Privacy

Privacy Policy – Catalia Health Platform updated June 2016

This Privacy Policy applies to your use of the Mabu Wellness Companion Robot and its related hosting and data services in the Catalia Health Secure Cloud (the “Mabu HCR”), the website located at and www.cataliahealth.com (including the mobile-optimized versions of such websites, the “Sites”) the owned by Catalia Health Inc. (“we” or “us”), and our mobile short message service (SMS) text messaging application (the “SMS Application”). The Mabu HCR, the Sites, and the SMS Application are referred to together as the “Platform”. If you do not agree to the terms of this Privacy Policy, including with respect to (a) the collection and processing of Health Information (as defined below), (b) the collection and processing of your geo-location data (c) our cookies policy, (d) cross-border transfer of data and (e) marketing, please do not use and set up the Mabu HCR or use the Sites.

We have the highest regard for your privacy and personal information and realize that the success of our service depends on the trust that users have in the way we handle their personal information. This policy sets out our commitments and explains the rights that you have with respect to your personal information.

Information Collection and Use

Catalia Health respects your right to privacy. While you may use some of the functionality of the Sites without registration, use of the Platform and certain tools of the Sites require registration. If you use our Sites without registering, we only collect information through the use of cookies, web beacons and navigational data collection. While we cannot directly identify you, in some jurisdictions, this information is still subject to applicable data protection laws and requires your consent to our cookies policy as described below. If you choose to register with us, you will be asked to provide Personal Information (as defined below) and may also be asked to input personal Health Information. It is your voluntary decision whether to provide us with any such Personal Information or Health Information, but if you refuse to provide such information we may not be able to register you to use the Platform or your use of the Platform may be limited.

Collecting and Using Your Information

Collecting and Using Your Personal Information and Health Information (Actively Provided Information)

Whenever you submit information via our Platform, or otherwise in connection with your use of the Platform, including, but not limited to, by telephone or email with customer service, you consent to the collection and processing of your Health Information and geo-location data, our cookies policy, and cross-border transfer of data, all in accordance with this Privacy Policy. Catalia Health respects your right to privacy. Please read this Privacy Policy for more information about collection, storage, use, processing, combination, deletion and disclosure of your Personal Information.

“Personal Information” means information that can be directly associated with a specific person (and includes Health Information). When you register or update your information on our Platforms, we collect Personal Information including your:

• first and last name,

• e-mail address,

• year of birth,

• gender,

• geographic location, including your zip code,

• phone number,

• data used to recognize your face (for facial recognition),

• disease state, and disease progression,

• medication type,

• medication usage and adherence,symptoms,

• side effects,

• self-reported wellness information, including weight, exercise, and nutrition,

• stress or anxiety levels,

• other self-reported information relevant to your health, wellness, and disease management

We take care to store identifying data separately from this health information to limit the instances and access of Personal Information.

During registration or subsequently, you may choose to use certain features of the Platform that will allow you to input Personal Information with respect to your health, such as the medications you take, the date of your prescription, the date you received your diagnosis, the number of refills you have made, how often you take your medication, the frequency you would like us to send you reminders to take your medication, whether you take your medication, your doctor’s name and the name of your pharmacy, the name of your health provider, and other information related to your treatment or your illness (“Health Information”). We will tailor our Platform to improve Mabu’s conversations with you and to improve our system for helping with your care management using this information.

If you use the Platform in connection with a program offered by a specialty pharmacy, pharmacy benefit manager, pharmaceutical company, integrated healthcare system, insurance company, employer, healthcare professional, clinical research organization, or other healthcare company that we partner with (our “Partner or Partners”), our Partners may provide us Personal Information about you, such as your medication list, address, phone number, and other Personal Information. This is in order to send Mabu Wellness Companion Robot to the correct address and to ensure it provides you with information about your prescription so that we can personalize our service to you. We will also provide certain Partners with your Personal Information in order to help coordinate your care management and help manage your health.

We may also use the Personal Information (1) to identify your account for purposes of providing you with customer services and to respond to your requests, (2) to provide you the specific services related to your care management, (3) to help diagnose problems with our servers, to make the Platform more useful, for other internal purposes or to customize the Platform and personalize its content for you; and (4) to send you texts, emails or other communications regarding general adherence information, Platform maintenance, updates, or changes to this Privacy Policy or any other relevant agreements.

Ensuring the accuracy and completeness of the Personal Information and any other information that you provide in connection with your use of the Platform is important. Inaccurate or incomplete information will affect the functioning of the Platform, as well as the information you receive from us and our ability to contact you.

Automatic Data Collection

Sites: We collect information about your use of the Sites (IP address, type of computing or mobile device you use, language of your operating system, the Internet browser you are using, geo-location and use of the Site) through the use of various technologies, such as cookies, web beacons and navigational data collection (log files, server logs, clickstream). For more information on our cookies policy, please see below.

The Platform may automatically collect certain information about you when you use the Platform, such as when you use the Platform, data related to the cellular or wifi-connection you use to connect to the Platform, and when the Mabu Wellness Companion Robot is turned off or turned on.

Data collected automatically on the Platform may be used, for example, to help diagnose problems with our servers, to make Catalia Health more useful, to customize the Platform and personalize its content for you.

Cookies

A cookie is a small piece of text that is sent to a visitor’s browser. The browser provides this piece of text to the device of the originating visitor when this visitor returns. We use cookies to help personalize your Catalia Health experience. A “persistent” cookie may be used to help save your settings and customizations. Also, if you log in to the Site, such a cookie will be used to recognize you as a valid user so you will not need to log in each time you use the Sites. Most Web browsers automatically accept cookies, but allow you to modify security settings so that you can approve or reject cookies on a case-by-case basis or reject all cookies. You can configure your web browser to remove cookies by following the directions provided in your Internet browser’s “help” section.

Also, you are free to delete any existing cookies at any time. If you delete or disable cookies from our Sites, some parts or functions of the Sites may not work properly for you.

Sharing of Your Personal Information with Third Parties and Service Providers

Catalia Health respects your right to privacy. This privacy policy explains Catalia Health’s policy regarding the collection, use, disclosure and protection of Personal Information. Please read it carefully.

We may share your Personal Information and Health Information with our Partner or Partners who are sponsoring your program. Personal Information and Health Information is provided to them to improve the Platform, improve the efficacy of your treatment program, improve their marketing to persons with similar treatment issues, and to more be able to treat people with similar issues. In most circumstances a separate Privacy Agreement will be provided to more fully detail the privacy policy we have established with a particular Partner or Partners.

In all cases, you will have been provided specific information about who will receive your Personal Information when you opted in to use of the Platform (through your specialty pharmacy who provides you with medication, through your Integrated Health System, through your provider, through your insurance company, through your employer, through the clinical research organization in which you are enrolled in a clinical trial, through a healthcare professional, or through another healthcare company).  Contact Catalia Health or the applicable Partner to get further information about who receives your Personal Information and for what purpose.

Under certain uses of the Platform, you may be presented with the option to send your Personal Information or other information to your doctor, healthcare provider, or close relative. Such sharing of your information is at your discretion and is solely your responsibility.

We will not publish your Personal Information without your explicit consent. However, we might share your Personal Information, as is reasonably necessary, without your consent with: (1) our contractors or consultants who are bound by an obligation of confidentiality, provided that we will only share Personal Information to the extent necessary with such contractors or consultants; and 2) affiliates of our company for the purposes of improving our marketing strategies, for research purposes and for entering into commercial contracts in order to provide our users with Catalia Health’s services.

We may share your Personal Information with third parties, such as research institutes, healthcare systems or doctors, for research purposes and so that they can cross-check such information with other information that they have about you, for research purposes and for improvement of our services. We will first obtain your consent for the same. Please note that we may share your de-identified data with such third parties without obtaining such consent.

Sometimes we may provide limited access to your Personal Information to the extent necessary to our contractors and consultants, including vendors and suppliers that provide us with development services, technology, services, or content for the operation, development and maintenance of our Platform or data and analysis on Platform use. Such access is limited to the information reasonably necessary for the contractor or consultant to perform its services to us. We also require that such contractors and consultants agree to protect the privacy of your Personal Information and agree not to use or disclose Personal Information for any purpose other than providing us with products and services and as required by law.

In addition we may share your Personal Information with third parties, such as law enforcement authorities, courts and tribunals, to respond to law enforcement requests or other legal requests or pursuant to a requirement imposed by law, order, judgment or decree, as required by law.

We may also share your Personal Information with legal advisors, consultants, or courts in order to protect and defend our rights and property or those of Platform users. We may also transfer your Personal Information in the event of a merger, acquisition or sale of all or a portion of our assets.

Use of Aggregated Data

We may analyze all information we receive and/or combine your Personal Information, including Health Information and information regarding your use of the Platform, with information from other users to create aggregated data that may be disclosed to and utilized by us, our affiliates and by third parties without restriction, on commercial terms that we can determine in our sole discretion for purposes of content marketing, for research purposes, in order to understand behavior patterns and in order to increase adherence to medication regimens, to lessen or reduce side-effects, and symptoms, and to improve disease management. Such aggregated data will not contain any information that could be used to contact or identify you.

SMS Texting

Personal Information and/or Health Information may be sent to you via SMS text if you authorize such usage. While the SMS text we send is encrypted according to industry standards through its transmission through our Platform, you should contact your cellular provider if you have questions about it’s encryption through your cellular network.

Emailing

Personal Information and/or Health Information may be sent to you via email message if you authorize such usage. While the email message we send is encrypted according to industry standards through its transmission through our Platform, you should contact your email host if you have questions about it’s encryption through your email service.

Disabling the Service, Access, Corrections, and Deletion

At any time, you can stop the collection of your information by turning of the Mabu HCR and refraining from using the Platform. You may also request that your Personal Information be deleted from our active databases. A separate request will have to be made with each Partner or Partners which are providing our Platform to you.  We cannot restore information that we have deleted. You are responsible for backing up the data that you store on the Platform. We may retain any data in non-identified form, subject to applicable law.

You may contact us as specified below under “How to Contact Us” to access information that we keep about you or update or correct such information or ask for its deletion. We will retain your information for as long as you continue to use our Platform and for a reasonable period of time afterwards.

Links to Other Websites or Apps

Our Sites may link to or refer to websites or mobile device applications that we do not control. Any Personal Information you provide on the linked pages is provided directly to this third party and is subject to this third party’s provider’s privacy policy. This Privacy Policy does not apply to such other websites or applications, and we are not responsible for the privacy practices or content of any website or application not controlled by us. If you have any concerns, we urge you to review the terms of those other websites or applications for more information about their applicable policies.

Security

We take reasonable steps to protect Personal Information as you transmit it to us and to protect such information from loss, misuse and unauthorized access, disclosure, alteration or destruction. However, you should keep in mind that no Internet transmission is ever completely secure or error-free.

Children

Our Platform is intended for use by persons 18 years of age and older. Under no circumstances should the Platform be used by children under 14 years of age, and we will not knowingly collect Personal Information from any person we know to be in this age group. If you are using the Platform for the benefit of a child, please do not provide information relating to such child unless you have obtained the child’s parents’ or guardians’ consent, including their consent to this Privacy Policy. If you discover that your child has been using the Platform without your consent, or that someone has been using the Platform for or on behalf of your child without your consent, please contact us using the information below under “How to Contact Us,” and we will take reasonable steps to delete the child’s information from our active databases.

We may transfer our databases containing your Personal Information if we sell our business or part of it.

HIPAA

Your Health Information is protected and secured under HIPAA (the Health Insurance Portability and Accountability Act of 1996) guidelines and other applicable law. Some Personal Information you provide to us (that which is not Health Information) is not protected by HIPAA. HIPAA protects health information held by or on behalf of your health care provider or health plan.

How to Contact Us

If you have any questions, comments, requests, or concerns related to this Privacy Policy or the privacy practices for our Platform, please contact us at:

Catalia Health

ATTN: Catalia Health Privacy Questions

629A Bryant St.., San Francisco CA 94107

Info@CataliaHealth.com

Changes to the Privacy Policy

From time to time we may need to change this Privacy Policy. You will be informed of such change in advance, and you will always have the possibility to stop using the service as explained above.

This Privacy Policy was last updated in June 2016.