Privacy Policy

1. What Information Do We Collect?

Personal information you disclose to us

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

We collect personal information that you voluntarily provide to us when you register for the Services, 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:

• names
• email addresses
• usernames
• health documents and records you upload (e.g., lab results, prescriptions, clinical notes, medical imaging, visit summaries)

Sensitive Information. We may process health-related information that you voluntarily provide to us through the App. Health information is considered sensitive under certain privacy laws and is treated with additional safeguards in accordance with applicable health privacy regulations. We only collect and process such information as necessary to provide our health records management service and with your explicit consent.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Apple. You may find their privacy notice link(s) here: https://www.apple.com/legal/privacy/en-ww/. We only receive limited metadata about your purchases from Apple after the transaction is completed.

Social Media Login Data. We may provide you with the option to register with us using your existing Google or Apple account details. If you choose to register in this way, we will collect your account ID, name, and email address with your consent.

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.

The information we collect includes:

• 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. 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, and hardware settings).

Information collected through our App

In Short: We collect information regarding your mobile device and user-provided content when you use our App.

If you use our App, we also collect the following information:

• Mobile Device Data. We collect mobile device information such as device ID and type. This information is primarily needed to maintain the security and operation of our App, for troubleshooting, and for our internal analytics and reporting purposes.
• User-Provided Content. We collect and process health documents, medical records, and related content that you voluntarily upload to our App for storage, organization, and management.

This information is primarily needed to maintain the security and operation of our App, for troubleshooting, and for our internal analytics and reporting purposes.

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 facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service, specifically to store, organize, and manage your health documents and records, and provide health records management features.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our services, changes to our terms and policies, and other similar information.
• To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. What Legal Bases Do We Rely On To Process Your Information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent in Section 8.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of another person.

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

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., 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, for example:

• 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 victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

4. When And With Whom Do We Share Your Personal Information?

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

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. They will retain the data for no longer than a period of one year and will be subject to the same terms as our use. The categories of third parties we may share personal information with are as follows:

• Data Analytics Services
• Data Storage Service Providers

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

• Business Transfers. We may share 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.

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, healthcare record retention requirements, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

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.

If you suspect any unauthorized access to your account or have any security concerns, please contact us immediately at hello@frontierintelligence.io.

7. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 13 years of age.

We do not knowingly solicit data from or market to children under 13 years of age. By using the Services, you represent that you are at least 13 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 13 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 13, please contact us at hello@frontierintelligence.io.

For health-related features, additional age or parental consent requirements may apply depending on your jurisdiction.

8. What Are Your Privacy Rights?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right:

• To request access and obtain a copy of your personal information
• To request rectification or erasure of your personal information
• To restrict the processing of your personal information
• To data portability (if applicable)
• To object to processing of your personal information
• To withdraw consent at any time where we are relying on consent to process your personal information

If you wish to exercise any of these rights, please contact us at hello@frontierintelligence.io. We will respond to your request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us at hello@frontierintelligence.io.

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.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.
• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

9. Controls For Do-Not-Track Features

In Short: We do not currently respond to Do-Not-Track browser signals.

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.

Instead of using DNT signals, we use the following measures to protect your privacy:

• We do not use cookies for tracking purposes.
• We do not share your personal information with third parties for marketing purposes.
• We give you control over your data through account settings and data access requests.
• We use encryption to protect your data in transit and at rest.

If you have any questions about our tracking practices or how we protect your privacy, please contact us at hello@frontierintelligence.io.

10. Do United States Residents Have Specific Privacy Rights?

In Short: If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you are granted specific rights regarding access to your personal information.

We collect various types of personal information to provide and improve our services. The following table outlines the categories of personal information we collect:

We will use and retain the collected personal information as needed to provide the Services or for:

• Category A — As long as the user has an account with us
• Category F — As long as the user has an account with us
• Category K — As long as the user has an account with us
• Category L — As long as the user has an account with us

Category K information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels
• Participation in customer surveys or contests
• Facilitation in the delivery of our Services and to respond to your inquiries

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in Section 4.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.

California Residents

The California Consumer Privacy Act (CCPA) provides you with rights regarding your personal data:

• Right to Know: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
• Right to Delete: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
• Right to Opt-Out of Sales: You have the right to opt-out of the sale of your personal information. However, we do not sell personal information.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

Colorado, Connecticut, Utah, and Virginia Residents

Recent laws in Colorado, Connecticut, Utah, and Virginia provide similar rights:

• Right to Access: You have the right to confirm whether or not we are processing your personal data and to access such data.
• Right to Correction: You have the right to correct inaccuracies in your personal data.
• Right to Deletion: You have the right to delete personal data provided by or obtained about you.
• Right to Data Portability: You have the right to obtain a copy of your personal data in a portable and readily usable format.
• Right to Opt-Out: You have the right to opt out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

How to Exercise Your Rights

To exercise any of these rights, please submit a verifiable consumer request to us by emailing us at hello@frontierintelligence.io.

We will respond to your request within the timeframe required by applicable law, which is generally within 45 days of receiving your request. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

Personal Information Sales

In the preceding twelve (12) months, we have not sold any personal information.

11. Do Other Regions Have Specific Privacy Rights?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).

This privacy notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

• Offer you the products or services that you want
• Respond to or help with your requests

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us using the contact details provided in Section 14.

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the Office of New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us using the contact details provided in Section 14.

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

12. 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 and the updated version will be effective as soon as it is accessible. 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.

13. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may contact us:

By email: hello@frontierintelligence.io

By mail:
Frontier Intelligence, Inc.
228 Park Ave S PMB 55927
New York, NY 10003
United States

14. 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@frontierintelligence.io.