Privacy Policy

Introduction

We at SCRENR Health (“We”, “Us”, “the Company”, or “SCRENR”) value your privacy and are committed
to keeping your personal data confidential. We use your data solely in the context of providing the
SCRENR application (“App”) and SCRENR website (collectively, the “Platform”), and providing remote
therapeutic monitoring (“RTM”) services, including all relevant content and functionality associated with
the Platform and the RTM services (collectively, the “Services”) for use by qualified clinicians (“Provider
Users”) to provide services and care to patients (“Patient Users”).

Privacy Policy Applicability

This Privacy Policy applies to personal data that SCRENR collects from Patient and/or Provider Users of
the SCRENR Platform and the Services (“Personal Data”). The term “Personal Data” includes any
information that can be used on its own or with other information in combination to identify or
contact one of our users. Some of the Personal Data We collect and transmit may be considered “health
data” (i.e., data related to your physical or mental health), “protected health information” or “PHI” (i.e.,
information that relates to your past, present, or future physical or mental health or condition(s); the
provision of health care to you; or the past, present, or future payment for the provision of health care
to you), and/or medical records as defined by state law.
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We believe that privacy and transparency about the use of your Personal Data are of utmost
importance. Therefore, our privacy practices are intended to comply with the Health Insurance
Portability and Accountability Act (“HIPAA”) and relevant state law related to the use and disclosure of
medical records, where applicable. Additionally, in this Patient User Privacy Policy, We provide you
detailed information about our collection, use, maintenance, and disclosure of your Personal Data. The
Patient User Privacy Policy explains what kind of information We collect, when and how We might use
your Personal Data, how We protect Personal Data, and your rights regarding your Personal Data.

For additional information related to how We use and disclose your Personal Data, health data, PHI,
and/or medical records data, please contact our Privacy Officer at support@screnrhealth.com

Note regarding third-party sites: Our Services may contain links to other sites that are not operated by
SCRENR. If you click a third-party link, you will be directed to that third party’s site. We strongly advise
you to review the privacy policy(ies) of every site you visit. SCRENR has no control over and assumes no
responsibility for the content, privacy policies, or practices of any third-party sites or services. This User
Privacy Policy does not apply to your use of or access to any third-party sites or services.

‍Agreement to Privacy Policy Terms

BY ACCESSING AND/OR USING THE SERVICES AND PLATFORM, YOU ARE ACKNOWLEDGING THAT YOU
HAVE READ AND AGREE TO THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE, YOU MUST
IMMEDIATELY CEASE USING THE SERVICES AND PLATFORM.

Patient User Privacy Policy Updates

‍Please note that We occasionally update this Privacy Policy, and it is your responsibility to stay up to
date with any amended versions. If any revisions to the Privacy Policy are made, we will change the Last
Updated date above. Any changes to this Privacy Policy will be effective immediately and will apply to
all Personal Data that We maintain, use, and disclose. If you continue to use the Services and Platform
following such notice, you are agreeing to those changes.

Account Deletion

If at any point you no longer agree to the use and disclosure of Personal Data, as described in this
Privacy Policy, you can deactivate your user account on the Platform (“User Account”) by sending a
deactivation request your prescribing provider with the following information:

-Your login email address; and
-A statement that you are requesting account deletion.

‍Questions or Concerns

If you have any questions or concerns after reading this Patient User Privacy Policy, please do not
hesitate to contact Us at support@screnrhealth.com. We appreciate your feedback

COLLECTION AND USE OF PERSONAL DATA

‍What Personal Data Does SCRENR Collect?

We collect four types of information from our Patient Users: (i) demographic data; (ii) medical data; (iii)
support data; and (iv) technology data. Each category of data is explained in depth below.

‍Demographic Data: SCRENR collects demographic data from Patient Users, which may include,
but not be limited to, your name, birth date, gender, phone number, and e-mail address. The
collection of this demographic data is primarily used to create your User Account, which you can
use to securely receive the Services.

Medical Data: In addition to demographic information, We will collect information regarding
your health conditions, including, but not limited to, images, age, gender, weight, height,
medical history, symptoms, and communications between you and your healthcare provider
who is providing services to you via the Platform. We collect this information to provide you
with the Services and to provide your health care provider (i.e., the Provider User associated
with your account) with the information required to provide medical treatment through the
Platform.

‍Support Data: If you contact Us for support or to lodge a complaint, We may collect technical or
other information from you through log files and other technologies, some of which may qualify
as Personal Data (e.g., IP address). Such information will be used for the purposes of
troubleshooting, customer support, software updates, and improvement of the Platform and
related Services in accordance with this Privacy Policy. Calls with SCRENR may be recorded or
monitored for training, quality assurance, customer service, and reference purposes.

Technology Data: We use common information-gathering tools, such as log files and similar
technologies to automatically collect information, which may contain Personal Data from your
computer or mobile device as you navigate our Platform or interact with emails or other
communications We have sent you. The information We collect may include your IP address (or
proxy server), device and application identification numbers, Internet service provider and/or
mobile carrier, the pages and files you viewed, your searches, your operating system and system
configuration information, and date/time stamps associated with your usage. This information is
used to analyze overall trends, help Us provide and improve our Services, and ensure the proper
functioning and security of the Platform and Services.

‍How Will SCRENR Use Your Personal Data?

SCRENR processes your Personal Data based on legitimate business interests, the fulfillment of our
Services to you, compliance with our legal obligations, and/or your consent. We only use or disclose
your Personal Data when it is legally mandated or where it is necessary to fulfill those purposes
described in this Privacy Policy. Where required by law, We will ask for your prior consent before
disclosing your Personal Data to a third party.

More specifically, SCRENR processes your Personal Data for the following legitimate business purposes:
-To provide Services;
-To fulfill our obligations to you under the Patient User Terms of Use;
-To communicate with you about and manage your User Account;
-To properly store and track your data within our system;
-To respond to lawful requests from public and government authorities, and to comply with
applicable state/federal law, including cooperation with judicial proceedings and court orders;
-To protect our rights, privacy, safety, or property, and/or that of you or others by providing
proper notices, pursuing available legal remedies, and acting to limit our damages;
-To handle technical support and other requests from you;
-To enforce and ensure your compliance with our Patient User Terms of Use or the terms of any
other applicable services agreement We have with you;
-To manage and improve our operations and the Platform, including the development of
additional functionality;
-To manage payment processing;
-To evaluate the quality of service you receive, identify usage trends, and improve your user
experience;
-To keep our Platform safe and secure;
-To send you information about changes to our terms, conditions, and policies;To enable you to connect with or share Personal Data with the Provider User you authorize, which enables that Provider User to monitor your progress and overall condition as they deem
appropriate.

‍Where Is Personal Data Processed?

The Personal Data We collect through the Platform will be stored on secure servers in the United States.
Personal Data may be transmitted to third parties, which parties may store or maintain the data on their
secure servers. These third parties are not permitted to transfer your Personal Data outside of the
United States. The App is “native” to your device, meaning information you enter into the App may also
be stored directly on the device that you use to access and enter information into the App.

‍With Whom Does SCRENR Share Personal Data?

We may share your personal information with the following categories of individuals/entities:
-Business Partners and Vendors: We share Personal Data with a limited number of partners,
service providers, and other persons/entities who help run our business (“Business Partners”).
Specifically, We may employ third-party companies and individuals to facilitate our Services,
provide Services on our behalf, perform Service-related functions, or assist Us in analyzing how
our Services are used. Our Business Partners are contractually bound to protect your Personal
Data and to use it only for the limited purpose(s) for which it is shared. Business Partners’ use of
Personal Data may include, but is not limited to, the provision of services such as data hosting,
IT services, customer services, and payment processing.
-Our Advisors: We may share your Personal Data with third parties that provide advisory services
to SCRENR, including, but not limited to, our lawyers, auditors, accountants, and banks
(collectively, “Advisors”). Personal Data will only be shared with Advisors if SCRENR has a
legitimate business interest in the sharing of such data.
-Provider Users: To use the Services, Patient Users must be affiliated with one or more Provider
Users. As part of the Services, We will share your Personal Data with your specified Provider
User(s). If at any point you want to deny access to one or more Provider Users, you can do so by
emailing support@screnrhealth.com.
-Third Parties Upon Your Direction or Consent: You may direct SCRENR to share your Personal
Data with third parties. Upon your request and consent, We may share such Personal Data with
those third parties that you identify.
-Third Parties Pursuant to Business Transfers: In the event of a reorganization, merger, sale,
joint venture, assignment, transfer, or other disposition of all or any portion of SCRENR’s
corporate entity, assets, or stock (including in connection with any bankruptcy or similar
proceedings), We may share your Personal Data with a third party.
-Government and Law Enforcement Authorities: If reasonable and necessary, We may share
your Personal Data to (i) comply with legal processes or enforceable governmental requests, or
as otherwise required by law; (ii) cooperate with third parties in investigating acts or omissions
that violate this Privacy Policy or the Patient User Terms of Use; or (iii) bring legal action against someone who may be violating the Patient User Terms of Use or who may be causing intentional or unintentional injury or interference to the rights or property of SCRENR or any third party, including other users of our Services.

‍How Long Does SCRENR Retain Personal Data?

SCRENR retains your Personal Data only as long as necessary and as required for our business
operations, the provision of Services, archival purposes, and/or to satisfy legal requirements. The exact
period of retention will depend on: (i) the amount, nature, and sensitivity of the Personal Data; (ii) the
personal risk of harm for unauthorized use or disclosure; (iii) the purposes for which We process your
Personal Data, including whether those purposes can be achieved through other means; and (iv)
business operations and legal requirements. In general, SCRENR strives to retain your data for no longer
than allowed by applicable state and federal law after your Account is closed (the “Retention Period”);
however, the above factors may extend or decrease this Retention Period.

At the end of the applicable Retention Period, We will remove your Personal Data from our databases
and will require that our Business Partners remove any identifiable Personal Data from their databases.
If there is any data that We are unable to delete entirely from our systems for technical reasons, We will
put in place appropriate measures to prevent any further processing of such data. Please note that once
We disclose your Personal Data to third parties, We may not be able to access that Personal Data and
We cannot force the deletion or modification of such information by third parties.

SCRENR and its Business Partners reserve the right to continue using de-identified data indefinitely, even
after Personal Data has been removed from SCRENR’s databases. We may continue to disclose de-
identified data to third parties in a manner that does not reveal personal information, as described in
this Privacy Policy. Our continued use of de-identified data will comport with applicable law.

‍What Happens to Personal Data Submitted by Minors?

‍SCRENR does not knowingly collect Personal Data from individuals under the age of 18. Additionally, our
Services are not directed to individuals under the age of 18. We request that these individuals not
provide Personal Data to Us. If We learn that Personal Data from users under the age of 18 has been
collected, We will deactivate the User Account associated with that data and take reasonable measures
to promptly delete such data from our records. If you are aware of a user under the age of 18 accessing
the Services or Platform, please contact Us at support@screnrhealth.com.

If you are a resident of California under the age of 18 and have registered for a User Account with Us,
you may ask Us to remove content or information that you have posted to our Platform.

PATIENT USER RIGHTS

‍What Rights Do Patient Users Have Concerning Their Personal Data?

‍As a user of SCRENR’s Services and Platform, you have certain rights relating to your Personal Data.
These rights are subject to local data protection and privacy laws, and may include the right to:
-Access Personal Data held by SCRENR;
-Erase/delete your Personal Data, to the extent permitted by applicable data protection and privacy laws and to the extent technologically feasible;
-Receive communications related to the processing of your Personal Data;
-Restrict the processing of your Personal Data to the extent permitted by law;
-Object to the further processing of your Personal Data, including the right to object to marketing;
-Request that your Personal Data be transferred to a third party, if possible;
-Receive your Personal Data in a structured, commonly used, and machine-readable format;
and/or
-Rectify inaccurate personal information and, taking into account the purpose of processing the Personal Data, ensure it is complete.

Where the processing of your Personal Data by SCRENR is based on consent, you have the right to
withdraw that consent at any time. If you would like to withdraw your consent or exercise any of the
above rights, please Contact Us at support@screnrhealth.com

‍How Can Patient Users Update, Correct, or Delete Personal Data or Their User Account?

‍You have the right to request restrictions on uses and disclosures of your Personal Data. While We are
not required to agree to all restriction requests, We will attempt to accommodate reasonable requests
when appropriate.

You may change your email address and other contact information by accessing your SCRENR User
Account. If you need to make changes or corrections to other information, you may contact Us at
support@screnrhealth.com. In order to comply with certain requests to limit the use of your Personal
Data, We may need to terminate your ability to access and/or use some or all of the Services. BY
REQUESTING TO LIMIT THE USE OF YOUR PERSONAL DATA OR DELETE PERSONAL DATA, YOU
ACKNOWLEDGE AND AGREE THAT SCRENR WILL NOT BE LIABLE TO YOU FOR ANY CORRESPONDING
LIMITATION IN THE SCOPE OF SERVICES OR TERMINATION OF SERVICES AS NECESSARY TO COMPLY
WITH YOUR REQUEST.

You have the right to request the deletion of any Personal Data from your User Account or the SCRENR
Platform. To request the deletion of your Personal Data, please email Us at support@screnrhealth.com
and include a description of the Personal Data you would like removed. We will respond to all requests
for data deletion as soon as reasonably possible.

Should you decide to delete your User Account entirely, you may do so by emailing Us at
support@screnrhealth.com. By terminating your User Account, you agree that you will not be able to
access any information previously contained in your User Account. You further understand that it may
not be technologically possible to remove all of your Personal Data from our systems. While We will use
reasonable efforts to remove your Personal Data, the need to back up our systems to protect
information from inadvertent loss means a copy of your Personal Data may exist in a non-erasable form
that will be difficult or impossible for Us to locate or remove.

PROTECTION OF PERSONAL DATA

‍Is Personal Data Secure?

‍SCRENR understands the importance of data confidentiality and security. We use a combination of
reasonable physical, technical, and administrative security controls to: (i) maintain the security and
integrity of your Personal Data; (ii) protect against any threats or hazards to the security or integrity of
your Personal Data; and (iii) protect against unauthorized access to or use of such information in our
possession or control that could result in substantial harm to you.

While SCRENR uses reasonable security controls, WE CANNOT GUARANTEE OR WARRANT THAT SUCH
TECHNIQUES WILL PREVENT UNAUTHORIZED ACCESS TO YOUR PERSONAL DATA. SCRENR IS UNABLE TO
GUARANTEE THE SECURITY OR INTEGRITY OF PERSONAL DATA TRANSMITTED OVER THE INTERNET, AND THERE IS NO GUARANTEE THAT YOUR PERSONAL DATA WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. ACCORDINGLY, WE DO NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY PERSONAL DATA YOU TRANSMIT TO US. YOU ASSUME THE RISK THAT UNAUTHORIZED ENTRY OR USE, HARDWARE OR SOFTWARE FAILURE, AND OTHER FACTORS MAY COMPROMISE THE SECURITY OF YOUR PERSONAL DATA AT ANY TIME.

‍What Safeguards Does SCRENR Have in Place to Secure Personal Data?

SCRENR stores Personal Data on secured servers and uses a combination of technical, administrative,
and physical safeguards to protect your personal information. Such safeguards include, but are not
limited to, authentication, encryption, backups, and access controls.

‍How Can Patient Users Protect Their Personal Data?

You are solely responsible for preventing unauthorized access to your devices and your User Account by
protecting your account credentials and limiting access to your devices. SCRENR has no access to or
control over your device’s security settings, and it is your responsibility to implement any device-level
security features and protections you feel are appropriate (e.g., password protection, encryption,
remote wipe capability). We recommend that you take all appropriate steps to secure any device that
you use to access our Services and Platform.

Please note that SCRENR will never send you an email requesting confidential information, such as
account numbers, usernames, passwords, or Social Security Numbers. If you receive a suspicious email
from SCRENR, please notify Us at support@screnrhealth.com.

Further, if you know of or suspect any unauthorized use or disclosure of your User Account information
or any other security concern, please notify SCRENR immediately.

‍What If SCRENR Experiences a Data or Security Breach?

SCRENR takes the security of your Personal Data seriously. In the event of a data or security breach,
SCRENR will take the following actions: (i) promptly investigate the security incident, validate the root
cause, and, where applicable, remediate any vulnerabilities within SCRENR’s control which may have
given rise to the security incident; (ii) comply with laws and regulations directly applicable to SCRENR in
connection with such security incident; (iii) as applicable, cooperate with any affected SCRENR user or
client in accordance with the terms of SCRENR’s contract with such user or client; and (iv) document and record actions taken by SCRENR in connection with the security incident and conduct a post-incident
review of the circumstances related to the incident and actions/recommendations taken to prevent
similar security incidents in the future. SCRENR will notify you of any data or security breaches as
required by and in accordance with applicable law.

ADVERTISING, MARKETING, AND TRACKING

‍Does SCRENR Send Marketing or Advertisement Materials?

‍SCRENR may use your Personal Data to contact you with newsletters, marketing, or promotional
materials and other information that may be of interest to you. You may opt out of receiving any
marketing or advertisement materials from SCRENR at any time by following the unsubscribe link or by
contacting Us.

‍Can Patient Users Opt Out of Receiving Communications from SCRENR?

We may send communications, including emails, to you regarding your User Account and the Services or
Platform. You can choose to filter any User Account, Services, and Platform emails using your email
settings, but We do not provide an option for you to opt out of these communications.If you consent to receive marketing or other communications not related to your User Account or the
Services/Platform, We will provide you with the option to opt out of such marketing communications
within the applicable message.

‍What Is SCRENR’s Cookie Policy?

Cookies are small files that a web server sends to your computer or device when you visit a web
application that uses cookies to keep track of your activity on that site. Cookies also exist within
applications when a browser is needed to view or display certain content within the application. Cookies
hold a small amount of data specific to a web application, which can later be used to help remember
information you entered in the application (like your email, username or it can be an authentication
token), preferences selected, and movement within the application. We use cookies and other
technologies to, among other things, better serve you with more tailored information, and to facilitate
efficient and secure access to the Services.

Our cookies do not, by themselves, contain Personal Data. Further, We do not combine the general
information collected through cookies with any other Personal Data to identify you. However, We do
use cookies to identify that your web browser has accessed aspects of the Services and may associate
that information with your User Account (if one exists).

Presently, SCRENR uses cookies to store authentication token and session ID. In addition, SCRENR may
also collect information using pixel tags, web beacons, clear GIFs, or other similar technologies. This
information may be used in connection with website pages and HTML-formatted email messages to,
among other things, track the actions of users and email recipients and compile statistics about usage
and response rates.

‍How Can Patient Users Opt Out of Cookies?

‍If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you
enable a do not track signal or otherwise configure your browsers to prevent Us from collecting cookies,
you will need to reenter your login information each time you visit the login page. You may also be
unable to take advantage of some of the Services.

‍Do Not Track Disclosure

Some web browsers may transmit do not track (“DNT”) signals to websites with which the user
communicates. To date, there is no industry standard for DNT and users cannot know how a given
company responds to a DNT signal they receive from browsers. SCRENR is committed to remaining
apprised of DNT standards. However, SCRENR does not support DNT browser settings and does not
currently participate in any DNT frameworks that would allow SCRENR to respond to signals or other
mechanisms regarding the collection of your personal information.