PRIVACY POLICY

Virgin HealthMiles, Inc. ("Virgin HealthMiles") is committed to protecting your privacy. This Privacy Policy explains what we can and cannot do with the information we collect about you and what steps you can take to protect that information.

To enable us to provide quality service to you, we need to keep personal information about you, including, but not limited to, information about your health, fitness and related activities, your email address, your credit card number and other demographic information ("Personal Information" ). This information will be collected through the Virgin HealthMiles Health Zone kiosks as well as information you provide through our website. In addition, we will collect non-personal information related to your use of our website through the Internet (e.g., cookies).

The Personal Information we collect will be used to track your fitness progress, determine your points for the reward program, as well as to provide you with information that you may find helpful. You understand that in order to provide benefits, rewards, and otherwise maintain the HealthMiles program, HealthMiles may need to share this personal information with companies involved in the HealthMiles program, and you hereby consent and authorize HealthMiles to share such information as it deems necessary or appropriate. Virgin HealthMiles staff may also have access to your Personal Information so they may contact you regarding your participation in a Virgin HealthMiles program.

You will have access to some of your Personal Information on the kiosks and all your Personal Information via our website. If any of your Personal Information is inaccurate or outdated, you can correct it at any time on the website.

Virgin HealthMiles will de-identify your information and disclose it in combination with others' information in such a way that no one could trace the information back to you directly (i.e. anonymous, aggregated data). This anonymous, aggregated data may be shared with other organizations for research purposes. You are welcome to request the names of such organizations from us.

If you became a member of Virgin HealthMiles through your employer's participation in one of our programs, then we will supply your employer with the same anonymous, aggregated data mentioned above. Your employer will not be able to trace such information directly back to your identity. Your employer may use this information to provide additional benefits, programs and services.

Your Personal Information will not be sold, divulged, or made available to any third party without your permission except as set forth in this policy or when Virgin HealthMiles has a legal duty to make the information available to a legally authorized party. However, Virgin HealthMiles may sell your de-identified Personal Information to third parties in the form of anonymous, aggregated data. In the event that Virgin HealthMiles is obligated to disclose your Personal Information pursuant to a legal or administrative proceeding you will be notified of the order requiring such disclosure.

Should you decide to end your Virgin HealthMiles membership, we will de-identify your Personal Information.

Virgin HealthMiles has taken responsible measures to ensure that no unauthorized person can obtain access to your personal information. Among the security measures taken is a login process requiring a password and username that you select and a firewall protecting our hosting server. Virgin HealthMiles will retain your password and username as part of your Personal Information, but will not share this information with anyone. Please be advised that you are responsible for keeping your password and user name confidential and secure from unauthorized persons.

You give permission that if there is a change of ownership of Virgin HealthMiles in the future, your Personal Information can be transferred to the new owner, provided that the new owner will not, in any way, limit your rights and obligations regarding the information as set out in this Privacy Policy, to the extent such information has been collected in such transfer.

© Virgin HealthMiles, Inc., 2008 All Rights Reserved