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Privacy Policy

SENSEMED INC.

WEBSITE PRIVACY POLICY

Last Updated: March 10.2023

Welcome to SenseMed! This Privacy Policy (“Policy”) explains how information about you (“you”, “your” or “User” refers to the individual that visits or uses our Website) is collected, used, and disclosed by SenseMed Inc. (doing business as “SenseMed”), and its affiliates (“SenseMed,” “we,” “us,” or “our”).

Please review this Privacy Policy as it governs your use of the Website (“Website”) and limits our liability to you. For further information on policies governing the use of our Website, please visit our Terms of Service. By accessing or using our Website, you agree to this Privacy Policy. Failure by us to exercise or enforce any right or provision of this Privacy Policy shall not constitute a waiver of such right or provision. We reserve the right, at our sole discretion, to update, change or replace any part of this Privacy Policy by posting updates and changes to our website. If we make changes, we will notify you by revising the date at the top of the Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an electronic notification). It is your responsibility to check our Website periodically for changes. Your continued use of or access to our Website following the posting of any changes to this Privacy Policy constitutes acceptance of those changes. If you do not agree with this Privacy Policy, you are not authorized to access or use the Website for any purpose.

All other terms not defined herein will have the meanings set forth in the SenseMed Terms of Service.

1. PURPOSE AND SCOPE

This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt-out of the use of, or correct or change, such information. This Privacy Policy also applies to information we collect when you use our website, or when you otherwise interact with us which includes but is not limited to: (1) personal Information that is processed by us in the course of our business, including on our Website and (2) other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of SenseMed). All individuals whose responsibilities include the Processing of Personal Information on behalf of SenseMed are expected to protect that data by adherence to this Privacy Policy.

This Privacy Policy is incorporated into and made a part of the website terms of service. Please review these terms of service because they govern your use of the website Services and limit our liability to you. By using our Services, you agree that we may treat your information in the ways we describe in this Privacy Policy. If you do not agree

with any term of this Privacy Policy or the Terms of Service, you may not use our Services.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an electronic notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

For more information regarding our technology platform policies, please also visit our website privacy policies https://sensemed.health.

2. COLLECTION OF INFORMATION

When you visit our Website, SenseMed receives and may collect certain types of information depending on the nature of the relationship you have with us and the requirements of applicable law. SenseMed may collect Information regarding its current, prospective, and former patients, as well as its Website Users (collectively “Individuals”). For example, we may collect information when you review educational materials on SenseMed’s webpage, request Services, or otherwise communicate with us. The types of information we may collect from you include:

  • Personal Information: We may ask to collect personal information that you provide directly to us. Personal information includes information that identifies you as an individual or relates to an identifiable person, which may include, for example, your name, email address, login credentials in combination with a password, phone number, and date of Personal information does not include publicly available information which is lawfully made available to the general public from federal, state, or local governments. We may also collect anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests, and favorites.
  • Information Submitted Via Services: You agree that SenseMed is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or We will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (1) you grant us permission to do so; (2) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (3) we are required to do so by law.
  • Protected Health Information: Our third party EHR may collect Protected Health Information (PHI) from you if you sign up for Services. Protected Health Information includes all “individually identifiable health information” held or

transmitted by a covered entity or its business associate, in any form or media, whether electronic, paper, or oral. Individually identifiable health information is information, including demographic data, that relates to: the individual’s past, present or future physical or mental health or condition; the provision of health care to the individual, or; the past, present, or future payment for the provision of health care to the individual; and that identifies the individual or for which there is a reasonable basis to believe it can be used to identify the individual. Individually identifiable health information includes common identifiers such as name, address, birth date, and Social Security Number. SenseMed will not request PHI from you unless you request Services.

  • Device-Specific Information: Information about your computer’s hardware and software may be automatically collected by this Website. This information can include your IP address, browser type, domain names, access times, and the page you visited before navigating to our This information is used for the operation of the Website, to maintain the quality of the Website, and to provide general statistics regarding the use of this Website.
  • Transaction Information: We may collect and store limited payment information from you, such as payment method and payment card information such as account number, credit or debit card number, in combination with any required security code access code, password, or other information that would permit access to a financial account.
  • Information About Others: This may include information such as your emergency contacts, caregivers, or any dependents under your care.
  • Social Media Information: Information you make available to us on social media platforms (such as by clicking on a social media icon listed on our Website, or by entering comments into the blog posts where enabled), including your account ID, username, or other information included in your posts.
  • Tracking Technologies: Our Website may use various technologies to collect information, including “cookies,” “log data,” “web beacons,” “tags,” and “pixels.”

SenseMed may place a unique cookie or other tracking technology on your browser. Our cookies collect general information that enhances our ability to serve you, improves your use of our Website, communicates special offers and featured items, and helps us respond to your questions and suggestions. For more information about cookies and other technologies. or how to disable them, please see “Tracking Technologies” and “Your Choices” below.

However, the use of cookies by third-party web analytics partners is not covered by our Privacy Policy. We do not have access or control over these cookies.

  • Other Information You Choose to Provide: We collect the information you provide when you participate in a survey, promotion, or interactive area of the

Website (such as using our messaging features or posting a review) or when you request technical, compliance, or customer support.

  • Usage Information: We automatically collect information about your activity on our Website. Information, such as, how you interact with the Website while using the
  • Mobile Device Information: SenseMed uses a third party EHR servicer to enable the ability to upload PHI. During the collection of this data, information about the mobile device you use to access or use our Website, including the hardware model, operating system and version, unique device identifiers, mobile network information, and information about your use of our Website may be automatically collected. With your consent, certain native applications on your device (such as your device’s phonebook applications)may also be accessed to collect information to facilitate your use of certain features of the Website. For more information about how you can control the collection of location information and/or our access to other applications on your device, please see “Your Choices”

o If you provide authorization, contact information from your address book on your mobile device or computer (“Contacts”) will be accessed. Your Contacts may be used in order to identify other Subscribers that you may know and to provide you or other Subscribers with recommendations for other services or for an invitation to join a video chat session. With your authorization, your Contacts may also be used to invite them to sign up for SenseMed’sservices.

  • In addition, if you use your phone number to verify your account, we may use your phone number to suggest to you other services or recommendations based on the information uploaded.
  • Note, your phone number,email, or phone numbers of third parties in your Contacts will not be shared with anyone else.
  • Log Information: Information about your use of the Website may be collected, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Website.
  • Information We Collect from Other Sources: We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as an App Store or SNS, we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the This supplemental information

allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services. We may also collect information about you when you post content to our pages or feeds on third-party social media sites.

NOTE: There may be inadvertent sharing of PHI when an individual enters their name, email, or other Personal Information on blog posts or in the “Contact Us” form. “Personal Information” does not include information about an individual that has been made publicly available by a federal, state, or local government entity. “Personal Information” does not include information that is encrypted, secured, or modified by any other method or technology that removes elements that personally identify an individual or that otherwise renders the information unusable. “Publicly Available” does not mean biometric information collected by a business about a consumer without the consumer’s knowledge. Information is not “publicly available” if that data is used for a purpose that is not compatible with the purpose for which the data is maintained and made available in the government records or for which it is publicly maintained.

3. USE OF INFORMATION

Our primary goals in collecting Personal Information are to provide and improve our Services, to administer your use of the Services (including your account, if you are a User), and to enable you to enjoy and easily navigate our Services. We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:

  • To Provide Products, Services, or Information Requested: We may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
  • generally manage Individual information and accounts;
  • respond to questions, comments, and other requests;
  • provide access to certain areas, functionalities, and features of our Services;
  • contact you to answer requests for customer support or technical support; or
  • allow you to register for events.
  • Administrative Purposes: We may use Personal Information about you for its administrative purposes, including to:
  • measure interest in our Services;
  • develop new products and Services;
  • ensure internal quality control;
  • verify Individual identity;
  • communicate about Individual accounts and activities on our Services and systems, and, in our discretion, changes to any SenseMed policy;
  • send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
  • prevent potentially prohibited or illegal activities; or
  • enforce our
  • Marketing Our Products and Services: We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, or email, as permitted by applicable Such uses include:
  • to tailor content, advertisements, and offers;
  • to notify you about offers, products, and services that may be of interest to you;
  • to provide Services to you and our sponsors;
  • for other purposes disclosed at the time that Individuals provide Personal Information; or
  • otherwise with your consent.

You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 10 below.

  • Research and Development: We may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, we may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products and services we

The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.

  • Direct Mail, Email and Outbound Marketing: Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, push notifications or text messages from us with information on our or our business partners’ products and services or upcoming special offers/events we believe may be of
  • Services via Mobile and Other Devices: SenseMed’s third party EHR servicer provides Services that are specifically designed to be compatible and used on mobile and other devices. The third party may collect certain information that your mobile or other device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile and desktop versions may require that Users log in with an account. In such cases, information about use of mobile and desktop versions may be associated with In addition, individuals may be enabled with the ability to download an application, widget, or other tools that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to enable Individuals to access accounts and to enable the ability to track use of these tools. Some of these tools may also enable Users to email reports and other information from the tool. Personal or non-identifiable information transmitted may be used to enhance these tools and/or to develop new tools for quality improvement and as otherwise described in this Privacy Policy or in other notices we provide.
  • Anonymous and Aggregated Information Use: We may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within SenseMed and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
  • Other Uses: We may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud

protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

4. SHARING OF INFORMATION

SenseMed may share aggregated or de-identified information as a part of an effort to longitudinally assess the benefits of its Products and Services. This information cannot reasonably be used to identify you. We may also share information about you as follows or as otherwise described in this Privacy Policy:

  • Vendors and Service Providers: We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (1) provision of IT and related services; (2) provision of information and services you have requested; (3) payment processing; (4) customer service activities; and (5) in connection with the provision of the Services. We have executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
  • Business Partners: We may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to In such cases, our business partner’s name will appear, along with us. We require our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which we provided them.
  • Disclosures to Protect Us or Others: We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (1) comply with law enforcement or national security requests and legal process, such as a court order or subpoena;

(2) respond to your requests; (3) protect yours’, ours’ or others’ rights, property, or safety; (4) to enforce our policies or contracts; (5) to collect amounts owed to us; (6) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (7) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

In addition, from time to time, server logs may be reviewed for security purposes

– e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in

order that they may identify Users in connection with their investigation of the unauthorized activities.

  • Merger, Sale, or Other Asset Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such an event, we will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was
  • Individuals involved in your care: We may share Personal Information with individuals involved in your care, such as parents, guardians, emergency contacts, and other caregivers who you designate to receive access to your account;
  • Breach of Terms; Protection: if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, and safety of SenseMed, its affiliated entities, or others;
  • Affiliates: we may share your Personal Information between and among SenseMed and its affiliates, its current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
  • Consent: we may share your Personal Information with your consent or at your

5. CHILDREN’S INFORMATION

SenseMed’s Services are not directed to persons under the age of eighteen (18) and does not knowingly collect any information from persons under the age of thirteen (13), or from persons between the age of thirteen (13) and eighteen (18) without appropriate authorization. We urge parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you are a parent or guardian of an individual under the age of eighteen (18) and believe your child has disclosed personal information to SenseMed without your authorization, please contact us at [email protected]. If we learn that we have collected any Personal Information from children under eighteen (18) without verifiable parental consent or proper authorization, we will promptly take steps to delete such information and terminate the child’s account.

6. TESTIMONIALS, REVIEWS, AND CONTESTS

Occasionally, SenseMed may run sweepstakes and contests. We ask those who enter in the sweepstakes or contests to provide contact information (e.g., an e-mail address). If you participate in a sweepstakes or contest, your contact information may be used to reach you about the sweepstakes or contest, and for other promotional, marketing and business purposes. In accordance with the laws of your jurisdiction, as a participant you will have the opportunity to opt-out of any communications that are not related to awarding prizes.

SenseMed cannot guarantee that the information discussed in testimonials, reviews, during contests, and during sweepstakes will remain private as SenseMed cannot control or predict the disclosure of your information by others outside of the Website. You should think carefully before sharing any Personal Information, or any other information that you intend to keep private.

7. THIRD-PARTY WEBSITES, SOCIAL MEDIA PLATFORMS, AND SOFTWARE DEVELOPMENT KITS

Our Website may contain links to other websites and other websites may reference or link to our Site or other Services. We use Third-Party software development kits (“SDKs”), such as the Facebook SDK, as part of the functionality of our Services (e.g., to suggest friends from Facebook or other platforms for your addition to your app contact list). Third-Party SDKs may allow Third Parties including advertisers to collect your personal information to provide content that is more relevant to you. You may opt out of tracking by accessing the Third Party’s settings on your device and disabling the tracking function for that Third Party or by choosing not to enable such SDKs in the settings for our Services.

These other domains, websites and services are not controlled by us, and we do not endorse or make any representations about Third-Party websites or social media platforms. We encourage our Users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting or connecting to these other websites, services or applications is at your own risk.

Our Services may contain private messaging features, links and interactive features with various social media platforms (e.g., widgets to suggest friends from Facebook or other platforms to add to your contacts). If you already use these platforms, their cookies may be set on your device when using our Services. You should be aware that Personal Information which you voluntarily include and transmit online in a chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such

services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

8. PERSONAL INFORMATION SECURITY AND STORAGE

SenseMed takes reasonable measures to help protect information about you from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction.

Safeguards Provided

We implement and maintain organizational, technical, and administrative security measures designed to safeguard the information we process within our organization against unauthorized access, destruction, loss, alteration, or misuse. These measures are aimed at providing ongoing integrity and confidentiality for your personal information. We evaluate and update these measures on an ongoing basis. Your information is only accessible to personnel who need access to the information to perform their duties. However, while we take precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.

Information Retention

We retain your personal information for as long as we have a relationship with you, subject to applicable law and regulation. When deciding how long to keep your personal information, we consider our legal and regulatory obligations and internal personal information management policies. For example, we retain records to investigate or defend against potential legal claims or where required by law. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

9. TRACKING TECHNOLOGIES

We, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, log data and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “devic e”) that allow us to record certain pieces of information whenever you visit or interact with our Services, and to recognize you across devices.

  • Cookies: “Cookies” are small data files that are placed on your device’s hard disk when you access our Services. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services, to better understand how you interact with our Services, to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent cookies, session Cookies are deleted when you log off from the

Services. Most Internet browsers automatically accept Cookies. If you do not want cookies from SenseMed or other services, you can change your settings to stop accepting Cookies or to prompt you before accepting a cookie from the services you visit. However, some Services may not function properly if you disable Cookies.

  • Pixel Tags/Web Beacons: A pixel tag (also known as a web beacon, web bug, or clearGIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our Unlike Cookies, which are stored on the User’s hard drive, pixel tags are typically embedded invisibly on web pages (or in an email).
  • Social Media Widgets: Our Services include social media features such as, integration of Facebook friends as suggested app contacts, and sharing features native to iOS and Android devices (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting through our Services, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly through our Services. Your interactions with these features are governed by the privacy policy of the company providing it.
  • Analytics: We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit http://www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
  • Log Data: Our servers automatically record information (“Log Data”) created by your use of the Services. Log Data may include information such as your IP address, browser type, operating system, location, your mobile carrier, device and application IDs, the Users with whom you video chat, access date and time spent on features of the Services and other statistics and Cookie information. We receive Log Data when you interact with our Services, for example, when you visit our websites, sign into our Services, participate in a video chat session, or interact with email or push notifications. SenseMed uses Log Data to provide our Services and to measure, customize, and improve For instance, SenseMed may provide you with recommendations based on your use of the Services using location Information. In addition to profile information, if you choose to enable your computer or mobile device to send location information, information about your location may be collected and stored by converting your

IP address into a rough geolocation or by accessing your computer’s or mobile device’s GPS coordinates or coarse location. Information about your location may be used and stored to provide features of our Services, such as providing location specific filters, and to improve and customize the Services with Content that has been tagged near your location. If you do not want us to collect location information, you may disable that feature on your computer or mobile device.

Our uses of such Technologies fall into the following general categories:

  • Operationally Necessary: We may use Cookies, pixel tags, or other similar Technologies that are necessary to the operation of our Site, Services, applications, and tools. This includes Technologies that allow you access to our Site, Services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;
  • Performance Related: We may use Cookies, pixel tags, or other similar Technologies to assess the performance of our Site, Services, applications and tools, including as part of our analytic practices to help us understand how our visitors use our Services, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our content, applications, services, or tools;
  • Functionality Related: We may use Cookies, pixel tags, or other similar Technologies that allow us to offer you enhanced functionality when accessing or using our Site, Services, applications, or tools. This may include identifying you when you sign into our Services or keeping track of your specific preferences, interests, or past items viewed so that we may enhance the presentation of content on our Services;

If you would like to opt-out of the Technologies we employ on our sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

10. YOUR CHOICES

SenseMed shall use all reasonable endeavors to give you free access to your personal information in an appropriate scope.

Account Information

You may update, correct, or delete information about you at any time by logging into your online account or emailing us at [email protected]. If you wish to delete or deactivate your account you may do so via your account; however, please note that we may retain certain information as required by law or for legitimate business

purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Opt-Out

You may opt-out of having information used for purposes not directly related to Services by emailing a clear notice to [email protected]. By using the Website or Services, you affirmatively consent to receiving SenseMed and its affiliates’ promotional and marketing material. Should you opt-out of having information used for purposes directly related to Services, it may prevent you from receiving Services.

Notice Concerning Do Not Track

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third-party purposes, and that is why we provide the opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals.

11. CALIFORNIA PRIVACY RIGHTS

If you are a resident of California, this section provides additional details about the personal information we collect about you, and your rights under the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”).

Subject to certain limitations, the CCPA and CPRA provide you the right to request:

  • That we provide you access to details on the categories or specific pieces of personal information we collect and/or sell (including how we use and disclose this information, to whom we may sell it);
  • That we delete any of your personal information;
  • That we correct any inaccuracies in your personal information;
  • To opt out of any “sale” or “sharing” of your personal information that may occur, including sensitive personal information; and
  • To not be discriminated against for exercising any of the above

SenseMed does not sell your personal information within the normal meaning of the word, but we do use cookies, pixels, and similar technology to improve your user experience. Under the CPRA’s broad definition of “sell”, this could be considered a sale. If you wish to opt out of this activity, you may do so by following the “Do Not Sell” instructions below. We do not sell the personal information of minors who are under thirteen (13) years old, or who are at least thirteen (13) years old and less than sixteen

(16) years old. Data will not be shared with any third parties for their marketing purposes.

If you opt-out of the sale of your personal information, we will wait at least twelve (12) months before asking you if we may sell your personal information. You have the right to

opt-in to the sale of your personal information after you have opted out. If you would like to opt-in t th sal o you persona information, yo ca emai us at [email protected]. We will not discriminate against you for exercising your rights under the CPRA.

You may submit a request to access or delete your personal information by emailing [email protected]. Before we approve your request(s), we may ask you to verify certain Personal Information that we have on file. Please note that requests pursuant to the CPRA are limited to non-medical personal information as the CPRA does not apply to health information governed by the Confidentiality of Medical Information Act (CMIA).

You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent, you or your authorized agent must provide written proof to [email protected] that the agent has a valid power of attorney pursuant to California Probate Code sections 4000-4465 or by submitting a signed, notarized authorization form.

The list below summarizes the categories of personal information categories, as identified by the CPRA that SenseMed has collected in the last twelve months, and the third parties with whom we may share your information for a business purpose as described in the Section above entitled “Sharing of Information.” The sources from which we collect personal information can be found in the Section above entitled “Collection of Information.” For purposes of this Section only, “personal information” has the meaning given in the CPRA, but excludes information exempted from the scope of the CPRA, such as health information that is exempt from the CPRA, as noted above.

Business or Commercial Purposes for Which SenseMed May Have Collected or Sold Personal Information in the Preceding twelve (12) Months

  • Performing services, including maintaining or servicing accounts, providing Subscriber service, verifying Subscriber information, processing payments, and providing marketing services;
  • Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, auditing compliance;
  • Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Undertaking internal research for technological development and demonstration; and
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to

improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

Categories of Sources from Which SenseMed Has Collected Personal Information About Users

  • From client or customer directly
  • Government Entities
  • Social networks

Categories of Personal Information Sold

  • Internet or other electronic network activity (e.g., “cookies” or other tracking tags)
  • Identifiers (e.g., name, mailing address, email address, phone number, credit/debit card number)

Categories of Third Parties to Whom Personal Information was Sold

  • Affiliate Partners

Categories of Personal Information Disclosed for a Business Purpose

  • Identifiers (e.g., name, mailing address, email address, phone number, credit/debit card number)
  • Commercial information (e.g., Services purchased, Service purchase history)
  • Geolocation data (e.g., latitude or longitude)

Categories of third parties to whom Personal Information has been disclosed for a business purpose

  • Internet Service Providers
  • Government Entities
  • Operating Systems and Platforms
  • Social Networks

“Shine the Light” Law (California Civil Code § 1798.83)

California law permits California residents to request certain details about how their information is disclosed to third parties for third-party direct marketing purposes. We do not share your information with third parties for their direct marketing purposes.

Privacy Rights for California Minors in the Digital World Act

If you are a California resident under the age of eighteen (18) and are a user of the Website then you may request that we remove the information you posted. Please be aware that applicable state or federal law may prevent SenseMed from deleting

certain categories of information such as health information. Requests for removals should include a description of the specific posted information (including information that will allow us to confirm it was created and posted by you) and should be sent to [email protected].

Do Not Track

Certain web and mobile browsers allow you to send a signal to inform websites that you do not want your online activities tracked. At this time, we do not currently respond to “Do Not Track” signals or similar mechanisms.

Do Not Sell

You may opt-out of having your information shared. Please note that if you opt out, SenseMed will attempt to block further sharing of these identifiers with the third parties we engage by placing a cookie on your browser to automatically prevent the sharing from happening when you visit our website. You will need to submit a separate opt-out of sale request on each device and browser you use to visit our website. After you submit an opt-out of sale request, you may still see advertising regarding our products and services. This advertising may be general audience advertising or may be delivered by service providers in ways that do not involve sales of your personal information.

If you would like to opt out, please contact us at [email protected]. If you have submitted an opt-out of sale request and would like to opt back in, also contact us at [email protected].

12. INTERNATIONAL TRANSFERS AND PRIVACY RIGHTS

Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal information, to the United States and process it there. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use our Website or Services.

You have the right to access the personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the “Contact Us” information located in Section 14 below.

13. HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA)

To the extent that any of the information we collect on our Website constitutes Protected Health Information (“PHI”) under HIPAA, we will comply with the requirements of HIPAA and its implementing regulations. Please see our Notice of Privacy Practices for further information. The Notice of Privacy Practices will apply with respect to the use and disclosure of PHI to the extent that there is a difference between this Privacy Policy and our Notice of Privacy Practices.

14. CONTACT US

If you have any questions, comments, or complaints regarding this Privacy Policy please contact us.

If you would like to request access to, correction of, or deletion of any personal information that you have provided to us, please contact us using the information below. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.

SenseMed Inc. 330 Bridge Street
Greenport, New York 11944
Email: [email protected]