1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us In Short: We collect information that you provide to us. We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services (such as by posting messages in our online forums or entering competitions, contests or giveaways) or otherwise when you contact us. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following: Personal Information Provided by You. We collect names; phone numbers; email addresses; medical information; contact preferences; and other similar information. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information. Information collected through our App In Short: We collect information regarding your push notifications, when you use our App. If you use our App, we also collect the following information:

• Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

The information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes. Information collected from other sources In Short: We may collect limited data from public databases, marketing partners, and other outside sources. In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion.

Information collected from Google Fit In Short: We may collect limited data with the Google Fit application. In order to enhance our ability to provide better health care services; we access and utilize Google Fit data in a responsible and secure manner. We ensure proper collection, retrieval, and storage of user fitness activity data for the purpose of tracking a patient’s physical activity and presenting it to the user in the App. The fitness data we have access to are; steps count, distance walked/run, and obtain move minutes. Access Steps Count: This scope allows us to retrieve the number of steps taken by the user, which is a key metric for tracking their physical activity levels. Retrieve Distance Walked/Run: With this scope, we can access the distance the user has walked or run, providing insights into their overall movement patterns. Obtain Move Minutes: By utilizing this scope, we can gather the duration of active movement in minutes, Once the fitness activity data is retrieved from Google Fit, we securely store it in our own database to display trends over a period of time.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent. We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below. We use the information we collect or receive:

• Manage your health or patients’ health. We may use your information to manage your health, patients health, associated medical information, and associated activities made through the Services.
• To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
• For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
• In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with third parties, publish such aggregated information or make such aggregated information generally available. We may collect aggregated information through the Services, through cookies, and through other means described in this Privacy Policy. We will maintain and use de-identified information in anonymous or de-identified form and we will not attempt to re-identify the information, unless required by law.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. We may process or share your data that we hold based on the following legal basis:

• Consent: We may share your personal identifiable data to 3rd parties if you have given us specific consent to use your personal information for a specific purpose. However, your de-identifiable data (i.e. anonymized) may be shared with 3rd parties without your consent.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

4. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).No purpose in this notice will require us keeping your personal information for longer than 10 years. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

6. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age. We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected]

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information. California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. If you are under 18 years of age, reside in California, and have a registered account with a Service, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, certain rights and obligations apply regarding your personal information.

What categories of personal information do we collect?

We may collect or may have collected the following categories of personal information:

Category

A. Identifiers

Examples

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name

Collected‍

Yes

Category

B. Personal information categories listed in the California Customer Records statute

Examples

Name, contact information, education, employment, employment history and financial information

Collected‍

Yes

Category

C. Protected classification characteristics under California or federal law

Examples

Gender and date of birth

Collected‍

Yes

Category

D. Commercial information

Examples

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name

Collected‍

No

Category

E. Biometric information

Examples

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements

Collected‍

No

Category

F. Internet or other similar network activity

Examples

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements

Collected‍

No

Category

G. Geolocation data

Examples

Device location

Collected‍

No

Category

H. Audio, electronic, visual, thermal, olfactory, or similar information

Examples

Images and audio, video or call recordings created in connection with our business activities

Collected‍

No

Category

I. Professional or employment-related information

Examples

Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us

Collected‍

No

Category

J. Education Information

Examples

Student records and directory information

Collected‍

No

Category

K. Inferences drawn from other personal information

Examples

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

Collected‍

Yes

We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at [email protected], or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal identifiable information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.

Reya Health Inc has not disclosed or sold any personal identifiable information to third parties for a business or commercial purpose in the preceding twelve (12) months. Reya Health Inc will not sell personal information in the future belonging to website/app visitors, users and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data – Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

Right to be informed – Request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell your personal information to third parties;
• the categories of personal information that we sold or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
• the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• you may object to the processing of your personal identifiable data
• you may request correction of your personal identifiable data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
• you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• you may request to opt-out from future selling of your personal identifiable information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.

To exercise these rights, you can contact us by email at [email protected], or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

10. NOTICE OF PRIVACY PRACTICES

In Short: Compliant with HIPAA we publish this notice of privacy practices Company is dedicated to maintaining the privacy of your protected health information (“PHI”). PHI is information about you that may be used to identify you (such as your name, social security number or address), and that relates to (a) your past, present or future physical or mental health or condition, (b) the provision of healthcare to you, or (c) your past, present, or future payment for the provision of healthcare. In conducting its business, Company may receive and create records containing your PHI. Company is required by law to maintain the privacy of your PHI and to provide you with notice of its legal duties and privacy practices with respect to your PHI.

Company must abide by the terms of this Notice while it is in effect. This Notice is in effect from the date noted above until Company replaces it. Company reserves the right to change the terms of this Notice at any time, as long as the changes are in compliance with applicable law. If Company changes the terms of this Notice, the new terms will apply to all PHI that it maintains, including PHI that was created or received before such changes were made. If Company changes this Notice, it will post the new Notice on its Platform and will make the new Notice available upon request.

Uses and Disclosures of PHI.

Company may use and disclose your PHI in the following ways:

1. Treatment, Payment and Healthcare Operations.Company is permitted to use and disclose your PHI for purposes of (a) treatment, (b) payment and (c) healthcare operations. For example:

• Treatment.Company may disclose your PHI to a physician in connection with the provision of treatment to you.
• Payment.Company may use and disclose your PHI to your health insurer or health plan in connection with the processing and payment of claims and other charges.
• Healthcare Operations.Company may use and disclose your PHI in connection with its healthcare operations, such as providing customer services and conducting quality review assessments. Company may engage third parties to provide various services for the Company. If any such third party must have access to your PHI in order to perform its services, Company will require that third party to enter an agreement that binds the third party to the use and disclosure restrictions outlined in this Notice.

2.Authorization.Company is permitted to use and disclose your PHI upon your written authorization, to the extent such use or disclosure is consistent with your authorization. You may revoke any such authorization at any time.

3. As Required by Law.Company is permitted to use and disclose your PHI upon your written authorization, to the extent such use or disclosure is consistent with your authorization. You may revoke any such authorization at any time.

4. Special Circumstances.The following categories describe unique circumstances in which Company may use or disclose your PHI:

• Public Health Activities. Company may disclose your PHI to public health authorities or other governmental authorities for purposes including preventing and controlling disease, reporting child abuse or neglect, reporting domestic violence, and reporting to the Food and Drug Administration regarding the quality, safety and effectiveness of a regulated product or activity. Company may, in certain circumstances disclose PHI to persons who have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition.
• Workers’ Compensation.Company may disclose your PHI as authorized by, and to the extent necessary to comply with, workers’ compensation programs and other similar programs relating to work-related illnesses or injuries.
• Health Oversight Activities.Company may disclose your PHI to a health oversight agency for authorized activities such as audits, investigations, inspections, licensing, and disciplinary actions relating to the healthcare system or government benefit programs.
• Judicial and Administrative Proceedings.Company may disclose your PHI, in certain circumstances, as permitted by applicable law, in response to an order from a court or administrative agency, or in response to a subpoena or discovery request.
• Law Enforcement.Company may, under certain circumstances, disclose your PHI to a law enforcement official, such as for purposes of identifying or locating a suspect, fugitive, material witness or missing person.
• Decedents.Company may, under certain circumstances, disclose PHI to coroners, medical examiners, and funeral directors for purposes such as identification, determining the cause of death and fulfilling duties relating to decedents.
• Organ Procurement.CCompany may, under certain circumstances, use or disclose PHI for the purposes of organ donation and transplantation.
• Research.Company may, under certain circumstances, use or disclose PHI that is necessary for research purposes.
• Threat to Health or Safety.Company may, under certain circumstances, use or disclose PHI if necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public.
• Specialized Government Functions. Company, may in certain situations, use and disclose PHI of persons who are, or were, in the Armed Forces for purposes such as ensuring proper execution of a military mission or determining entitlement to benefits. Company may also disclose PHI to federal officials for intelligence and national security purposes.

You have the following rights regarding the PHI maintained by Company :

You have the following rights regarding the PHI maintained by Company :

• Confidential Communication. You have the right to receive confidential communications of your PHI. You may request that Company communicate with you through alternate means or at an alternate location, and Company will accommodate your reasonable requests. You must submit your request in writing to Company.
• Restrictions. You have the right to request restrictions on certain uses and disclosures of PHI for treatment, payment, or healthcare operations. You also have the right to request that Company limits its disclosures of PHI to only certain individuals involved in your care or the payment of your care. You must submit your request in writing to Company. Company is not required to comply with your request. However, if Company agrees to comply with your request, it will be bound by such agreement, except when otherwise required by law or in the event of an emergency.
• Inspection and Copies. You have the right to inspect and copy your PHI. You must submit your request in writing to Company. Company may impose a fee for the costs of copying, mailing, labor, and supplies associated with your request. Company may deny your request to inspect and/or copy your PHI in certain limited circumstances. If that occurs, Company will inform you of the reason for the denial, and you may request a review of the denial.
• Amendment. You have a right to request that Company amend your PHI if you believe it is incorrect or incomplete, and you may request an amendment for as long as the information is maintained by Company. You must submit your request in writing to Company and provide a reason to support the requested amendment. Company may, under certain circumstances, deny your request by sending you a written notice of denial. If Company denies your request, you will be permitted to submit a statement of disagreement for inclusion in your records.
• Accounting of Disclosures. You have a right to receive an accounting of all disclosures Company has made of your PHI. However, that right does not include disclosures made for treatment, payment or healthcare operations, disclosures made to you about your treatment, disclosures made pursuant to an authorization, and certain other disclosures. You must submit your request in writing to Company and you must specify the time period involved (which must be for a period of time less than six years from the date of the disclosure). Your first accounting will be free of charge. However, Company may charge you for the costs involved in fulfilling any additional request made within a period of 12 months. Company will inform you of such costs in advance, so that you may withdraw or modify your request to save costs.
• Breach Notification. You have the right to be notified in the event that Company (or a Company Business Associate) discovers a breach of unsecured PHI.
• Paper Copy. You have the right to obtain a paper copy of this Notice from the Company at any time upon request. To obtain a paper copy of this notice, please contact the Company by submitting a request to [email protected]
• Complaint. You may complain to the Company and to the Secretary of the Department of Health and Human Services if you believe that your privacy rights have been violated. To file a complaint with Company, you must submit a statement in writing to Company at [email protected]. Company will not retaliate against you for filing a complaint.
• Further Information. If you would like more information about your privacy rights, please contact the Company by submitting your request addressing the Privacy and Security Officer. To the extent you are required to send a written request to Company to exercise any right described in this Notice, you must submit your request to [email protected].