Sense Relief Inc. Privacy Policy

Effective Date: March 31, 2019

1. Who We Are and What We Do

At Sense Relief, Inc. (together with any affiliates and/or subsidiaries, “Sense Relief”, “we” or “us”), we provide a mobile app with one or more features or services that allow you to select delivery of modulated acupressure via connected compatible wearable devices in an effort to prevent and relieve symptoms of nausea and vomiting (the “App”) and a related website (the “Site”, collectively with the App and the features and services provided through the App, the “Services”). This Privacy Policy applies to information relating to an identified or identifiable natural person (“Personal Information”) that we collect, use, store, or disclose (together with any operation which is performed upon Personal Information, “Process”) in our business, including on the App and the Site.

2. Transparency/Notice

2.1 Personal Information We Collect and How We Use It

We currently do not collect any Personal Information directly from you when you use the Services. We may collect certain information automatically when you access a Site. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Site, information about the links you click, and other information about how you use the Site. Information we collect may be associated with other devices.

We may also collect or receive information about your downloading and use of the App, such as total number of downloads, frequency and timing of use of the App. We may also collect your heart rate and/or other information available through your watch, as provided to us by Apple. This information will not be associated with any direct identifiers. For example, if you access the App through a third-party application, such as an App Store, we may receive information about you from that third- party application that is made available via your privacy settings.

2.2 How We Use Information

We Process information for a variety of business purposes, including:

• To Provide Services or Information Requested including to:

o Respond to questions, comments, and other requests; and

o Contact you to answer requests for customer support or technical support.

• For Administrative Purposes including to:

o Provide you with the Services;

o Measure interest and engagement in our Services;

o Conduct research and development;

o Improve our products and Services;

o Develop new products and Services;

o Ensure internal quality control;

o Prevent potentially prohibited or illegal activities; and

o Enforce our Terms.

• De-identified and Aggregated Information Use. We may use information to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. De-identified or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

• Other Uses. Sense Relief may use information to pursue legitimate interests, such as research (including marketing research), network and information security, and fraud prevention. In addition, Sense Relief may use Personal Information for other purposes that are clearly disclosed to you at the time you provide Personal Information or with your consent.

2.3 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising

We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Services.

Cookies. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about engagement on that web page. The use of a pixel allows us to record, for example, a particular web page visited or a particular advertisement clicked.

Social Media Widgets: We may include social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs) on our Services. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. These social

media features are either hosted by a Third Party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing it.

Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Site. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Site by going to http://tools.google.com/dlpage/gaoptout.

Our uses of such Technologies fall into the following general categories:

Operationally Necessary. This includes Technologies that allow you access to our Services, and tools that are required to identify irregular behavior, prevent fraudulent activity and improve security or that allow you to make use of certain functions;

Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;

Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you or keeping track of your specified preferences, interests, or past items viewed;

Advertising or Targeting Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third party sites.

2.4 Third Party Websites and Applications

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Site or App. These other websites and applications are not controlled by us. We encourage you to read the privacy policies of each website and application with which you interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

3. Onward Transfer—How We May Disclose Information

3.1 Information We Share

We may share information as described in this Privacy Policy:

We Use Service Providers. We may share any information we receive with service providers. The types of service providers (processors) to whom we entrust information include service providers for: (i) the provision of the Services; and (ii) provision of IT and related services.

Business Partners. We may provide information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.

Marketing – Interest-Based Advertising and Third-Party Marketing. Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.” If you prefer not to share your Personal Information with third party advertising partners, you may follow the instructions below.

• Disclosures to Protect Us or Others. We may access, preserve, and disclose information if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vi) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

3.2 International Data Transfers

You agree that all information Processed by us may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States and/or other countries. Information may be accessible to law enforcement or other authorities pursuant to a lawful request.

4. Your Choices: Right to Object to Processing

4.1 General

You may have the right to object to or opt out of certain uses of your Personal Information. Where you have consented to the Processing of your Personal Information, you may have the right to withdraw that consent at any time and prevent further Processing by contacting us as described below.

4.2 “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

4.3 Cookies and Interest-Based Advertising

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.

Please note you must separately opt out in each browser and on each device.

5. Rights of Access, Rectification, Erasure, and Restriction

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are Processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly Processed Personal Information; and (vi) request erasure of Personal Information held about you by Sense Relief, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will process such requests in accordance with applicable laws. To protect your privacy, Sense Relief will take steps to verify your identity before fulfilling your request.

6. Data Retention

Sense Relief retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

7. Security of Information

We take steps to ensure that information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

8. Children’s Information

The Services are not directed to children under 18 (or other age as required by local law), and we do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us as set forth below. If we learn that we have collected any Personal Information in violation of applicable law, we will promptly take steps to delete such information.

9. Supervisory Authority

If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our Processing of your Personal Information violates applicable law.

10. Changes to Our Privacy Policy

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

11. Terms of Use

This Privacy Policy is incorporated by reference into the Sense Relief Terms of Use (the “Terms”). All other terms not defined in this Privacy Policy will have the meanings set forth in the Terms.

12. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us at: info@sensereliefapp.com