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Privacy Policy

This Privacy Policy (“Privacy Policy”) describes the types of information Delfina Care Inc. and its subsidiaries or affiliates (collectively, “Company”, “we”, “us”, or “our”) collect, use, and share about you when you visit or use www.delfina.com (the “Site”) and the Delfina mobile application “Delfina” (the “App”), the Delfina Care software (the “Software”), the blood pressure cuffs, glucometers, and weigh scales (the “Devices”) (collectively, the “Platform”), and all related non-clinical support services, features, and content offered by the Company or when you otherwise contact or interact with us (collectively, the “Services”). The terms “you” and “your” refers to you, the user. This Privacy Policy also explains how Company may use and share your Personal Information (as defined in Section 1), as well as the choices available to you. By using and continuing to use the Platform and Services, you acknowledge that you have read, understand, and agree to the collection, storage, use, and disclosure of your Personal Information as described in this Privacy Policy, and you agree to the Terms of Use (the “Agreement”) which is incorporated by reference. If you do not agree, please do not access or use the Platform or Services.

Terms of the Agreement

If you choose to access or use the Platform or Services, your access and use, and any dispute related to your Personal Information or the privacy thereof is subject to this Privacy Policy and our Agreement, including, but not limited to, the limitations on damages and resolution of disputes.

The Platform and Services Do Not Provide Medical Advice

Company is not a medical group and does not provide medical advice, care, or treatment. Company provides administrative and management services to independent, physician-owned and operated, medical practices. Any telemedicine consults and treatment obtained through our Platform are provided by independently owned and operated medical practices (the “Medical Group”). Company provides the Platform, Services, and the information, materials, and data contained therein for informational and educational purposes only. Company does not provide any medical advice through the Platform or Services, and the information, materials, and/or data contained therein should not be so construed or used. Using, accessing, or browsing the Platform or Services or providing personal or medical information to Company does not create a physician-patient, professional-client, or similar relationship between you and Company. Nothing contained in the Platform or provided through the Services is intended to create a physician-patient, professional-client, or similar relationship intended to replace the services of a licensed, trained physician or health professional, or to be a substitute for medical advice of a physician or trained health professional licensed in your state. You should not rely on anything contained on the Platform or learned through the Services, and you should consult a physician licensed in your state in all matters relating to your health. You hereby agree that you will not make any health or medical related decision based in whole or in part on anything contained on the Platform or learned through the Services. You are solely responsible for the use of any information, materials, or data available through the Platform or from the Services. COMPANY IS NOT A LICENSED MEDICAL CARE PROVIDER AND THE PLATFORM AND SERVICES ARE NOT INTENDED TO REPLACE PROFESSIONAL MEDICAL ADVICE OR DIAGNOSE, TREAT OR MANAGE ANY ILLNESS OR MEDICAL CONDITION, OR SERVE AS A BIRTH CONTROL METHOD OR CONTRACEPTION. PLEASE CONSULT WITH A LICENSED PHYSICIAN OR OTHER QUALIFIED HEALTHCARE PROVIDER BEFORE MAKING ANY DECISIONS OR TAKING ANY ACTIONS THAT MAY AFFECT YOUR HEALTH AND SAFETY OR THAT OF YOUR FAMILY OR FETUS. NEVER DISREGARD PROFESSIONAL MEDICAL ADVICE OR DELAY IN SEEKING IT BECAUSE OF SOMETHING YOU HAVE READ OR LEARNED IN CONNECTION WITH THE PLATFORM OR SERVICES. ALWAYS CONSULT WITH YOUR HEALTHCARE PROFESSIONAL IF YOU HAVE ANY QUESTIONS OR CONCERNS ABOUT YOUR HEALTH OR CONDITION OR EXPERIENCE ANY CHANGES IN YOUR CONDITION OR HEALTH STATUS. IF YOU THINK YOU HAVE A MEDICAL EMERGENCY, CALL 911 (OR OTHER APPLICABLE EMERGENCY PHONE NUMBER) OR GO TO THE NEAREST OPEN EMERGENCY ROOM IMMEDIATELY.

1. Personal Information We Collect

Generally, we collect three (3) types of information about you: (A) information and content you give us directly; (B) information we obtain automatically when you use our Platform or Services; and (C) information we get about you from other sources. When we talk about “Personal Information” in this Privacy Policy, we are talking about any of the following information: A. Information and Content You Give Us Directly i. Personally Identifiable Information. Information such as your name, address, e-mail address, username, password, social security number, phone number, date of birth, and any other information you directly provide us on or through the Platform or Services. This includes information you provide when you register or create an account or submit a request for customer service. ii. Characteristics of Protected Classifications under Applicable Law. Information such as race, age, disability status, sexual orientation, and sex and sex life (e.g. gender, gender identity, pregnancy, or child birth). iii. Email and SMS Correspondences. Records and copies of your email messages together with your email address and our responses and your text messages, if you choose to correspond with us through email or SMS. iv. Health Related Information. Health related information such as your mood, blood pressure, blood glucose, height, weight, physical (biometric) data, various mental and clinical health information, health insurance information, and any other health or medical information you directly provide us through the Platform or Services. B. Information We Obtain Automatically When You Use Our Services i. Activity Information. Details of your visits to our Platform, including the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; the time, frequency, and duration of your activities; and other information about your use of and actions on the Platform. ii. Equipment Information. Information about your computer and internet connection, including your device or computer operating system, IP address, browser type, and browser language. iii. Location Information. Information about the location of your device, including GPS location, for purposes of enhancing or facilitating the Platform and Services. For example, we may use information about the location of the device you are using to help us understand how the Platform, Services and functionality are being used and to deliver more relevant advertising. If you do not want to share your location, you can disable location sharing in the settings on your device. iv. Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide the content, advertising, or other functionality on the Platform may use cookies, web beacons, JavaScript, entity tags, HTML5 local storage, resettable device identifiers, and other technologies (collectively, the “Technologies”) to automatically collect information through your use of the Platform. The following describes some of these Technologies we may use for this automatic data collection: a. Cookies. A cookie is a small data file stored on the hard drive of your device either for (1) the duration of your visit on a website ("session cookies") or (2) for a fixed period ("persistent cookies"). Cookies contain information that can later be read by a web server. We may use cookies to provide you with a more personal and interactive experience on the Platform. 1. Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Platform. Google Analytics uses cookies, to help our Platform analyze how users use our Website. You can find out more about how Google uses data when you visit our Platform by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/). For more information, please visit Google and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html. b. Web Beacons. Web beacons are small files that are embedded in webpages, applications, and emails (also known as "clear gifs", "pixel tags", "web bugs", and "single-pixel gifs") that collects information about engagement on our Platform. For example, web beacons allow Company to track who has visited those webpages or opened an email, to test the effectiveness of our marketing, and for other related website statistics. c. JavaScripts. JavaScripts are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components. d. Entity Tags. Entity Tags are HTTP code mechanisms that allow portions of websites to be stored or "cached" within your browser and validates these caches when the website is opened, accelerating website performance since the web server does not need to send a full response if the content has not changed. e. HTML5 Local Storage. HTML5 local storage allows data from websites to be stored or "cached" within your browser to store and retrieve data in HTML5 pages when the website is revisited. f. Resettable Device Identifiers. Resettable device identifiers (also known as "advertising identifiers") are similar to cookies and are found on many mobile devices and tablets (for example, the "Identifier for Advertisers" or "IDFA" on Apple iOS devices and the "Google Advertising ID" on Android devices), and certain streaming media devices. Like cookies, resettable device identifiers are used to make online advertising more relevant. This Privacy Policy does not cover the use of tracking technologies by third parties in connection with their websites or applications. The Platform may contain links, content, advertising, or references to other websites offered by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you interact with their content on the Platform. The information they collect may be associated with your Personal Information or they may collect information about your online activities over time and across different websites. Please be aware that we do not control these third parties' tracking technologies or when and how they may be used. Therefore, Company does not claim nor accept responsibility for any privacy policies, practices, or procedures of any such third party. We encourage you to read the privacy statements and terms and conditions of linked or referenced websites you enter. If you have any questions about an ad or other targeted content, you should contact the responsible provider directly. C. Information We Get About You from Other Sources We may receive information about you from other sources and add it to our information, including from third-party services and organizations who have the right to provide us with such information. We protect this information according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These sources may include: online and offline data providers, from which we obtain demographic, interest-based, and online advertising related data; publicly-available sources such as open government databases or social networks; and service providers who provide us with information and updates to that information, based on their relationship with you. By gathering additional information about you, we can correct inaccurate information, enhance the security of your transactions, and give you product or service recommendations and special offers that are more likely to interest you. This Privacy Policy does not apply to information collected from users who log-in to the password-protected and secure portions of our Platform (“Secure Platform”). The Secure Platform allows users who obtain access (“Customers”) to perform certain functions or obtain certain services. All information collected and stored by us or added by Customers into such Secure Platforms is considered Protected Health Information ("PHI") and/or medical information and is governed by applicable state and federal laws that apply to that information, for example the Health Insurance Portability and Accountability Act (“HIPAA”). How we use and disclose such PHI is in accordance with the applicable Notice of Privacy Practices provided to you by the Medical Group. We will not use or disclose information collected from the Secure Platform or received from Medical Group or your provider for advertising, marketing, or other use-based data mining purposes. We will not sell any PHI.

2. How We Use Your Information

We may use the information we collect about you in a variety of ways, including, to provide our Platform and Services, for administrative purposes, and to market and advertise our Platform and Services and products. A. We Use Your Personal Information to Provide Our PLatform and Services We may use your Personal Information to: i. provide the Platform and Services to you. ii. respond to comments, questions, and provide customer service. iii. fulfill any other purpose for which you provide Personal Information. iv. communicate with you about your account. v. inform you about important changes to, or other news about, the Platform or Services or any of its features or content. B. We Use Your Information for Administrative Purposes We may use your Personal Information to: i. operate, maintain, improve, personalize, and analyze the Platform and Services. ii. monitor and analyze trends, usage, and activities for marketing or advertising purposes. iii. detect, prevent, or investigate security breaches, fraud, and other unauthorized or illegal activity. iv. carry out our obligations and enforce our rights arising from any contracts entered into between you and us. v. maintain appropriate records for internal administrative purposes. vi. allow you to participate in interactive features on the Platform. vii. develop, improve, and analyze our predictive models, both experimental and underlying the Platform and Services. viii. anonymize and aggregate information for analytics and reporting. C. We Use Your Information to Market and Advertise Our Platform, Services, and Products. We may use your Personal Information to: i. send promotional communications, such as information about features, newsletters, offers, promotions, contests, and events. ii. share information across the Platform, Services, and devices to provide a more tailored and consistent experience on the Platform and Services. iii. develop, test, and improve new products or services, including by conducting surveys and research and testing and troubleshooting new products and features.

3. How We May Share or Disclose Your Information

We may share or disclose aggregated or anonymized information about our users to third parties for a variety of business purposes without any restrictions, including to provide our Services and improve our Platform, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer. The following circumstances describe in additional detail the ways we may share or disclose your Personal Information that we collect or that you provide under this Privacy Policy: A. We Disclose Your Information to Provide Our Platform and Services i. Subsidiaries and Affiliates. We may share your Personal Information with our parent companies, subsidiaries, joint ventures, and affiliated companies for purposes of management and analysis, decision-making, and other business purposes, consistent with this Privacy Policy. ii. Service Providers. We may share your Personal Information with our third-party service providers, contractors, and any other similar third parties that help us operate our Platform or provide our Services. This may include service providers that help us with analytics services or support services, such as credit card processing, website hosting, email and postal delivery, location mapping, product and service delivery. iii. Advertising/Marketing Service Providers. We may share your Personal Information with marketing service providers to assess, develop, and provide you with promotions and special offers that may interest you, administer contests, sweepstakes, events, or for other promotional purposes. iv. Consent or to Fulfill the Purpose that Information was Provided. We may share your Personal Information to fulfill the purpose for which you provide that information, with your consent, or for any other purpose disclosed by us when you provide the information. v. Improvement of Analytics and Research Studies. We may share your Personal Information with research associates, health institutions, and other third-party research organizations to assess, develop, improve, and exchange predictive modeling and data analytics for purposes of improving healthcare outcomes. For example, we may use your Personal Information as a part of a data set that will be used to improve the accuracy of our healthcare outcomes predictive modeling algorithms or in connection with a grant-based healthcare study. B. We May Disclose Your Information in the Event of a Merger, Sale, or Other Asset Transfers If we become involved in a merger, acquisition, financing due diligence, divestiture, restructuring, reorganization, bankruptcy, dissolution, sale, or transfer of some or all of our assets (whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding), or transition of the Platform and Services to another provider, your Personal Information may be sold or transferred to business entities or people involved in such process. C. We Disclose Your Information to Protect Us or Others i. When Required by Law. We may share your Personal Information to comply with any court order, law, or legal process, including to respond to any government or regulatory request. ii. To Enforce Our Rights. We may share your Personal Information to enforce or apply this Privacy Policy, our Agreement, and other agreements, including for billing and collection purposes. iii. To Protect Lawful Interests. We may share your personal information if we believe disclosure will help us protect the rights, property, or safety of Company, our users, partners, agents, and others. This may include exchanging information with other companies and organizations for fraud protection, and spam and malware prevention.

4. Your Privacy Choices and Rights

You have certain choices and rights with respect to your privacy. For example, you may be able to opt out of receiving marketing messages from us, make choices regarding cookies, and exercise other privacy rights under applicable law. A. Mechanisms to Control Your Information i. Cookies and Other Tracking Technologies. You may be able to set your browser to reject cookies and certain other technologies by adjusting the appropriate settings in your browser. Each browser is different, but many common browsers have preferences that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed, or allow you to remove or reject the use or installation of certain technologies altogether. We recommend that you refer to the “Help” menu in your browser to learn how to modify your browser settings. Please note that you cannot remove Flash cookies simply by changing your browser settings. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or may not function properly. ii. Communications from Company. If you do not wish to have your contact information used by Company to promote our own or third-party products or services, you can opt-out by: (1) informing us of your preference at the time you sign up for your App account, or complete any other form on or through the Platform which we collect your data; (2) modifying your user preferences in your account profile by checking or unchecking the relevant boxes; (3) following the opt-out instructions at the bottom of the promotional emails we send you; or (4) sending an email stating your request to support@delfina.com. Please note that we may also send you non-promotional communications, however you will not be able to opt-out of these communications (e.g., transactional communications, including emails about your account or purchases; communications regarding our Platform and Services; and communications about updates to this Privacy Policy and the Agreement). iii. “Do Not Track”. "Do Not Track" (“DNT”) is a privacy preference you can set in certain web browsers. When you turn on this preference, it sends a signal or message to the websites you visit indicating that you do not wish to be tracked. Please note that we currently do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative and the Digital Advertising Alliance. B. Accessing and Correcting Your Information In accordance with applicable law, you may have the right to: i. Access Personal Information. You may access Personal Information about you, including: (1) confirming whether we are processing your Personal Information; (2) obtaining access to or a copy of your Personal Information; and (3) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the "right of data portability"). ii. Request Correction of Personal Information. You may request correction of your Personal Information where it is inaccurate, incomplete, or improperly possessed. iii. Request Deletion of Personal Information. You may request deletion of your Personal Information held by us about you. Please note: we cannot delete your Personal Information except by also deleting your account. If you would like to exercise any of these rights, you may send an email to deletions@delfina.com to request access to, correction of or removal of any Personal Information that you have provided to us. We will process such requests in accordance with applicable law. You may also access, correct, or remove your Personal Information by logging into the App and visiting your account profile.

5. How We Protect Your Information

We have implemented safeguards reasonably designed to secure your Personal Information. Such safeguards include the implementation of various technical, physical, administrative and organizational security measures intended to reduce the risk of loss, misuse, unauthorized access, disclosure, or modification of your information. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information is also dependent on you. If we have given you (or where you have chosen) a password for access to certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. While we have employed security technologies and procedures to assist safeguarding your Personal Information, no system or network can be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

6. International Transfer of Personal Information

If you provide Personal Information through the Platform and Services, you acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of Company and the other third parties referenced in this Privacy Policy located in the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of such laws, where applicable.

7. Personal Information Retention Period

We keep your information for the length of time needed to carry out the purpose outlined in this Privacy Policy and to adhere to our policies on keeping records (unless a longer period is needed by law). Our records policies reflect applicable laws. We will retain and use your information to the extent necessary to manage your relationship with us, personalize and improve your overall customer experience, and to comply with our legal obligations.

8. State Privacy Rights

A. California Shine the Light. The California "Shine the Light" law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to exercise any of your rights under the law, please contact us as set forth in "Contact Information" below. We will process such requests in accordance with applicable laws. B. Nevada Privacy Rights. If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to sell or license that Personal Information, even if your Personal Information is not currently being sold. If you would like to exercise this right, please contact us via the information found in the “Contact Information” section below.

9. Children Using or Accessing The Platform

We are especially committed to protecting the privacy of children. Company’s Platform and Services are directed at a general audience over the age of eighteen (18) and are not targeted to children. If we learn that we have inadvertently collected or received Personal Information from an individual under the age of eighteen (18), we will use reasonable efforts to immediately remove such information, unless we have a legal obligation to keep it. If you are a parent or legal guardian and think your child under the age of eighteen (18) has given us information without your consent, please contact us via the information found in the “Contact Information” section below.

10. Changes to Our Privacy Policy

We reserve the right to update this Privacy Policy from time to time in order to reflect, changes to our practices or for other operational, legal, or regulatory reasons. When we do update this Privacy Policy, we will post the updates and changes on the Platform. We may elect to notify you of material changes by mail, email, posting of a modified Privacy Policy, or some other similar manner. However, it is your responsibility to check our Platform regularly for changes to this Privacy Policy. Your continued use of or access to the Platform and Services following the posting of any changes to this Privacy Policy constitutes acceptance of those changes.

11. Third-Party Websites and Applications; Social Networking Services

Our Platform may offer links to websites or applications that are not run by us but by third parties. These third-party services, websites or applications are not controlled by us, and may have privacy policies that differ from our own. We encourage our users to read the privacy policies and terms and conditions of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the practices of such third parties or the content of their application or website. Providing Personal Information to third-party websites or applications is at your own risk.

12. Contact Information

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e mail at support+privacy@delfina.com or by phone at (617) 575-9166.