Your privacy is very important to Advanced Monitored Caregiving, Inc. (“AMCH”). Your access to, and use of the Advanced Monitored Caregiving Inc. (“AMCH”) services which include this website (www.amchealth.com) and the information, products and services that we provide to you and other users through this website, our proprietary platform as well as any mobile apps provided by us in connection with our products and services (collectively, the “AMCH Services”) is subject to the AMCH Terms of Service and this Privacy Policy. AMCH has created this Privacy Policy to explain what information we gather from you when you use the AMCH Services, how we may use this information, the security approaches we use to protect your information, and how you can access and request modification of certain information that we may store about you. Please note that this Privacy Policy applies only to information collected via the AMCH Services – it does not apply to information you disclose to AMCH through other means. This Privacy Policy is incorporated and made part of the AMCH Terms of Service. Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

1.0 YOUR ACCEPTANCE OF THIS PRIVACY POLICY

By accessing, viewing or otherwise using any AMCH Service, you consent to the collection and use of your information by AMCH in accordance with this Privacy Policy. If you do not agree to this Privacy Policy, you may not use any AMCH Service. AMCH reserves the right to change, modify, add or remove portions of this Privacy Policy at any time, without prior notice. Changes take effect on the date that change appears on the revised Privacy Policy. If you use any AMCH Service following a change in this Privacy Policy, your use will be understood to signal that you accept and agree to be bound by the changes. Accordingly, we urge you to review this Privacy Policy frequently for changes.

2.0 COLLECTION AND USE OF PERSONAL INFORMATION

2.1 For the purposes of this Privacy Policy, “Personal Information” means any data, information or set of information that identiﬁes or could be used by or on behalf of AMCH to uniquely identify an individual. Personal Information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal Information.

2.2 We collect Personal Information and other non-individually identifiable information from you when you register on the AMCH Services, create an AMCH User ID, register for a webinar, participate in an online survey, respond to communication such as e-mail, or otherwise use the AMCH Services in any manner. To participate in certain features of the AMCH Services, you will be required to provide certain Personal Information. For example, when registering as a user on any AMCH Service, we may ask you for your name, e-mail address, birth date, mailing address, zip code, phone number or other Personal Information. You may, however, visit portions of the AMCH Services without providing any Personal Information. If you use AMCH Services to connect to a health care provider, that healthcare provider and other providers in the same health care practice will have access to Personal Information in your account for purposes of your treatment. While you are not required to provide us with Personal Information, failure to do so may limit your ability to use certain functions of our AMCH Services or to request certain services or information from us.

2.3 If you choose to upload any Personally Identifiable Information (PII) via the Service, including Protected Health Information (“PHI”) as defined by the Health Insurance Portability and Accountability Act (HIPAA) and related state data privacy laws, this Privacy Policy covers how AMCH collects, receives, uses, retains, and discloses such PII and PHI across the AMCH Services. PHI includes information relating to your health, for example medical history, test and laboratory results, insurance information and other data that you upload and share with a healthcare professional, and data that a healthcare professional collects to identify an individual and determine appropriate care. PII and PHI may include other types of information depending on the legal definition that applies in your physical location. Only the definitions of PII and PHI that apply in your location will apply to you under this Privacy Policy.

2.4 We may collect and use mobile device identifiers, IP addresses and session identifiers to analyze trends, to administer the AMCH Services, to track user activities, to infer user interests, and to otherwise induce, deduce, and gather information about individual users and market segments. Like many web sites and certain mobile apps, we use and may allow third party service providers to use “cookies”, flash cookies, local shared objects, web beacons, pixels, single pixel GIFs, clear GIFs, and/or other tracking technologies to enhance your experience and gather information about visitors and visits to the AMCH Services, including how you use the AMCH Services (“Usage Data”). Please refer to the “cookies” section below for information about cookies and how we use them.

2.5 We may also collect transactional information, customer services information, or any other legally permissible information. We may also collect and store certain other personally non-identifiable information. This information is collected passively using various technologies and cannot presently be used to specifically identify you.

Your information may be supplemented with additional information from other companies such as publicly available information, information about households and other information that we may append or match your information.

2.6 AMCH and its aﬃliates may share your Personal Information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services and content.

2.7 You are responsible for ensuring the accuracy of the information that you submit to AMCH. Inaccurate information will affect your experience when using our AMCH Services and our ability to contact you as described in this Privacy Policy.

3.0 HOW WE USE YOUR PERSONAL INFORMATION

3.1 We may use the Personal Information and other data we collect as described in Section 2 hereof in the following ways:

To provide any legitimate business service or product.
To personalize your AMCH Service and to allow us to deliver the type of content and product offerings in which you are most interested (including to present offers to you on behalf of business partners and advertisers).
To allow us to better service you in responding to your customer service requests.
To contact you when necessary or requested.
To verify and validate your identity.
To administer a promotion, survey or other AMCH Service features.
To the extent you have not opted out of receiving marketing communications, to send you information about AMCH or our products or the AMCH Services, including by letter, email, text, telephone or other forms of communication (You can opt-out any time by contacting us at privacy@amchealth.com).
To the extent you have not opted out of receiving marketing communications, to provide you with information about third-party businesses, products and services, including by letter, email, text, telephone or other forms of communication.
To show you advertisements, including interest-based or online behavioral advertising.
To troubleshoot problems with the AMCH Services, or any services, as requested.
To enforce the AMCH Terms of Services, and to detect and protect against error, fraud and other unauthorized or illegal activities.
To comply with applicable laws, regulations, and legal processes.
To operate and improve the Services available through us.
To fulfill your requests for tools, software, functionality, features and other products, and services.
To communicate with you and respond to your inquiries.
To protect someone’s health, safety, or welfare.
To conduct research about your use of our products; and
To help offer you other products, features or services that may be of interest.

3.2 We reserve the right to make full use of Usage Data. For example, we may use Usage Data to provide better service to Service visitors or end users, customize the Services based on your preferences, compile and analyze statistics and trends about the use of our Services and otherwise administer and improve our Services.

3.3 You understand and agree that if you are using any AMCH Service from a country outside the United States and provide Personal Information to the AMCH Service, you will be authorizing and consenting to the transfer of Personal Information about yourself to the United States. You understand that the privacy laws of the United States may be different from and not as comprehensive or protective as those in your country, and you agree that the transfer of your Personal Information to the United States occurs with your consent. Personal Information collected on the AMCH Service may be stored and processed in the United States or abroad.

3.4 AMC Health offers access to specialty service messages via SMS (Short Message Service) text alerts. Upon your active enrollment in an AMC Health program patients and/or their providers provide a mobile phone number and agrees to these text alert services which can be opted-out of at any time. If you no longer wish to receive SMS messages from us, you can opt out at any time by replying 'STOP' to any of our text messages or by contacting us at 877-262-2240. Please note that opting out of receiving SMS messages may impact your use of certain features or services that are only available via text message.

4.0 COLLECTION AND USE OF NON-PERSONAL INFORMATION

4.1 We also collect non-Personal Information – data in a form that does not permit direct association with any speciﬁc individual. We may collect, use, transfer, and disclose non-Personal Information for any purpose.

4.2 We may collect information such as occupation, language, zip code, area code, unique product identiﬁer, IP (Internet Protocol) address, location, number of users, and the time zone where a user of any AMCH Services is located. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our AMCH Services are of most interest and most widely utilized. Aggregated data is considered non-Personal Information for purposes of this Privacy Policy.

4.3 If we do combine non-Personal Information with Personal Information, the combined information will be treated as Personal Information for as long as it remains combined.

5.0 DO WE DISCLOSE THE INFORMATION WE COLLECT TO OUTSIDE PARTIES

5.1 You understand and agree that we can disclose your Personal Information and other data to third parties, as follows:

To our subsidiaries or affiliates, strategic partners and to third party service providers we engage to provide services.
In the event of the sale or transfer of AMCH, of one or more of our business units or of some or all of our assets, or in the context of some other business acquisition transaction.
In response to lawful governmental requests or legal process (for example a subpoena, court order, or search warrant); to establish or exercise our legal rights, or to defend against claims; or to protect the safety or security of the public or of users of the AMCH Services; or in other circumstances in which we have a good-faith belief that a crime has been or is being committed by a user of our Services, that an emergency exists that poses a threat to the safety of you or another person,
When necessary to protect either our rights or our property or for us to render the service you have requested.
We can disclose aggregate information and other non-individually identifiable information about users of the AMCH Service to our service providers, partners, advertisers or others. For example, we may share information publicly to show trends about the general use of our AMCH Services.

Personal Information will only be shared by AMCH to provide or improve our products, services and advertising; it will not be shared with third parties for their marketing purposes.

6.0 SAFEGUARDING YOUR PERSONAL INFORMATION

6.1 AMCH follows generally accepted industry security standards to safeguard and help prevent unauthorized access, loss, theft or misuse, as well as against unauthorized access, disclosure, alteration and destruction. However, no security system is impenetrable and, while we make every effort to safeguard your Personal Information, we cannot guarantee the security of the AMCH Services, nor can we guarantee that the Personal Information you supply is completely secure from people who might attempt to evade our security measures or intercept transmission over the Internet, and we are not liable for the illegal acts of third parties such as criminal hackers. As a result, we cannot guarantee the absolute security of any Personal Information submitted to or otherwise collected during your use of any AMCH Service. Accordingly, you understand and agree that you will transmit all data, including Personal Information, to us at your own risk.

6.2 When you use some AMCH products, services, or applications or post on an AMCH forum, chat room, or social network service, the Personal Information you share may be visible to other users and can be read, collected, or used by them. You are responsible for the Personal Information you choose to submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.

7.0 STORING YOUR INFORMATION

We maintain Personal Information that we collect from you in secured cloud storage environments provisioned by third party cloud providers in the United States. Nevertheless, any such information will be maintained and processed by us and our authorized affiliates and service providers which are located in various locations around the world.

8.0 NO MEDICAL SERVICES

Please be aware that no doctor-patient relationship is established between AMCH, and you when you use any of the AMCH Services (or under any circumstances whatsoever). Nothing contained, expressed or implied in our AMCH Services is intended as nor shall be construed as medical advice. Please address any questions or inquiries you may have about medical issues, or any matters you feel are sensitive or want to keep conﬁdential, to an appropriate health care professional.

9.0 CHILDREN’S PRIVACY

Only individuals 18 years of age or older are authorized to use the AMCH Services, either for themselves or on behalf of their minor children. We do not knowingly collect information directly from children under the age of eighteen. If you have reason to believe that an individual under the age of 18 has provided Personal Information to us through an AMCH Service, please contact us, and we will endeavor to delete that information from our databases.

10.0 ACCESS TO PERSONAL INFORMATION

You can help ensure that your contact information and preferences are accurate, complete, and up to date by contacting us. For other Personal Information, we make good faith efforts to provide you with access so you can request that we correct the data if it is inaccurate or delete the data if AMCH is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion request can be granted by contacting us.

11.0 THIRD PARTY WEBSITES

The AMCH Services may contain links to third-party websites, apps and services. Our products and services may also use or offer products or services from third parties – for example, a third-party app. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

12.0 YOUR RIGHTS

We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your Personal Information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed. In the table below, you can review how Consumers can exercise their rights, and appeal such decision, or if and when AMCH sells or shares the personal data and how to opt out.

RIGHT TO KNOW (ACCESS)	You have the right to confirm whether we collect Personal Information, or Personal Data, and to know the information specifically collected on you. You can exercise your right by reviewing this Privacy Policy, and in case you would like to receive a copy of your information please submit a request to privacy@amchealth.com.
RIGHT TO CORRECTION	You have the right to correct inaccuracies in your Personal Information, or Personal Data, taking into account the nature of the process and the purposes. At any time, you may correct any of the Account information through your account or app settings, or otherwise you may contact us at: privacy@amchealth.com.
RIGHT TO DELETION	You have the right to delete the Personal Information we collected from you, and you can exercise your right for deletion by sending an email to privacy@amchealth.com. You do not need to create an account with us to submit a request to know or delete. The deletion right is not absolute and in certain circumstances we may deny such a request. We may deny your deletion request, in full or in part, if retaining the information is necessary for us or our service provider(s) for any of the following reasons: (1) Complete the transaction for which we collected the Personal Data, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you; (2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (3) Debug products to identify and repair errors that impair existing intended functionality; (4) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (5) Comply with the law or legal obligation; (6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent; (7) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (8) Make other internal and lawful uses of that information that are compatible with the context in which you provided it. We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our processors to take similar action.
RIGHT TO PORTABILITY	You have the right to obtain the personal data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We will select the format in which we provide your copy. To request a copy of your Personal Information, send an email to privacy@amchealth.com.

In addition to your right subject to state laws, if we process PHI, you have additional rights under HIPAA which are detailed in Section 13 below.

HIPAA RIGHTS
- We may use your PHI for any of the following purposes:
Treatment: We may use and disclose your PHI for treatment purposes, we may share the PHI with doctors, optometrists, and other personnel involved in your health care. This helps to coordinate your care and make sure that everyone who participates in your care has the information that they need about you to meet your health care needs.
Payment: We may use and disclose your PHI so that we, or health care providers can bill and collect payment from you, your insurance company, or a third party that help us submit bills and collect amounts owed. For example, we may contact your insurer, or other health care payor to determine whether it will pay for health care products and services you need and to determine the amount of your co-payment. The information on or accompanying the bill may include information that identifies you, as well as information about the services or products that were provided to you. We may also disclose your PHI to other health care providers or covered entities you are associated with, who may need it for their payment activities related to their engagement with you.
Healthcare Operations: We may use and disclose your PHI to improve our services, to improve our AMCH Services, for marketing activities permitted under HIPAA (such as personalized advertising based on your past purchases), and ensure you receive quality customer service, performance evaluation, and other internal business management purposes. We may use your PHI to create de-identified data, which is stripped of your identifiable data and no longer identifies you.
Business Associates: We may contract with third parties to perform certain services for us, such as billing services, copy services or consulting services. These Third Party Service Providers, referred to as Business Associates and/or Business Associate Subcontractors, may need to access your PHI to perform services for us and in such case we will use our best efforts to ensure they are required by contract and law to protect your PHI and only use and disclose it as necessary to perform their services for us.
Family Members: We may disclose your PHI to a family member, other relative, friend, or other individual identified by you, who is involved in your medical care or payment for your care, provided you agree to this disclosure, you had an opportunity to object and did not do so, or we infer from the circumstances in our professional judgment that the disclosure is appropriate.
As Required by Law: We will disclose your PHI when required to do so by federal, state, or local law.
Safety, Quality Management, Public Health, and FDA: We may disclose your PHI to relevant authorities to prevent or control product recalls, repairs, or replacements.
Health Oversight Activities: We may disclose your PHI for legally authorized oversight activities, such as audits, investigations, inspections, and credentialing.
- We may use or disclose your PHI to communicate with you regarding your care and related matters. For example, we may use or disclose your PHI to provide reminders. We typically provide these services through text or email and solely subject to your consent and approval. You may withdraw your consent and opt-out of these communications at any time.
- You have the following rights concerning your PHI:
Access PHI and Receive a Copy: You have the right to review or get copies of your PHI and health related information, with limited exceptions. You may request that we provide copies in a format other than photocopies. We will use the format you request unless we cannot practically do so. Please make such a request in writing. You may obtain a paper copy at the site where you obtain health care services from us or by contacting privacy@amchealth.com. You have the right to request a copy of your information in electronic format, and to direct us to transmit a copy of your information to a third party designated by you.
Alternative Communication: You have the right to request in writing that we communicate with you about your PHI by alternative means or to alternative locations. Your request must specify the alternative means or location and provide a satisfactory explanation how payments will be managed under the alternative means or location you request.
Restrict Uses and Disclosures of PHI: You have the right to request additional restrictions on our use or disclosure of your PHI. We are not required to agree to these additional restrictions except in the case where the disclosure is to a health plan for purposes of conducting payment or health care operations, or otherwise required by law. Note, we will not disclose your health information to a health plan for purposes of payment or health care operations when the information relates solely to a service or product for which you paid out-of-pocket in full.
Amendment of PHI: If you feel that PHI we maintain about you is incomplete or incorrect, you may request that we amend it. Your request must be in writing, and it must explain why the information should be amended. We may deny your request under certain circumstances. You may obtain a form to request an amendment to your health information by using the contact information listed at the end of this Notice.
Accounting of Disclosures of PHI: You have the right to receive a list of instances in which we disclosed your PHI for purposes other than treatment, payment, health care operations, where you have provided an authorization and certain other activities, for the last 6 years (or a shorter period if our relationship with you has existed for less than 6 years). If you request this accounting more than once in a 12-month period, we may charge you a reasonable, cost based fee for responding to these additional requests.
PHI Breach Notification: If we become aware that your PHI has been breached and the privacy or security of the information has been compromised, you have the right to be notified of the breach without unreasonable delay and in no event later than 60 days following our discovery of the breach.

13.0 COOKIES AND OTHER TECHNOLOGIES

13.1 Our AMCH Services may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our AMCH Services users have visited/utilized, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected cookies and other technologies as non-Personal Information. However, to the extent that IP addresses or similar identiﬁers are considered Personal Information by local law, we also treat these identiﬁers as Personal Information. Similarly, to the extent that non- Personal Information is combined with Personal Information, we treat the combined information as Personal Information for purposes of this Privacy Policy.

13.2 AMCH and our partners also use cookies and other technologies to remember Personal Information when you use our AMCH Services. Our goal in these cases is to make your experience with AMCH more convenient and personal, thereby providing you with a more customized and useful experience. If you want to disable cookies and other technologies, please check with your internet provider to ﬁnd out the proper method to do so. Please note that certain features of our AMCH Services may not be available once cookies are disabled.

13.3 As is true of most websites, apps and platform, our AMCH Services gather some information automatically and stores it in log ﬁles. This stored information includes your IP address, browser type and language, Internet Service Provider (ISP), referring and exit pages, operating system, date/time stamp, and clickstream data. We use this information to understand and analyze trends to administer our website, to learn about user behavior on our Website, and to gather demographic information about our user base as a whole. AMCH may use this information in our marketing and advertising services.

13.4 In some of our email messages, we may use a “click-through URL”” linked to content on our AMCH Services. When customers click one of these URLs, they pass through a separate web server before at destination page on our one of our AMCH Services. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links contained in the email messages.

13.5 Pixel tags enable us to send email messages in a format that customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

14.0 COMMUNICATION WITH OUR AMCH SERVICES

AMCH welcomes your feedback and suggestions about how to improve any of the AMCH Services. However, please note that when you submit suggestions, information, material, or other content (collectively, your “Content”) to AMCH, you automatically grant AMCH a royalty-free, perpetual, irrevocable, nonexclusive right and license to use, reproduce, modify, adapt, publish, translate, create derivative works from, distribute, redistribute, transmit, perform and display your Content (in whole or part) worldwide and/or to incorporate it in other works in any form, media, or technology now known or later developed for the full term of any rights that may exist in your Content. Moreover, AMCH may use any ideas, concepts, know-how, techniques, and suggestions contained in your Content for any purpose whatever, including but not limited to, creating and marketing products and/or services using your Content. Please note that AMCH is not responsible, nor shall it be liable for content posted to our AMCH Services by visitors or persons other than AMCH employees. Opinions or comments contained in such content [solely] reﬂect the views of the author and not of AMCH unless AMCH expressly states to the contrary].

15.0 PRIVACY QUESTIONS

If you have any questions or concerns about this Privacy Policy, please contact us at privacy@amchealth.com or by sending a written correspondence to:

Advanced Monitored Caregiving Inc.

1 World Trade

85th Floor

New York, NY 10007

CALIFORNIA CONSUMER PRIVACY STATEMENT

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we, Advanced Monitored Caregiving Inc., together with its subsidiaries, affiliates, or related companies (“Company”, “our”, “we” or “us”) provide California residents (consumers or employees) with notice at collection ("CCPA Notice"). The CCPA Notice shall disclose the Personal Information (as defined below) that is collected, processed and shared during the use of the Services, and your rights. The CCPA Notice is an integral part of our Privacy Policy; capitalized terms used but not defined in this CCPA Notice will have the meanings set out in the Privacy Policy or as defined under the CCPA or CPRA. If there is any conflict or inconsistency between the terms of this CCPA Notice and the Privacy Policy, the terms of this CCPA Notice will prevail solely for eligible consumers.

PART I: A COMPREHENSIVE DESCRIPTION OF THE INFORMATION PRACTICES

CATEGORIES of PERSONAL information WE COLLECT

We collect “Personal Information” which is defined under the CCPA as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device, all as detailed in the table below. Personal Information under the CCPA further includes Sensitive Personal Information (“SPI”) as detailed in the table below.

Personal Information does not include: Publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; Information excluded from the CCPA or CPRA scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPPA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.

We may have collected the following categories of Personal Information within the last twelve (12) months:

CATEGORY	EXAMPLE	COLLECTED
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.	Yes: real name, shipping or billing address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and phone number.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes: name, age, gender, physical characteristics or description (vision tests), partial credit card number, health insurance policy number and medical information regarding eye care treatment when applicable, including prescription.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes: Gender.
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes: purchase habits, shopping history, transactions, partial credit card number.
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	Yes: information we collect in relation to our Virtual Try-On tool may constitute biometric information under the CCPA. For more information on our processing of information that may constitute biometric information in relation to our Virtual Try-On tool, please review our Privacy Policy.
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.	Yes: browsing history and search history within and outside our Properties, interaction with our Properties and our advertisement.
G. Geolocation data.	Physical location, approximate location derived from IP address or movements.	Yes: approximate geolocation extracted from IP, physical location and GPS when using the App and approving the GPS permission.
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	Yes: pictures uploaded to the site, and recording customer service calls.
I. Professional or employment-related information.	Current or past job history or performance evaluations.	Yes: Governed by our Privacy Policy.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information.	Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes: gender, certain demographic data, profiling. The profiling is not based on SPI.
L. Sensitive personal information.	Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life.	No

Categories of Sources of Personal Information

Directly and indirectly from your actions within AMCH Services.
Directly from you when you contact us.
From third-parties, advertising and analytic vendors, advertising networks, social networks share information with us when you log in, data enrichment vendors, etc.

For more information, please review our Privacy Policy.

USE OF PERSONAL INFORMATION

We may use the Personal Information collected as identified above, for the following purposes: to fulfill or meet the reason you provided the Personal Information (support, respond to a query, review create an account, etc.); monitor and improve our AMCH Services; provide the AMCH Services; marketing our AMCH Services; analyzing our AMCH Services and your use thereof; respond to law enforcement; or otherwise as detailed in our Privacy Policy.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

We may disclose your Personal Information to a contractor or service provider for a Business Purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract; we further restrict the contractor and service provider from selling or sharing your Personal Information. In the preceding twelve (12) months, we might have disclosed the following categories of Personal Information for a business purpose:

"BUSINESS PURPOSE (AS DEFINED UNDER CCPA)"	"DATA CATEGORY (CORRESPONDING WITH THE TABLE ABOVE)"	CATEGORY OF RECIPIENT
Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.	Category A Category D Category F Category G	Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.	Category A Category B Category F	Subsidiaries, operational partner, security and fraud prevention providers, operating systems.
Debugging to identify and repair errors that impair existing intended functionality	Category A Category B Category F	Analytic providers, operational partner, security and fraud prevention providers, operating systems.
Short-term, transient use, provided the personal information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.	Category A Category D Category F Category G	Advertising networks; data analytics providers; social media networks.
Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.	Category A Category D Category E Category F Category G Category H	Payment processors, fraud prevention providers, IT security providers, cloud service providers and others for the sole purpose of providing the services, subsidiaries, affiliated companies, operating systems, CRM, ERP, shipping partners, health care providers, health insurance, or other survey providers, customer support, cloud computing and storage vendors, fulfillment vendors, frames and lens vendors, etc.
Undertaking internal research for technological development and demonstration.	Category A Category D Category F Category G Category H	Developers, operating systems, cloud and hosting providers, SaaS platforms for task management and development, customer support and optimization tools.
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned or controlled by the business.	Category A Category D Category F Category G Category H Category K	Developers, operating systems, cloud and hosting providers, security providers, SaaS platforms for task management and development, customer support and optimization tools.
Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the Personal Information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with Personal Information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you.	Category A Category D Category F Category G Category K	Advertising networks; data analytics providers; social media networks. Marketing service providers and technical platforms such as E-mail and text messaging providers, CRM and tracking tools (tracking within the Properties).
Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.	Category A Category D Category F Category G Category K	Advertising networks; data analytics providers; social media networks. Marketing service providers and technical platforms such as E-mail and text messaging providers, CRM and tracking tools (tracking within the Properties).

SALE OR SHARE OF PERSONAL INFORMATION

We do not “sell” or “share” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Information in direct exchange for money or some other form of payment.

For retargeting and analytic purposes, when we promote our AMCH Services and advertise our products and services, we use third-party providers and tracking tools, advertising networks and social media. They provide these services by placing cookies, pixel or other tracking technology on our AMCH Services and sharing with these vendors the online identifiers and online behavior information. The CCPA defines these actions as “sharing” or “selling”.

In the preceding twelve (12) months, we “sell” or “share” the following categories of Personal Information for a business purpose:

PURPOSE OF SALE OR SHARE	DATA CATEGORY (CORRESPONDING WITH THE TABLE ABOVE)	CATEGORY RECIPIENT
Targeted advertising, CCBA, promoting the Properties and Services, analytics and	marketing tools, analytic tools, advertising networks, social media networks, media buying, search platforms.	Category A Category F Category G

CHILDREN UNDER AGE 16

We do not knowingly collect information from users under the age of 18.

DATA RETENTION

The retention periods are determined according to the following criteria:

For as long as it remains necessary in order to achieve the purpose for which the Personal Information was initially processed.
To comply with regulatory obligations. For example: transactional data will be retained for up to seven years (or even more under certain circumstances) for compliance with our bookkeeping obligations purposes.
To resolve a claim, we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.

PART II: EXPLANATION OF YOUR RIGHTS UNDER THE CCPA and how to exercise them

YOUR RIGHTS UNDER THE CCPA AND HOW CAN YOU EXERCISE THE RIGHTS?

If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge, except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law, all as detailed herein:

CALIFORNIA PRIVACY RIGHT	DETAILS
The right to know what Personal Information the business has collected and access rights.	The right to know what Personal Information the business has collected about the consumer, including the categories of personal information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom the business discloses Personal Information, and the specific pieces of Personal Information the business has collected about the consumer. You can exercise your right by reviewing this Notice and the Privacy Policy, in case you would like to receive the specific pieces please fill in this form to receive a copy of your data: _______________.
Deletion Rights.	The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions. You can exercise your right for deletion in the following ways: 1. Through the App settings. 2. Through this link: _____________________ We reserve the right to reject such request under certain circumstances, and will inform you of the basis for the denial, which may include, but is not limited to, ensure the security and integrity, provide the services, a legal obligation, etc.
Correct Inaccurate Information	The right to correct inaccurate Personal Information that a business maintains about a consumer. At any time, you may correct any of the account data we collect, or otherwise you may contact us at: privacy@amchealth.com.
Opt-Out of Sharing for Cross-Contextual Behavioral Advertising (“CCBA”) or from selling, where applicable.	You have the right to opt-out of the “sharing” of your personal information for “cross-contextual behavioral advertising,” often referred to as “interest-based advertising” or “targeted advertising”. You may opt out through the “do not sell or share my personal information” button available within the Properties’ footer or within the App settings. You may further opt out through device settings (opt-out from tracking AAID, ADID, please see the following for information applicable to all devices: https://thenai.org/opt-out/mobile-opt-out/). Further, you can opt-out from interest-based advertising, CCBA, by using Self-Regulatory Program for Online Behavioral Advertising such as: Digital Advertising Alliance’s (“DAA”): https://www.aboutads.info/choices and https://www.aboutads.info/appchoices, and the Network Advertising Initiative (“NAI”): https://www.networkadvertising.org/choices. Last, you are able to install privacy-controls in the browser's settings to automatically signal your opt-out preference to the websites you visit (like the “Global Privacy Control”). We honor the Global Privacy Control: https://globalprivacycontrol.org/ as a valid request to opt-out of the sharing of information linked to your browser. In any event, please keep in mind: Opt-out tools are limited to the browser or device you use because they work off your browser ID and device ID. If you’re not signed-in to your customer account or don’t have a customer account, you will need to opt-out on each browser and device you use. Your browser may save some information in its cookies and cache to maintain your privacy preferences. Clearing these may remove opt-out preferences, requiring you to opt-out again. If you opt-out, you will still see ads online, but these ads will not be based on your inferred interests. Some automated means may still be used to collect information about your interactions with our online services for the other purposes such as to remember user preferences or enable specific functionality. We use necessary cookies to make our AMCH Services work. Necessary cookies enable core functionality such as security, network management, and accessibility. You cannot disable those. You can read more about targeted adverting and take additional steps to control targeted advertising from many ad networks and exchanges by visiting the Digital Advertising Alliance (www.optout.aboutads.info). As online environments continue to evolve, additional opt-out mechanisms or privacy settings may become available to you. We encourage you to review the information on opt-outs and settings that browser owners, device manufacturers, technology companies, and industry associations make available to you.
Non-Discrimination	The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicants, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc.
Data Portability	You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format. In case you would like to receive the specific pieces please fill in this form to receive a copy of your data: _______________.

Note: You may only exercise this right, unless legally required otherwise, twice within 12 years.

NOTICE OF FINANCIAL INCENTIVE

We may, at times, offer you various financial incentives such as loyalty programs, discounts and special offers when you provide us with contact information and identifiers such as your name and email address. When you sign-up for our loyalty program, email list or other discounts and special offers, you opt-in to a financial incentive. You may withdraw from a financial incentive at any time by opting out from our email or closing your loyalty member account. Generally, we do not assign monetary or other value to Personal Information, however, California law requires that we assign such value in the context of financial incentives. In such context, the value of the Personal Information is related to the estimated cost of providing the associated financial incentive(s) for which the information was collected. You can end program participation at any time by contacting us at privacy@amchealth.com to unsubscribe or cancel your participation in any program. We will not discriminate against you, in any manner prohibited by applicable law, for exercising these rights.

AUTHORIZED AGENTS

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.

RESPONSE TIMING AND FORMAT

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional forty-five (45) 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. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

CONTACT US:

privacy@amchealth.com

UPDATES:

This notice was last updated in December 2023. As required under the CCPA, we will update our Privacy Policy every 12 months. The last revision date will be reflected in the “Last Modified” heading at the top of this Privacy Policy.

PART III: OTHER CALIFORNIA LAWS AND RIGHTS

CALIFORNIA DIRECT MARKETING REQUESTS:

California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us at: privacy@amchealth.com.

DO NOT TRACK SETTINGS:

Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we so not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.

Last updated: December 2023