Privacy Notice

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us via the Services.

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, or otherwise when you contact us.

Personal Information Provided by You. 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:

• Contact information, such as your name, mailing address, email address, phone number, resume information, professional credentials, institutional affiliations and any other information you choose to provide to us
• Demographic information, such as date of birth, age, gender and marital status
• Payment-related information such as credit card and financial account information

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• health and wellness data (to the extent such information constitutes PHI, it will be subject to our HIPAA Notice of Privacy Practices)
• race and ethnicity
• geolocation data

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 automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Please refer to the Section 4 below regarding how we collect information through cookies and similar technologies.

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Personal information does not include information that can no longer be used to identify you, whether in combination with other information or otherwise, including de-identified or aggregated consumer information.

For California Residents: The categories of personal information listed include those collected in the previous twelve (12) months.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To provide you with the requested service
• To provide and improve the content and functionality of the Services
• To identify visitors, customize the content and/or layout of pages for each individual visitor
• To analyze traffic to our Services
• To communicate with you and respond to your service-related requests, questions and feedback
• To keep our Services safe and secure, including fraud monitoring and prevention
• To investigate any complaints received from you or from others about our Services
• To undertake internal research for technological development and demonstration
• Where it is necessary for our legitimate interests (or those of a third party) and, where consistent with applicable laws
• To process employment applications
• As we believe necessary or appropriate to: (i) comply with any legal, regulatory or contractual obligation and to respond to requests from public and governmental authorities; (ii) investigate and deter security breaches as well as fraudulent, harmful, unauthorized, unethical or illegal activity; (iii) enforce our Terms and Conditions; and (iv) protect our rights, privacy, safety and property and the rights, privacy, safety and property of others
• For any other purpose with your consent

We may also use your personal information, including through automated processing and artificial intelligence technologies, to enable the generation of content, such as text, audio, images and videos in connection with the Amae Portal. We do not conduct automated processing of personal information for the purposes of evaluating, analyzing or predicting an individual’s personal aspects in furtherance of decisions that produce legal or similarly significant effects, as those practices are defined under applicable laws. We do not use racial or other protected class information for discriminatory purposes in violation of applicable law. While we strive to provide accurate, appropriate and helpful AI-generated content, you acknowledge that AI technology is evolving and may not always produce complete or accurate information, we do not guarantee the suitability of AI-generated content for any particular purpose and you should exercise independent judgment when acting on AI-generated advice or guidance.

Please note that the use of our PHI is explained in the Notice of Privacy Practices.

3. WHEN AND TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

In Short: We may disclose information in specific situations described in this section and/or with the following third parties.

We may need to disclose your personal information in the following situations:

• Service Providers and Contractors. We may disclose your personal information with our trusted third parties with whom we contract to help provide, improve, protect and promote our Services.
• Business Transfers. We may disclose 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.
• Compliance, Fraud Prevention and Safety. We may disclose your information for the compliance, fraud prevention and safety purposes described above and to comply with legal requirements and processes.
• Legal Purposes. We may disclose your information when we think it is necessary to investigate or prevent actual or suspected fraud, criminal activity, injury or damage to us or others; when otherwise required by law, regulation, subpoena, court order, warrant or similar legal process; or if necessary to assert or protect our rights or assets.
• Other Applications and Third-Party Links. The Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or disclose data about you. We do not control these third-party websites and are not responsible for their privacy practices. When you leave our Services, we encourage you to read the privacy policies of every website you visit. Please remember that their use of your personal information will be governed by their privacy policies and terms.
• The Public, with Your Consent. We may make available functionality that enables you to disclose information to the public. We do not control how other individuals or third parties use any personal information that you choose to make available to the public. If you gave us consent to post a testimonial on our Services and/or social media pages but wish to update or delete it, please contact us at hello@amaehealth.com.
• Other Parties. We may disclose your information to another party or parties for any other purpose disclosed by us when you provided your personal information, with your consent or authorization, or as otherwise permitted or required by applicable law.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). Note that advertising cookies are not used on the Amae Portal. The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a “sale”/”sharing” (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section “DOES AMAE HEALTH COLLECT, SELL OR SHARE YOUR PERSONAL INFORMATION AS DESCRIBED IN THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)?”

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

5. 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, subject to your rights, in certain circumstances, to have your personal information erased). We may be required by law to hold certain personal information for specific periods. In other cases, we will retain your personal information for an appropriate period after our relationship ends to protect ourselves from legal claims or to administer our business. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

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.

6. 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 and reasonable 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.

7. 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 collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. 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 hello@amaehealth.com.

In Short: If you are a resident of California, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

Text message: If you have opted in to receive texting messaging from us, you may opt-out at any time by texting STOP in response to the communication.

9. 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. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

10. DOES AMAE HEALTH COLLECT, SELL OR SHARE YOUR PERSONAL INFORMATION AS DESCRIBED IN THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)?

If you are a California resident, this section of the Privacy Notice may apply to you. For purposes of the CCPA, “personal information” means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information does not include:

• Protected health information subject to the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations, as amended (collectively, “HIPAA”);
• Medical information governed by the California Confidentiality of Medical Information Act (“CMIA”);
• Information that is collected, used or disclosed in research;
• Publicly available information from government records or lawfully obtained truthful information that is a matter of public concern; or
• De-identified or aggregated consumer information.

The CCPA requires us to provide certain disclosures at or before collection of personal information from California residents. The below CCPA Notice at Collection provides you with information about how we collect, use, sell or share your personal information through the use of the Services.

Sources of Personal Information. For additional information on how we may collect your personal information, refer to the “WHAT INFORMATION DO WE COLLECT?” section of this Privacy Notice, above.

How We Use and Disclose Personal Information. For additional information on how we may use and disclose your personal information refer to the “HOW DO WE PROCESS YOUR INFORMATION?” and “WHEN AND TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?” sections of this Privacy Notice, above.

We do not generally sell or share any personal information as the terms “sell” and “share” are traditionally understood. We do not sell or share information (including de-identified personal information) to third parties for money. During the past twelve (12) months, we may have engaged in delivering online advertising that was tailored to your interests, but we did not disclose data that would identify you by name, address or phone number. To the extent “sale” or “sharing” under the CCPA are interpreted to include advertising technology activities such as those disclosed here and in this Privacy Notice as a “sale” or “sharing,” we will comply with applicable law, including the CCPA, as to such activities. As described below, you have the right to opt out of the “sale” or “sharing” of your personal information. Additionally, you should know that the CCPA prohibits third parties to whom we “sell” or “share” personal information from reselling or resharing it unless you have received explicit notice and an opportunity to opt-out of further sales or sharing. We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old.

Your Rights

If you are a California resident, you have certain rights related to your personal information under the CCPA. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know. You have the right to request that we disclose certain information to you about how we have collected, used, sold and/or shared your personal information during the past twelve (12) months. Once we receive and verify your request, we will disclose to you, if requested: the categories of personal information we collected about you; the specific pieces of personal information we collected about you; the categories of sources for the personal information we collected about you; our business or commercial purpose for collecting, disclosing, selling or sharing your personal information; the categories of third parties to whom we disclose your personal information; and if we sold, shared or disclosed your personal information for a business purpose, three separate lists setting out: sales (identifying the personal information categories that each category of recipient purchased); sharing (identifying the personal information categories that each category of recipient obtained); and disclosures for a business purpose (identifying the personal information categories that each category of recipient obtained).
• Right to correct inaccurate information. You have the right to correct inaccuracies in your personal data that we maintain about you.
• Right to delete. You have the right to request the deletion of your personal data that we have collected about you, subject to certain exceptions.
• Right to non-discrimination. We will not discriminate against you for choosing to exercise any of your rights under the CCPA, including, for example, by denying goods or services to you, charging you different prices or rates, or providing a different level of quality of products or services. However, we may charge a different price or rate or provide a different level or quality of goods or services when that difference is reasonably related to the value provided to us by the data.
• Right to opt out of sale or sharing. You have the right to opt out of the sale or sharing of your personal information (e.g., if it is used for targeted advertising or profiling in furtherance of decisions that produce legal or similarly significant effects).
• Right to limit use and disclosure of sensitive personal information. You have the right to limit the use or disclosure of your sensitive personal information if used to infer characteristics about you.

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at hello@amaehealth.com, calling us at 1-888-860-2825 or by referring to the contact details at the bottom of this document.

You can designate an authorized agent to make a request 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 applicable laws.

Request Verification

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. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if 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.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf. We will not disclose, correct or delete any of your personal information until identity has been verified.

California “Shine The Light” Act

California Civil Code Section 1798.83, also known as the “Shine The Light” Act, 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, as defined in Shine the Light Act, (if any) we disclosed to third parties for their own direct marketing purposes. In general, if we have made such a disclosure of personal data, upon receipt of a request by a California resident, we must either (i) required to provide a list of all third parties to whom personal data was disclosed in the preceding calendar year, as well as a list of the categories of personal data that were disclosed; or (ii) permit the California resident to opt-in to or opt-out of this type of sharing. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this Privacy Notice, you may email us at hello@amaehealth.com or contact us by post at:

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us at hello@amaehealth.com.