

We may update or change this Privacy Policy from time to time. Any changes will become effective when we post the revised Privacy Policy on the Website. If we make material changes to how we collect or use Personal Information, we will take reasonable steps to notify you (for example, by posting a notice of the changes in a prominent area of our site or, if appropriate, by email). You can see when this Privacy Policy was last updated by checking the “Last updated” date at the top of this Policy. By continuing to use the Website or our Services after any changes become effective, you are agreeing to the revised Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices to ensure you understand how your information is being handled.

CONTACTING US

If you have any questions, concerns, or comments about this Privacy Policy or our privacy practices, please contact us by email at wellness@mythrivelink.com. We will do our best to address your inquiry promptly and thoroughly. Your privacy is important to us, and we welcome your feedback.