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Updated 21 st December 2022

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ICER Health is committed to data protection and privacy. This policy sets out the basis on which any

information we collect from you, how we collect it, use, share, store, or otherwise process your

personal information in connection with the Services. Please read the following carefully to

understand our views and practices regarding your information and how we will use it. By visiting

our website or downloading our apps in AppStore or the Google Play Store, you are accepting and

agreeing to the practices described in this Privacy Policy.

ICER Health and its affiliated entities and subsidiaries (collectively “ICER Health”, “we”, “us”, or

“our”) provide services and information to individuals and our business customers (collectively, the

“Services”).

COLLECTION OF PERSONAL INFORMATION

When you use the Services, we may collect, import or receive personal information including the

following:

Contact information, such as your name, e-mail address(es), mailing address(es), the state and

country in which you reside, and telephone number(s).

Your login credentials if registering for or logging in to any of our Services.

Your areas of interest.

Your photo.

Your job title.

Geolocation information.

Information about your company, such as company name, the number of employees at your

business, and industry type

. Comments and other information you submit in connection with ICER Health blog posts, social

media accounts, public forums, or surveys.

Payment information, including credit card number, debit card number, or other payment card

information. When you use the Services, we may automatically collect information, such as the

following:

Device identifiers, including Apple and Android device identifiers.

IP address.

MAC address.

Browsing activity on our Apps and related sites, including movements and preferences on our

Apps and related sites, the date and time you access the Site, and pages accessed.

Apps and related sites you visit, including referring apps and related sites (the Internet address of

apps and related sites from which you link to our Apps and related sites).

…. automated technology to collect information in connection with the Services, including personal

information. The automated technologies we use include the following:

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To make ICER Health Apps and related sites work properly, facilitate access to our Apps and related

sites, and personalize your experience, we may assign your computer or device one or more

“cookies.” A cookie is a small data file that our Apps and related sites save on your computer or

mobile device when you visit our Apps and related sites, respond to surveys, participate in polls, or

otherwise use the Services. For example, it enables our Apps and related sites to remember your

actions, browsing activities, favorite content, and preferences (such as clicking “Remember me”

during login). Whenever you sign into our Apps and related sites, we will record your user ID in a

cookie file on your computer or device.

We use a combination of Google Analytics, marketing automation, and cookies on our Apps and

related sites that identify your computer to help us analyze traffic patterns on our Apps and related

sites as well as to provide you with a better experience by showing you content that matches your

interests, improving content, and making the Apps and related sites easier to use.

Through the use of a cookie, ICER Health may also automatically collect information about your

online activity on our Apps and related sites, such as the web pages you visit, the links you click, and

the searches you conduct.

Google Analytics uses cookies to help ICER Health analyze how visitors use its Apps and related sites.

The information generated by the cookies about your use of ICER Health Apps and related sites

includes your IP address, and will be transmitted to and stored by Google on its servers.

Google will use this information for the purpose of evaluating your use of our Apps and related sites,

creating reports on website activity, and providing other services relating to Internet usage. Google

may also pass this information onto third parties when required to do so by judicial or administrative

process or otherwise to the extent required by law, or when such third parties process the

information on Google’s behalf.

If you so choose, you may be able to opt out by turning off cookies in the preferences settings in

your browser, or by downloading and installing the Google Analytics Opt-Out Browser Add-On from

http://tools.google.com/dlpage/gaoptout.

Should you wish to not have cookies enabled when using our Apps and related sites, you may be

able to adjust your browsers settings accordingly. However, this may cause issues in accessing

information where authorization is required. Additionally, you can set your user preferences on your

profile on our Apps and related sites to control how cookies are set.

ICER Health may use other standard Internet technology, such as web beacons (also called “clear

GIFs” or “pixel tags”), locally stored objects (often referred to as “flash cookies”), and other similar

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technologies, to deliver or communicate with cookies and track your use of our Apps and related

sites and content presented and information about

The device technology you are using.

Your browser version, screen resolution, and operating system.

Search inquiries using a Site search function.

Information you download.

Webinar registration and views.

ICER Health may also include web beacons in email messages or newsletters to determine whether

messages have been opened and acted upon. The information ICER Health obtains in this manner

enables customization of the programs and services ICER Health offers and measures the overall

effectiveness of ICER Health’s online content and advertising campaigns. We use web beacons/clear

GIFs/pixel tags to track how users are interacting with our content and monitor the effectiveness of

our communications.

With respect to personal information that we receive from or on behalf of our business customers as

a result of the Services we provide to them, ICER Health acts as the “processor” of such personal

information. In those cases, we collect, receive, use, and disclose personal information at the

direction of our business customers. The types of personal information we collect, and how we use

and disclose that information, will generally align with the descriptions provided above in this

section on Collection of Personal Information and below in the sections on Use of Personal

Information and Disclosure of Personal information.

Import Contacts

We utilize an import contacts feature to help us track who is using the and give suggestions. We

import contacts from your email program or mobile phone, or you can provide your email username

and password through a secure program and we will store your email contacts.

USE OF PERSONAL INFORMATION

We may use the personal information we collect or receive about you for purposes including the

following:

To provide Services to our users and customers.

To communicate with you and provide you with information that you request from us or which we

feel may interest you, including newsletters, white papers, company updates, survey reports, and

invitations to events.

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To market our Services and improve and personalize marketing and advertising efforts.

To enroll you in Services or free trials.

To improve our membership experience.

Administering, protecting, and improving our Services and our systems.

To better understand the preferences of our Site visitors.

To identify server problems.

To compile aggregated statistics about Site usage.

To help personalize your experience when using our Services.

To operate, evaluate, and improve our business.

To enforce our policies, Terms, or rights arising from any agreement reached between you and

ICER Health and to carry out our contractual obligations.

To protect the rights, property, or safety of ICER Health, our affiliates, our users, our customers,

and others.

To investigate or prevent unlawful activities, fraud, or misuse of the Services.

To comply with any court order, law, or legal process and respond to lawful requests from public

authorities, including to meet national security or law enforcement requirements.

DISCLOSURE OF PERSONAL INFORMATION

We may share your personal information as follows:

Within the ICER Health group of companies.

With trusted business partners, such as system integrators, distributors, business customers, and

referral partners, and any other party specifically identified on the page on which you submit your

information.

With contractors, service providers, and other third parties we use to support our business

operations. For example, we use service providers to provide web hosting services, SaaS applications

for customer relationship management and data analytics, payment processing, and marketing

automation tools.

To comply with any court order, law, or legal process and respond to lawful requests from public

authorities, including to meet national security or law enforcement requirements.

To enforce our policies, Terms, or rights arising from any contracts entered into with you and to

meet our contractual obligations related to the processing of your personal information.

To protect the rights, property, or safety of the ICER Health group of companies, our customers,

our users, or others.

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To provide Services to our users and business customers.

In connection with a prospective or actual sale, merger, transfer, or other reorganization of all or

parts of our business. We also may post or livestream (including through social media channels and

our Apps and related sites) video or audio recordings, photographs, and other media that we create,

collect, or receive in connection with ICER Health-sponsored live events.

We reserve the right to fully use and disclose any information that is not personally identifiable (such

as aggregate statistics and survey results).

YOUR RIGHTS AND CHOICES

You can ask us to stop sending you marketing messages at any time by contacting us or clicking on

the opt-out link included in each marketing message. You may continue to receive service-related

and other non-marketing messages.

Some of the business partners that collect information about users’ activities on our apps and

related sites or in our mobile applications may be members of organizations or programs that

provide choices to individuals regarding the use of their browsing behavior or mobile application

usage for purposes of targeted advertising.

You may opt out of receiving targeted advertising on apps and related sites through participating

members of the following organizations or programs:

Network Advertising Initiative (USA)

Digital Advertising Alliance (USA)

European Interactive Digital Advertising Alliance (Europe)

Digital Advertising Alliance of Canada (Canada)

Australian Digital Advertising Alliance (Australia)

Data Driven Advertising Initiative (Japan)

Users of mobile applications may opt out of receiving targeted advertising in mobile applications

through participating members of the Digital Advertising Alliance by installing the AppChoices

mobile application, available here, and selecting the user’s choices. In addition, your mobile device

settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or

targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your

mobile device.

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Please note that we also may work with companies that offer their own opt-out mechanisms and

may not participate in the opt-out mechanisms that we linked above.

If you choose to opt-out of targeted advertisements, you will still see advertisements online, but

they may not be relevant to you. Even if you do choose to opt out, not all companies that serve

online behavioral advertising are included in this list, and so you may still receive some cookies and

tailored advertisements from companies that are not listed.

Do Not Track Signals

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that

you visit. We currently do not respond to do not track signals. To find out more about "Do Not

Track," please visit http://www.allaboutdnt.com.

Choosing not to provide your personal data

Where we request personal data directly from you, you do not have to provide it to us. If you decide

not to provide the requested information, in some circumstances we, or our clients, may be unable

to provide products or services to you. For example, we may be unable to process your transaction.

Accessing, modifying or deleting your information

In some jurisdictions, applicable law may provide a right for individuals to access, modify, or delete

their personal data in some. You may contact us directly to request access to, modify or delete your

information. We may not be able to provide access to, modify, or delete your information in all

circumstances.

Complaints

If you have a complaint about our handling of your personal data, you may contact our data

protection officer using the contact information below. We request that a complaint be made in

writing. Please provide details about your concern or complaint so that our data protection officer

can investigate it. We will take appropriate action in response to your complaint, which may include

conducting internal discussions with relevant business representatives. We may contact you for

additional details or clarification about your concern or complaint. We will contact you to inform you

of our response to your complaint. You also may have a right to file a complaint with a national or

local regulatory agency.

SECURITY

Transmissions over the Internet are never 100% secure or error-free. ICER Health takes technical and

organizational measures to protect your information against accidental or unlawful destruction or

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accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission

over the Internet, and no means of electronic or physical storage, is absolutely secure, and so we

cannot ensure or warrant the security of that information.

DATA RETENTION

We store personal information for as long as we reasonably need it to fulfill the purposes for which

it was collected. We will also retain your information as necessary to comply with our legal

obligations, resolve disputes, and enforce our agreements.

INTERNATIONAL DATA TRANSFERS AND PRIVACY SHIELD PARTICIPATION

When you use our products and services, information about you will be transferred to the Singapore

or any other country where the majority of ICER Health’s data processing occurs. We may also

transfer information that we collect about you to third party processors across borders from your

country or jurisdiction to other countries or jurisdictions around the world.

ICER Health uses appropriate technical and operational safeguards for cross-border transfers of

personal data collected in the United States, European Economic Area (EEA), United Kingdom, and

Switzerland, as required by applicable local law, including the Standard Contractual Clauses.

USE BY CHILDREN UNDER 16

Our apps and related sites and services are not directed at children for any other reason other than

for health records. We do collect Personal Data from children under the age of 16 for the stated

reasons. Children under the age of 16 sign up and provide personal data through our apps and

related sites or Services to benefit from our health care services provided through the said digital

platform. If you are a parent or guardian and believe your child has provided us with Personal Data

through the Apps and related sites or Services without your consent, please contact us as described

in the “Contact Us” section below and we will use commercially reasonable efforts to delete that

information.

YOUR PRIVACY RIGHTS

ICER Health users from around the world use our products to bring clarity to their work. Regardless

of what country you’re located in, we respect your ability to know, access, correct, export, restrict

the processing of, and delete your information, and have extended those rights globally. We will not

discriminate against you for exercising your privacy rights.

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Information About Your Rights

Upon your request, and subject to applicable legal exceptions, we will:

provide access to and/or a copy of certain information we hold about you

prevent the processing of your information for promotional purposes (including any direct

marketing processing based on profiling)

update information which is out of date or incorrect

delete certain information which we have about you

restrict the way that we process and disclose some of your information

transfer your information to a third-party provider of services

revoke your consent for the processing of your information

Exercising Your Rights

We will need to verify your identity and may need to verify your relationship with ICER Health (for

example, if you’re an administrator of an ICER Health Organization or Workspace and you’re making

a request on behalf of another individual) for security and to prevent fraud.

We may take additional steps to verify that you are authorized to make the request. If you are an

end user of ICER Health’s services and not a direct customer of ICER Health (for example, your

company uses ICER Health and you’re an employee or authorized representative of that company),

you should direct requests relating to your information to the administrator of your company’s ICER

Health account. We will redirect you to your administrator or notify the administrator directly.

AMENDMENTS

We reserve the right to change, modify, add or remove portions of this Privacy Policy from time to

time and in our sole discretion, but will alert you that changes have been made by indicating on the

accepting the current version of this Privacy Policy as posted on the Site at that time. We

recommend that users revisit this Privacy Policy on occasion to learn of any changes.

Please feel free to contact us with any comments, questions, complaints or suggestions you might

have regarding the information practices described in this Privacy Policy.