1. Introduction

a. Purpose of the Privacy Policy

This Privacy Policy governs the manner in which Elvo AI, Inc. ("Elvo," "we," "us," or "our") collects, uses, maintains, and discloses information collected from users (referred to as "you" or "your") of the Elvo Health mobile application and websites ("the App" or "the Sites"). The purpose of this Privacy Policy is to inform you about the types of information we collect, how we use and protect that information, and the choices you have regarding the information you provide us.

b. Scope of the Privacy Policy

This Privacy Policy applies to the App and all related services offered by Elvo. It outlines our practices regarding the collection, storage, use, and disclosure of personal and non-personal information in connection with your use of the App. This Privacy Policy does not cover the practices of third-party services or websites that may be linked to or integrated with the App.

c. Your Consent

By accessing or using the App, you consent to the collection, use, storage, and disclosure of your information as described in this Privacy Policy. If you do not agree with any aspect of this Privacy Policy, please refrain from using the App.

If you have any questions or concerns about this Privacy Policy, please refer to the "Contact Us" section of this Privacy Policy.

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2. Information We Collect

a. Personal Information

We collect certain personal information from you when you use the App. This information may include:

• First Name: We collect your first name to personalize your experience within the App and to address you appropriately in our communications.
• Last Name: Your last name is collected to further personalize your experience and facilitate accurate identification within the App.
• Mobile Number: We collect your mobile number to provide you with essential notifications, send SMS to deep link between Family and Loved One accounts, updates, and secure communication related to your account and the services offered by the App.
• Date of Birth: Your date of birth is collected to ensure that you meet any age restrictions for using certain features of the App and to provide age-appropriate content. We may also aggregate and analyze this data on an anonymized basis to improve our services and enhance user experience.
• Email Address: Your email address is collected to establish communication with you, send important updates, provide account-related information, and facilitate password reset if needed.
• Location: The App utilizes GPS technology via Google Maps to collect and monitor your location. We may collect precise location information to provide location-based services and enhance your user experience.

We collect this personal information with your consent and only to the extent necessary for the purposes outlined in this Privacy Policy. You have the choice to provide or withhold this information, but please note that use of the App may not be granted without providing the information as detailed above. Certain features or services within the App may require it for proper functionality.

We handle your personal information in accordance with applicable data protection laws and take appropriate measures to protect its confidentiality and integrity. We do not sell, rent, or lease your personal information to third parties unless we have obtained your explicit consent or are required by law to do so.

b. Non-Personal Information

In addition to personal information, we may also collect non-personal information when you use the App. This information is not directly associated with your individual identity and may include:

• Gender: We may collect your gender to better understand the demographics of our user base and to provide a more personalized experience within the App.
• Type of Cognitive Impairment: We may collect information about the type of cognitive impairment you have so we can better understand the users of our application.
• Ethnicity: We may collect information about your ethnicity to better understand the diversity of our user base and to improve our services.
• Health Data: We may collect medication-related data, such as medication names, types, and dosage information that you voluntarily provide to offer you specific functionality in relation to the App.
• Task Data: We may collect task data, such as task names and related information that you voluntarily provide to offer you specific functionality in relation to the App.
• Appointment Data: We may collect appointment-related data such as appointment names, appointment locations, and related information that you voluntarily provide to offer you specific functionality in relation to the App.
• Aggregated Statistics: We collect and analyze aggregated statistics to better understand user behavior, preferences, and trends. This information is anonymized and used to improve the App's features, functionalities, and overall user experience. We may also aggregate and analyze Health Data, Task Data, and Appointment Data on an anonymized basis to improve our services and enhance user experience.
• App Usage Data: We collect information about how you use the App, such as the number of times the App is launched, screens visited, buttons clicked, or interactions within the App. This data helps us analyze usage patterns, identify areas for improvement, and enhance the overall user experience.
• Aggregated Feedback: We may collect and aggregate feedback, reviews, or ratings provided by users to gain insights into the App's strengths, weaknesses, and areas for improvement. This information is anonymized and used to enhance the App's features and functionalities.

We may also collect other data to personalize the LLM responses via our intake features. All information we collect will fall under the terms of this Privacy Policy.

c. Cookies and Similar Technologies

The App may use cookies, beacons, and similar technologies to collect certain information automatically as you use and navigate through the App. These technologies allow us to gather non-personal information, such as:

• Device Information: We may collect device-specific information, including the type of device you are using, unique device identifiers, operating system version, and mobile network information. This data helps us optimize the App's performance and provide you with a seamless user experience.
• Log Information: Our servers automatically record certain log information when you access or use the App. This information may include your IP address, browser type, referring/exit pages, clickstream data, and timestamps. We use this information for purposes such as analyzing trends, administering the App, and gathering demographic information.
• Analytics: We may use third-party analytics tools to collect information about your usage of the App. This includes information such as the features you interact with and the time spent on the App. This data helps us understand user behavior and improve the App's functionality and performance.

Please note that you have the option to disable or manage cookies and other similar technologies through your device or browser settings. However, doing so may affect the functionality and performance of the App and limit your ability to use certain features.

Remember that personal information collected through cookies and similar technologies may be combined with other data we have collected about you, as described in Section 2.a. We treat such combined information as personal information in accordance with this Privacy Policy.

It is important to note that we do not use cookies and similar technologies to collect or track any personally identifiable information without your explicit consent.

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3. How We Use Your Information

a. Providing and Improving the Services

We use the personal information we collect to provide and improve the services offered through the App. The primary purposes for which we use your information include:

• Account Creation and Management: We may use your personal information, such as your first name, last name, email address, and mobile number, to create and manage your user account. This enables you to access and use the features and functionality of the App.
• Service Delivery and Customization: We use your personal information to deliver the services you request through the App. This may include processing your orders, providing customer support, and personalizing your experience within the App based on your preferences and usage patterns. This also includes collecting location information to provide location-based services and enhance your user experience.
• Communication: We may use your email address and mobile number to send you important notifications, such as updates, account-related information, and transactional messages. These communications are necessary for the proper functioning and administration of the App.

b. Communication and Support

We may use the personal information you provide to communicate with you and provide customer support. This includes:

• Responding to Your Inquiries: If you contact us with a question, feedback, or support request, we may use your personal information to respond to and address your inquiries or concerns.
• Service-related Communications: We may send you service-related communications, such as notifications about changes to our terms or policies, security alerts, or updates regarding the App's features and functionality. These communications are essential for the proper operation and use of the App.

c. Personalization and User Experience

We strive to enhance your user experience within the App by personalizing the content and features based on your preferences and interests. This includes:

• Customized Content: We may use your personal information to tailor the content and user experience within the App. This personalization aims to provide you with a more relevant and engaging experience.
• User Preferences: By analyzing your usage patterns, interactions, and feedback, we may use your personal information to understand how to make the App user experience better.

d. Analytics and Measurement

We may use both personal and non-personal information for analytics and measurement purposes. This includes:

• Performance Evaluation: We analyze aggregated data, including your personal information, to evaluate the performance of the App, measure its effectiveness, and identify areas for improvement.
• Usage and Trends Analysis: By examining usage patterns, user behavior, and other relevant metrics, we gain insights into how the App is used, which features are popular, and how we can enhance the overall user experience.

e. Marketing and Advertising

We may use your personal information, with your consent where required, for marketing and advertising purposes. This includes:

• Direct Marketing Communications: With your permission, we may send you promotional emails, newsletters, or other marketing communications to inform you about new features, offers, updates, or events related to the App. You have the option to opt out of receiving such communications at any time.

We comply with applicable laws and regulations regarding marketing communications and targeted advertising, and we respect your choices and preferences regarding such communications.

f. Legal Purposes

We may use your personal information for legal purposes, including:

• Compliance with Applicable Laws: We may process your personal information to comply with applicable laws, regulations, legal processes, or enforceable governmental requests. This includes fulfilling our legal obligations and responding to legal claims or requests from authorities.
• Protection of Rights and Safety: We may use your personal information to protect the rights, safety, and security of our users, the App, and our organization. This includes detecting and preventing fraud, unauthorized access, or other illegal activities.
• Dispute Resolution: In the event of a dispute or legal claim involving you and the App, we may process your personal information to facilitate the resolution of such disputes, whether through negotiation, mediation, arbitration, or litigation.
• Legal Defense: If necessary, we may process your personal information to defend our legitimate interests, exercise our legal rights, or pursue available legal remedies.
• Compliance with Court Orders: We may disclose your personal information in response to court orders, subpoenas, or other legal processes if required to do so by law.

It is important to note that we will only use your personal information for legal purposes to the extent permitted or required by applicable laws and regulations.

If you have any further questions or concerns about the use of your personal information for legal purposes, please feel free to reach out to us using the contact information provided in the "Contact Us" section of this Privacy Policy.

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4. Information Sharing and Disclosure

We understand the importance of protecting your personal information and strive to handle it with utmost care. This section explains how we may share and disclose your information in certain circumstances:

a. Third-Party Service Providers

We may engage trusted third-party service providers to perform various functions on our behalf. These service providers may have access to your personal information for the purpose of assisting us in delivering and improving the services provided through the App. However, they are strictly bound by confidentiality obligations and are not permitted to use or disclose your personal information for any other purpose.

b. Legal Requirements

We may disclose your personal information if required to do so by law or in good faith belief that such action is necessary to:

1. Comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
2. Protect and defend our rights, safety, and property, as well as the rights, safety, and property of our users or others.
3. Detect, prevent, or address fraud, security breaches, or technical issues.

c. Business Transfers

In the event of a merger, acquisition, reorganization, or sale of our business or assets, your personal information may be transferred or disclosed to the acquiring entity or parties involved as part of the transaction. We will notify you via prominent notice on the App and obtain your consent if required by applicable laws.

d. Aggregated and Anonymized Data

We may aggregate and anonymize your personal information to create statistical or aggregated data that does not directly identify you. This data may be used for various purposes, including research, analysis, business intelligence, and improving the services. This aggregated and anonymized data may be shared with third parties, such as partners, advertisers, or affiliates, for lawful purposes.

Please note that we will not sell, rent, or otherwise disclose your personal information to third parties for their direct marketing purposes without your explicit consent.

While we take reasonable precautions to protect your personal information, we cannot guarantee the absolute security of your data during its transmission or storage. We implement industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction.

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5. Your Rights and Choices

We respect your rights and provide you with choices regarding the collection, use, and disclosure of your personal information. In this section, we outline the rights and choices available to you:

a. Access and Correction

You have the right to access and update your personal information held by us. If you would like to review, correct, or update any of your personal information, please use the settings within the application or contact us using the information provided in the "Contact Us" section. We will make reasonable efforts to respond to your request in a timely manner.

b. Data Portability

Subject to applicable laws, you have the right to request the portability of your personal information. If you wish to obtain a copy of your personal information held by us in a structured, commonly used, and machine-readable format, please reach out to us using the contact details provided in this Privacy Policy.

c. Opting Out

You have the choice to opt out of certain uses and disclosures of your personal information. You may choose not to provide certain personal information or limit the collection and use of your information by adjusting your device settings or preferences within the App. However, please note that opting out may impact your ability to access the App or certain features or services provided.

d. Account Deletion

If you no longer wish to use the App and want your personal information to be deleted from our systems, please contact us using the provided contact information or use the delete functionality within the App. We will make reasonable efforts to delete your personal information, subject to any legal obligations or legitimate interests that require its retention.

e. Marketing Communications

You have the right to manage your preferences regarding marketing communications from us. You can opt out of receiving promotional emails or newsletters by following the unsubscribe instructions provided in the email or by adjusting your communication preferences within the App.

f. Do Not Track Signals

We currently do not respond to "Do Not Track" signals or similar mechanisms that indicate your preference to disable tracking of your online activities.

g. Privacy Settings

Where applicable, we provide you with privacy settings and controls within the App that allow you to manage and customize the collection, use, and sharing of your personal information. We encourage you to review and adjust these settings based on your preferences.

Please note that while we strive to accommodate your rights and choices, there may be limitations or exceptions as permitted by applicable laws and regulations.

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6. Data Retention

We will retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The specific retention periods for different categories of personal information may vary based on legal requirements, contractual obligations, or our operational needs.

a. Retention Period

We will retain your personal information for the duration necessary to fulfill the purposes outlined in this Privacy Policy or as required to comply with our legal obligations, resolve disputes, enforce our agreements, or protect our rights. Once the retention period expires, we will securely delete or anonymize your personal information, unless we are required by law to retain it for a longer period.

b. Data Deletion and Anonymization

Upon the expiration of the retention period or at your request, we will take appropriate measures to delete or anonymize your personal information to ensure it is no longer identifiable or recoverable.

Please note that even after the deletion or anonymization of your personal information, residual copies may remain in our backup systems or archives for a limited period of time if permitted by law or necessary for legitimate business purposes.

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7. Data Security

We take the security of your personal information seriously and implement reasonable safeguards to protect it from unauthorized access, disclosure, alteration, or destruction. We have implemented technical, administrative, and physical measures to ensure the confidentiality, integrity, and availability of your personal information.

a. Security Measures

We employ industry-standard security practices to safeguard your personal information. These measures include:

• Encryption: We use encryption techniques to protect your personal information during transmission and storage. This helps prevent unauthorized parties from accessing or intercepting your information.
• Access Controls: We restrict access to your personal information to authorized personnel who have a legitimate need to access it. Access is granted based on the principle of least privilege, ensuring that only necessary individuals can access your information.
• Data Minimization: We only collect and retain the personal information that is necessary for the purposes outlined in this Privacy Policy. We take steps to minimize the collection and storage of sensitive information.
• Secure Infrastructure: We maintain secure infrastructure, including firewalls, intrusion detection systems, and regular security audits, to protect against unauthorized access to our systems.

Despite these measures, please be aware that no security system is completely foolproof. We cannot guarantee the absolute security of your personal information. It is important to keep in mind that any transmission of data over the internet or any method of electronic storage carries inherent risks.

b. Data Breach Procedures

In the event of a data breach that affects your personal information, we have implemented procedures to respond promptly and effectively. These procedures include:

• Incident Response: We will promptly investigate the breach, mitigate its impact, and take necessary actions to prevent similar incidents in the future.
• Notification: If required by applicable laws, we will notify you and the appropriate regulatory authorities about the data breach in a timely manner. We will provide you with information about the nature of the breach, the types of personal information affected, and any recommended steps you can take to protect yourself.

c. Children's Privacy

Our services are not intended for children under the age of 13 (or a higher age threshold as required by applicable laws). We do not knowingly collect personal information from children without appropriate parental or guardian consent. If we become aware that we have inadvertently collected personal information from a child without proper consent, we will take steps to delete the information as soon as possible. If you believe that we may have collected personal information from a child without consent, please contact us using the information provided in the "Contact Us" section of this Privacy Policy.

We continuously review and update our security practices to adapt to evolving threats and technologies. However, no security measures are foolproof, and we cannot guarantee the absolute security of your personal information. We encourage you to take appropriate steps to protect your personal information, such as using strong and unique passwords and keeping them confidential.

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8. International Data Transfers

As a global mobile application, we may transfer and process your personal information outside of your country of residence. When we transfer your personal information to other countries, we take appropriate measures to ensure that your information is protected in accordance with applicable data protection laws.

a. Cross-Border Data Transfers

By using the App and providing us with your personal information, you understand and consent to the transfer of your information to countries outside of your country of residence. These countries may have different data protection laws than those in your jurisdiction.

When we transfer your personal information to other countries, we ensure that adequate safeguards are in place to protect your information. These safeguards may include implementing standard contractual clauses approved by the relevant authorities or relying on other legally recognized mechanisms to ensure an adequate level of protection for your personal information.

We take appropriate measures to ensure the security and confidentiality of your personal information during international transfers. These measures may include assessing the privacy practices of third parties involved in the transfer, entering into contractual arrangements, or implementing other safeguards to protect your rights and interests.

By using the App and providing your personal information, you consent to the transfer, processing, and storage of your information as described in this Privacy Policy.

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9. Third-Party Links and Services

The App may contain links to third-party websites or services that are not owned or controlled by us. This Privacy Policy applies solely to the information collected by our App, and we are not responsible for the privacy practices of third-party websites or services.

a. Third-Party Integrations

The App may integrate with third-party services or platforms to enhance your experience or provide additional functionalities. These third-party integrations may collect and process your personal information in accordance with their own privacy policies. We encourage you to review the privacy policies of these third-party services to understand how they handle your personal information.

The apps we may integrate with include but are not limited to:

• Google Maps
• Firebase
• Twilio
• OneSignal
• Smartlook
• Byga
• TeamSnap

When you navigate away from our App to a third-party website or engage with third-party services, our Privacy Policy no longer applies. We encourage you to read the privacy policies and terms of service of any third-party websites or services you interact with to understand their practices.

We are not responsible for the privacy practices or content of third-party websites or services, and we do not endorse or make any representations about them. Any interactions you have with third-party websites or services are solely between you and the third party.

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10. Updates to the Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or industry standards. We will notify you of any material changes to this Privacy Policy by posting the updated version on our website or through other appropriate communication channels. The "Effective Date" at the top of this Privacy Policy indicates when it was last updated.

a. Notification of Changes

We will make reasonable efforts to notify you of any material changes to this Privacy Policy. We may do so by sending an email to the address associated with your account or by posting a notice within the App. It is important that you review the updated Privacy Policy to ensure you understand the changes made.

b. Effective Date

The effective date of this Privacy Policy indicates the date when it was last revised. We encourage you to check the effective date regularly to stay informed about the most recent version of the Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your personal information. Your continued use of the App after the posting of any updated Privacy Policy constitutes your acceptance of the changes.

If you disagree with any changes made to this Privacy Policy, you may choose to discontinue using the App and request the deletion of your personal information, as outlined in the "Your Rights and Choices" section.

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11. Contact Us

If you have any questions, concerns, or feedback regarding this Privacy Policy or our privacy practices, please contact us using the following information:

a. Contact Information

• Name: Elvo Health
• Email: info@elvohealth.com

b. Questions and Concerns

If you have any questions or concerns about our privacy practices or how your personal information is handled, please feel free to reach out to us using the contact information provided above. We will make reasonable efforts to respond to your inquiry and address any concerns in a timely and appropriate manner.

We value your privacy and are committed to resolving any issues or concerns you may have regarding the protection of your personal information.

Please note that if you are contacting us regarding a specific request, such as accessing or updating your personal information, please provide sufficient details to help us locate your information and process your request efficiently.

We appreciate your feedback and suggestions as we continually strive to improve our services and protect your privacy.

Thank you for your trust and cooperation.

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