Privacy Policy

This Privacy Policy describes how Cyglera collects and uses Personal Information about you through the use of our Website, Mobile Application ("Application"), and through email, text, and other electronic communications between you and Cyglera.

Cyglera ("Cyglera," "we," "our," or "us") respects your privacy, and we are committed to protecting it through our compliance with this policy.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit cyglera.com or any of our affiliated websites where this Policy is posted (collectively, "Website") and the Cyglera Application and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• ✓On our Website and Application.
• ✓In emails, text messages, phone conversations, audio and video interactions and other electronic messages between you and our Website and Application.
• ✓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 Cyglera or any third party.
• ✕Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or Application.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using our Website and/or Application, you are deemed to have read and understood this Privacy Policy. This Privacy Policy may change from time to time — please check it periodically for updates.

Our Website and Application are not intended for children under the age of 18 without parental consent.

If you are under the age of eighteen (18) and wish to create an account with Cyglera, your parent or legal guardian must create the account, submit your Personal Information, and agree to this privacy policy on your behalf. If you are under the age of 13, you may only use our services with the supervision and consent of your parents or legal guardians. If we learn that we have collected Personal Information from someone under the age of 13 without parental consent, we will promptly delete that information. Please contact us if you believe we have impermissibly collected such information.

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

We collect several types of information from and about users of our Website and Application (collectively, "Personal Information" or "Personal Data"), specifically:

• ✓Information by which you may be personally identified, such as name, address, email address, telephone numbers, date of birth, credit or debit card number, audio, images and videos of you, gender, Social Security Number, medical history, health insurance subscriber information, and health information.
• ✓Information about your Internet connection, the equipment you use to access our Website or Application, and usage details such as traffic data, logs, referring/exit pages, date and time of your visit, error information, click stream data, and other communication data.

We collect this information:

• ✓Directly from you when you provide it to us.
• ✓Automatically as you navigate through the Website or use our Application, including usage details, IP addresses, and information collected through cookies and other tracking technologies.
• ✓From third parties, for example, our business partners.

Information You Provide To Us

The information we collect on or through our Website or Application includes:

• ✓Information that you provide by filling in forms on our Website or the Application, including information provided at the time of registering, using Provider consultation services, purchasing products, or requesting further services.
• ✓Records and copies of your correspondence (including email addresses) if you contact us.
• ✓Details of transactions you carry out through our Website or Application. You may be required to provide financial information before placing an order.

Video and audio from your medical telehealth visit may be recorded for purposes including treatment, quality improvement, patient experience, peer review, payment, and other purposes relating to operations and provision of telehealth services. Behavioral health visits are not recorded. By using the telehealth services, you specifically consent to the recording of the medical visit.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website and Application, we may use automatic data collection technologies to collect certain information, specifically:

• ✓Details of your access and use of the Application and Website, including traffic data, location data, logs, and other communication data.
• ✓Information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, and mobile network information.
• ✓Information stored on your mobile device, including photographs, audio and video clips, personal contacts, and health information (including iOS HealthKit data, used only to provide and improve our services, never shared with third parties for marketing purposes).
• ✓Real-time information about the location of your device.

The technologies we use for automatic data collection include:

• ✓Cookies (or browser cookies). We and our service providers may use cookies, pixel tags, web beacons, and other technologies to receive and store certain types of information. You may refuse cookies via your browser settings, though some parts of our Website or Application may then be inaccessible.
• ✓Flash Cookies. Certain features of our Website and Application may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation. Flash cookies are not managed by the same browser settings as browser cookies.
• ✓Google Analytics. We use Google Analytics to evaluate our website functionality and make improvements. View Google's privacy policy. Google account users may opt out via Google's Marketing Platform.
• ✓Meta (Facebook/Instagram). We use the Meta Pixel to keep track of users who access our Website and Application and to better serve relevant advertisements. Data from the Meta Pixel is saved and processed by Meta in accordance with Meta's Data Policy.
• ✓Microsoft. We may use Microsoft Universal Event Tracking and similar technologies to evaluate advertising effectiveness. Please review Microsoft's privacy policy for additional information.

We use your Personal Information for various purposes, including to:

• ✓Provide our Website or Application to you.
• ✓Provide services to you.
• ✓Provide you with information you request from us.
• ✓Enforce our rights arising from contracts.
• ✓Notify you about changes to our services.
• ✓Provide you with notices about your account.
• ✓Provide and improve our Website, Application, products, and services, including through machine learning and artificial intelligence programs.
• ✓For purposes of treatment, quality, improvement of health status, patient experience, behavior modification, peer review, payment, efficiency, and cost effectiveness.
• ✓Process, fulfill, support, and administer transactions and orders for products and services.
• ✓Contact you in response to a request; administer surveys; and fulfill any other purpose for which you provide information.
• ✓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. You may opt-out at any time by clicking unsubscribe at the bottom of these communications.

Health Information

Some information Cyglera collects constitutes protected health information ("PHI") under HIPAA. Cyglera is a "business associate" (as that term is used under HIPAA) that provides services to and for health care providers and health care plans, and enters into business associate agreements with these covered entities. Cyglera will use and disclose PHI only in accordance with those agreements and HIPAA.

De-Identified Information

We may de-identify your Personal Information so that it no longer reasonably identifies you. We may use de-identified data without restriction and for any purpose, including to improve our Website, Application, and services.

We may disclose your Personal Information to a few third parties, including:

• ✓Our affiliates and third-party service providers that we use to support our business, including IT, infrastructure, marketing, advertising, and payment processing services.
• ✓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.
• ✓To fulfill the purpose for which you provide it (e.g., to a Provider).
• ✓For any other purpose disclosed by us when you provide the information.
• ✓With your consent.
• ✓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.
• ✓If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Cyglera, our customers, or others, including exchanging information for fraud protection and credit risk reduction.

We do not share or otherwise disclose your Personal Information for purposes other than those outlined in this Privacy Policy.

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

• ✓Tracking Technologies and Advertising. You can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, some parts of our Website or Application may be inaccessible or not function properly.
• ✓Promotional Offers from Cyglera. If you do not wish to have your email address used to promote our products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any promotional emails. This opt-out does not apply to information provided as a result of a product purchase or use of our services.
• ✓Location Information. You can choose whether to allow the Application to collect and use real-time location information through the device's privacy settings. Blocking location information may make some parts of the Application inaccessible or not function properly.

You may review and change your Personal Information by logging into the Application or Website and visiting your Account Details page.

You may also notify us through the Contact Information below of any changes or errors in any Personal Information 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 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 any PHI in our possession, you have certain rights under HIPAA as described in the Notice of Privacy Practices provided to you by your healthcare Provider.

California and Colorado residents have additional rights with respect to accessing and correcting Personal Information, as described in Sections 9–11 below.

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Information. We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure, including application timeouts and encryption technology.

The safety and security of your information also depends on you. Where you have chosen a password for the use of our Website or Application, 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 work diligently to protect your Personal Information, we cannot guarantee the security of Personal Information transmitted to our Website or through our Application. Any transmission of Personal Information is at your own risk.

The California Consumer Privacy Act ("CCPA") and the Colorado Privacy Act ("CPA") provide residents of those states with certain additional privacy rights as described below.

These rights supplement the other information contained in our Privacy Policy and apply solely to visitors, users, and others who reside in the State of California or the State of Colorado.

Please note that these laws expressly exclude information regulated as protected health information (PHI) collected by a "covered entity" or "business associate" subject to HIPAA. The CCPA also excludes information regulated under the California Confidentiality of Medical Information Act (CMIA).

If you are in Canada, this section applies to you.

We may process your information if you have given us specific permission (express consent) or in situations where your permission can be inferred (implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including:

• ✓If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
• ✓For investigations and fraud detection and prevention.
• ✓For business transactions provided certain conditions are met.
• ✓If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
• ✓For identifying injured, ill, or deceased persons and communicating with next of kin.
• ✓If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse.
• ✓If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.
• ✓If the collection is solely for journalistic, artistic, or literary purposes.
• ✓If the information is publicly available and is specified by the regulations.

Categories of Personal Information Cyglera Collects

As described in detail throughout this Privacy Policy, we collect and/or disclose Personal Information or Personal Data about you when you visit or use our Website or Application, including information you provide to us and information we automatically collect from you or your device.

Categories of Sources from Which Cyglera Has Collected Personal Information

We collect Personal Information or Personal Data directly from you, for example when you provide it to us to contact us through our Website or Application, and indirectly from you automatically through your computer or device as you use our Website or Application. We may also collect Personal Information from our advertising partners and service providers.

Use of Personal Information or Personal Data

We may use Personal Information we collect for the purposes described elsewhere in this Privacy Policy. Please refer to Section 4 ("How We Use Your Information") for details.

Sharing and Disclosing Personal Information

Cyglera may disclose your Personal Information to various service providers for business purposes as described above. When we disclose Personal Information to a service provider, we enter a contract that describes the purpose and requires the recipient to keep that Personal Information confidential and not use it for any purpose except performing the contract.

Additionally, the CCPA defines a "sale" as disclosing or making available to a third party Personal Information in exchange for monetary or other valuable consideration. While we do not disclose Personal Information to third parties in exchange for monetary compensation, we may "share" or "sell" (as defined by the CCPA) identifiers and internet and electronic network activity information to third parties to improve and evaluate our advertising campaigns. We do not have actual knowledge that we sell or share any Personal Information about individuals under sixteen (16) years old.

To the extent you are a California resident, you may have the following rights regarding your Personal Information:

• ✓Right to Access: You have the right to request (up to twice per year) the categories of Personal Information collected, the sources, our business purposes, the categories of third parties to whom we disclosed it, and a copy of the specific pieces of your Personal Information we have collected.
• ✓Right to Correct: You have the right to request that we correct inaccuracies in your Personal Information.
• ✓Right to Delete: Subject to certain conditions and exceptions, you may have the right to request deletion of Personal Information that we have collected about you.
• ✓Right to Opt-Out of Sale/Sharing: You may have the right to opt-out of the "sale" or "sharing" of your Personal Information. To opt out, please click the "Do Not Sell or Share My Personal Information" link on the website homepage.
• ✓Right to Non-Discrimination: We will not discriminate against you for exercising any of the rights described in this section.
• ✓Authorized Agent: You may designate someone as an authorized agent to submit requests and act on your behalf by providing us written permission.

To make a request for the rights described above, please contact us by email. You may only make a verifiable consumer request for access twice within a 12-month period. Your request must provide sufficient information to reasonably verify you are the person about whom we collected Personal Information, including: (1) first and last name; (2) email address; (3) date of birth; and (4) address.

Under the CPA, Colorado residents have the following rights with respect to our processing of Personal Data subject to applicable Colorado law:

• ✓Right to Access: You have the right to confirm whether or not we are processing your Personal Data and to access such Personal Data.
• ✓Right to Correction: You have the right to correct inaccuracies in your Personal Data, considering the nature of the data and the purposes of processing.
• ✓Right to Deletion: You have the right to delete the Personal Data provided to us by you.
• ✓Right to Data Portability: You have the right to obtain a copy of your Personal Data in a portable, readily usable format that allows you to transmit your data to another controller without hindrance.
• ✓Right to Opt-Out of Sale, Targeted Advertising, and Profiling: We do not "sell" Personal Information as defined by the CPA. Colorado residents have the right to opt out of targeted marketing — please click the "Cookie Preferences" link on the website homepage.
• ✓Right to Appeal: If we decline to act regarding your request, you have the right to appeal. We will notify you of our reasons and instructions for how you can appeal the decision.

To make a request, email us at contact@cyglera.com, indicating you are making a request pursuant to your "Colorado Privacy Rights," and provide: (1) first and last name; (2) email address; (3) physical address; and (4) date of birth.

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. If we make material changes to how we treat our users' Personal Information, we will notify you by email to the address specified in your account and/or through a notice on the Website homepage or the Application's home screen. The date this Privacy Policy was last revised is identified at the top of the page.

If you have any questions, concerns, or suggestions regarding our Privacy Policy or need to contact us, you can reach us through the Contact Us page on our Website or at: