Last modified: December 4, 2020

1. Introduction

This Privacy Policy describes how Caremeda collects and uses Personal Data about you through the use of our Website, App, Devices, and through e-mail, text, and other electronic communications between you and Caremeda.

Caremeda, LLC (“Caremeda,” or “we,” “our,” or “us”) respects your privacy, and we are committed to protecting it through our compliance with this policy.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit or use our website located at Caremeda.com (our “Website”), the Caremeda Family App mobile application, (our “App”), or while you use our wearable devices (our “Devices”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. For purposes of this Privacy Policy, our Website, App, Devices, and all related services and functionality that we provide through them are referred to as our “Digital Services.”

This policy applies to information we collect:

• on our Digital Services;

• in e-mail, text, and other electronic messages between you and our Digital Services; and

• when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by Caremeda or any third party; or

• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Digital Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Digital Services. By accessing or using our Digital Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Digital Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Caremeda is not a medical group and does not provide medical services or treatment. Any medical care or treatment obtained as a result of the use of our Digital Services will be provided by your health care providers, not Caremeda. Your health care provider is responsible for providing you with a notice of privacy practices describing its collections and use of your health information, not Caremeda. If you do not agree to be bound by those terms, you are not authorized to access or use our Digital Services, and you must promptly discontinue use of our Digital Services.

Health Information. Some information Caremeda collects on behalf of your health care provider or health care facility may constitute protected health information (“PHI”) under the U.S. Health Insurance Portability and Accountability Act (“HIPAA”). As set forth above, your health care provider will provide you with a notice of privacy practices describing its collection and use of your health information, not Caremeda. Accordingly, Caremeda will use PHI only for the purpose for which it was collected, and we only collect the information we need to fully perform our services, to respond to you or your health care provider, or as otherwise permitted by the health care provider or applicable law. We may use your PHI to contact you, to provide requested services, to provide information to your health care providers and insurers, to obtain payment for our services, to respond to your inquiries and requests, to improve our products or services, and to respond to inquiries and requests from your health care providers and benefits programs. We may combine your information with other information about you that is available to us, including information from other sources, such as from your health care providers, insurers, or benefits program, in order to maintain an accurate record of our participants. PHI will not be used for any other purpose, including marketing, without your consent.

2. Children Under the Age of 18

Our Digital Services are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Digital Services. We will remove any information about a child under the age of 18 if we become aware of it.

Our Digital Services are not intended for children under 18 years of age. No one under age 18 may provide any information to or through the Digital Services. We do not knowingly collect personal data or information from children under 18. If you are under 18, do not use or provide any information on or in our Digital Services or on or through any of their features, including your name, address, telephone number, e-mail address, or any screen name or user name you may use. If we learn we have collected or received personal data or information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at privacy@caremeda.com or call us at 1-888-305-3958.

3. Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

Generally

We collect several types of information from and about users of our Digital Services, specifically information:

• by which you may be personally identified, such as name, billing address, home, permanent or temporary residence address, shipping address, e-mail address, home, work, and mobile telephone numbers, date of birth, credit or debit card number (for payment purposes only), medical history, and health information (“Personal Data”);

• about your use of our Devices (including a unique identifier for your Devices);

• that is about you but individually does not identify you, such as traffic data, logs, referring/exit pages, date and time of your visit to or use of our Digital Services, error information, clickstream data, and other communication data and the resources that you access and use on or through our Digital Services; and

• about your Internet connection, the equipment you use to access or use our Digital Services, and usage details.

We collect this information:

• directly from you when you provide it to us;

• automatically as you navigate through or use our Digital Services. Information collected automatically may include estimated or precise geo-location, usage details, IP addresses, and information collected through cookies and other tracking technologies; and

• from third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Digital Services is:

• Personal Data such as the data identified above;

• information that you provide by filling in forms on our Digital Services. This includes information provided at the time of registering to use our Digital Services, using our services or other services available through the Digital Services, purchasing products, or requesting further services. We may also ask you for information when you report a problem with our Digital Services;

• records and copies of your correspondence (including e-mail addresses), if you contact us;

• from use of our wearable devices and through your health care provider or facility; and

• details of transactions you carry out through our Digital Services and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Digital Services.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Digital Services, we may use automatic data collection technologies to collect certain information about your physical health and condition and your equipment, browsing actions, and patterns, specifically:

• information collected automatically by our Digital Services, including information about your physical health and condition, such as body temperature, weight, oxygen saturation, respiratory rate, heart rate, blood pressure, cardiac health, steps and activity levels, facial recognition information, sleep state and data, proximity to other Devices, and other similar data;

• details of your visits to our Digital Services, such as traffic data, location, logs, referring/exit pages, date and time of your visit to or use of our Digital Services, error information, clickstream data, and other communication data and the resources that you access and use on or in the Digital Services; and

• information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, browser type, and App version information.

The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Digital Services and to deliver a better and more personalized service by enabling us to:

• estimate our audience size and usage patterns;

• store information about your preferences, allowing us to customize our Digital Services according to your individual interests; and

• recognize you when you return to our Digital Services.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). We and our service providers may use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Digital Services through your computer or mobile device. A cookie is a small file or piece of data sent from a website and stored on the hard drive of your computer or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting, you may be unable to access or use certain parts of our Digital Services. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or use our App.

• Web Beacons or Pixel Tags. Pages of our Digital Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail, and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

• 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 Website. Google Analytics uses “cookies,” which are text files placed on your computer, to help our Website analyze how users use the site. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps” (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics, please visit Google’s website and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.

4. How We Use Your Information

We use your Personal Data for various purposes described below, including to:

• provide our Digital Services to you;

• monitor and collect information about your health and physical condition;

• provide products and services to you;

• provide you with information you request from us;

• enforce our rights arising from contracts;

• notify you about changes; and

• provide you with notices about your account.

We use information that we collect about you or that you provide to us, including any Personal Data:

• to provide our Website and its functionality, contents, and services to;

• to provide our App and its functionality, contents, and services;

• to provide our products and services to you;

• to monitor and collect information about your health and physical condition for your use and (subject to compliance with applicable laws) use by your health care provider in connection with your health care treatment and care coordination;

• to provide you with information, products, or services that you request from us or that may be of interest to you;

• to process, fulfill, support, and administer transactions and orders for products and services ordered by you;

• to provide you with notices about your Caremeda account;

• to create statistical data sets to better provide our services, and to improve our products and services;

• to contact you in response to a request;

• to fulfill any other purpose for which you provide it;

• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

• to notify you about changes to our Digital Services or any products or services we offer or provide though them;

• in any other way we may describe when you provide the information; and

• for any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications or by visiting your Account Preferences page. For more information, see Choices About How We Use and Disclose Your Information.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We disclose your Personal Data to a few third parties, including:

• our affiliates and third party service providers that we use to support our business;

• to a company we merge, acquire, or that buys us, or in the event of a change in the structure of Caremeda of any form;

• to comply with our legal obligations;

• to enforce our rights; and

• with your consent.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users and information that does not identify any individual without restriction.

We may disclose Personal Data that we collect or you provide as described in this privacy policy:

• to affiliates, contractors, service providers, and other third parties we use to support our business. The services provided by these organizations include providing IT and infrastructure support services, ordering, marketing, and payment processing services;

• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Caremeda about our Digital Services users are among the assets transferred;

• to fulfill the purpose for which you provide it;

• for any other purpose disclosed by us when you provide the information;

• with your consent.

We may also disclose your Personal Data:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;

• to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; and

• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Caremeda, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

6. Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for our advertising to you, and other targeted advertising.

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. These third parties may aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

• Tracking Technologies and Advertising. You can set your browser or operating to refuse all or some cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Digital Services may then be inaccessible or not function properly

• Promotional Offers from Caremeda. If you do not wish to have your e-mail address used by Caremeda to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any e-mail or other marketing communications you receive from us or logging onto your Account Preferences page. This opt out does not apply to information provided to Caremeda as a result of a product purchase or your use of our services. You may have other options with respect to marketing and communication preferences through our Digital Services.

You may contact us to access or change your Personal Data. You may also be able to review and change your personal information by logging into the Digital Service and visiting your Account Preferences page.

You can Contact Us at 1-888-305-3958 or support@caremeda.com to access and/or find out what information we have about you and to correct that information. You may also notify us of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We cannot delete your personal information except by also deleting your account with us. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

With respect to PHI, Caremeda may obtain, you have certain rights under HIPAA to access your data, to restrict use and disclosure of it, to request communication methods, to request corrections to your data, to receive an accounting disclosures, and to receive notice of any breach. To exercise these rights, we may direct you to your health care provider to fulfill your request or seek your health care provider’s permission to do so before fulfilling such request. The notice of privacy practices provided to you by your health care provider will provide you more information.

8. Do Not Track Signals

We currently do not use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.

Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals, but we currently do not use automated data collection technologies to collect information about your online activities over time and across third party websites or other online services (behavioral advertising).

9. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Digital Services confidential.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depend on you. Where you have chosen a password for the use of our Digital Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to, on, or through our Digital Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website, in your operating system, or in the App.

10. California Privacy Rights for California Residents

Under some circumstances, California law may provide you with the right to obtain a list of third parties (if any) that we provide your Personal Data to for their own direct marketing purposes.

California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Digital Services that are California residents and who provide Personal Data in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Data and the names and addresses of those businesses with which we shared your Personal Data with for the immediately prior calendar year (e.g., requests made in 2020 will receive information regarding such activities in 2019). You may request this information once per calendar year. To make such a request, please contact us using the Contact Information below.

We will post any changes to our Privacy Policy on our Website. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website’s home page or the App’s home screen. If we make material changes to how we treat our users’ Personal Data, we will notify you by e-mail to the e-mail address specified in your account and/or through a notice on the Website’s home page or the App’s home screen. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable e-mail address for you and for periodically accessing the App or visiting our Website and reviewing this Privacy Policy to check for any changes.

12. Contact Information

You may contact us through the contact information below.

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the “Contact Us” page on or in our Digital Services.

Caremeda, LLC

Attn: Privacy Officer

8130 Lakewood Main St., Suite 103 #322

Lakewood Ranch, FL 34202

E-mail: Privacy@Caremeda.com