Effective Date

August 05^th, 2021

1. INTRODUCTION
   • Ingenuity Insights, Inc. (“Ingenuity Insights,” “we,” “us,” or “our”) respects the privacy of its Users (“User,” “your,” or “you”). This Privacy Policy (the “Policy”) explains how we collect, use, disclose, and safeguard your information when you use our “Website,” “Platform” and/or “Services.”
   • Ingenuity Insights in committed to protecting the privacy of its Users and the privacy of children whose information is collected and stored using Ingenuity Insights’, Website, Platform and Services.
   • INGENUITY INSIGHTS’ WEBSITE, PLATFORM AND SERVICES ARE NOT MEANT FOR USE DIRECTLY BY CHILDREN UNDER THE AGE OF 13. IF YOU ARE UNDER 13, PLEASE DO NOT USE OUR WEBSITE, PLATFORM AND SERVICES ON YOUR OWN.
   • IF YOU ARE UNDER 13 YEARS OF AGE AND YOU WANT TO MAKE USE OF OUR WEBSITE, PLATFORM AND SERVICES YOU CAN DO SO ONLY THROUGH YOUR PARENTS OR LEGAL GUARDIANS. ANY PERSON OR GUARDIAN WILL BE REQUIRED TO GIVE US INFORMED CONSENT BEFORE THEIR CHILDRENS CAN MAKE USE OF OUR WEBSITE, PLATFORM AND SERVICES. ANY INDIVIDUAL UNDER THE AGE OF 13 CAN USE OUR PLATFORM ONLY IF THEIR PARENTS OR LEGAL GUARDIAN OBTAIN SUCH SERVICES AND ACCESS RIGHTS FROM US FOR SUCH UNDER 13 INDIVIDUALS.
   • PRIOR TO COLLECTION, USE AND STORAGE OF ANY INFORMATION ABOUT CHILDREN UNDER 13 ON OUR SERVERS, INGENUTIY INSIGHTS MAKES ALL REASONABLE EFFORTS TO OBTAIN CONSENT FROM PARENTS.
   • ANY AND ALL INFORMATION ABOUT CHILDREN UNDER 13, OBTAINED UNDER OUR WEBSITE, PLATFORM AND SERVICES IS COLLECTED DIRECTLY FROM PARENTS AND WITH PARENTAL CONSENT.
   • PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. IF YOU DO NOT AGREE WITH THE TERMS OF THIS POLICY, PLEASE DO NOT ACCESS THE WEBSITE, USE OUR PLATFORM AND/OR SERVICES.
   • The capitalized terms have the same meaning as ascribed in the Terms of Service, unless otherwise noted here.
   • BY ACCESSING OUR WEBSITE, PLATFORM AND SERVICES YOU AGREE TO ACCEPT ALL THE TERMS CONTAINED IN THIS POLICY AND ACKNOWLEDGE AND AGREE WITH THE PRACTICES DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH THE TERMS OF THIS POLICY, PLEASE DO NOT ACCESS AND USE OUR PLATFORM, WEBSITE AND SERVICES.
   • IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT PRIVACY@INGENUITYINSIGHTS.COM.
2. COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY)
   • The Children’s Online Privacy Protection Act (“COPPA”) is a legislation that applies to entities that collect and store personal information from children under the age of 13. Ingenuity Insights is committed to ensure compliance with COPPA. Ingenuity Insights’ Website, Platform and Services are used and accessed by parents or guardians only. All information about children provided to Ingenuity Insights is provided directly by parents/guardians. If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at privacy@ingenuityinsights.com.
3. NOTICE FOR PARENTS (FOR CHILDREN UNDER 13 USERS ONLY)
   • Our Website, Platform and Services are designed to assist and help manage diabetes in children and adults. While adults can use our Website, Platform and Services directly, a child under the age of 13 can make use of our Platform and Services only through their parents and guardians.
   • Ingenuity Insights is required under the Children’s Online Privacy Protection Act (“COPPA”), with limited exceptions, to obtain verifiable parental consent (“Consent”) in order to collect, use or disclose personal information from children under the age of 13. If you (the “Parent”) wish to use our Services for the benefit of your child who is under the age of 13, you will be required to provide us with express Consent. When you create an Account with us on our Website, we will send you an email asking you for your Consent to collect information about your child. Any and all information collected about your child from you will be in accordance with the terms detailed under this Policy.
   • We will reconfirm you Consent at a later date by email, phone, fax, mail or other means. You have the right to revoke your Consent at any time, although you may be unable to use the features and functions of our Platform if you revoke your Consent.
4. PARENTAL RIGHTS (FOR CHILDREN UNDER 13 USERS ONLY)
   • We do not require parents to disclose more information than is required about their children to us. Parents have the right to periodically request review of a child’s information that is stored on our servers. Parents can also request deletion of all non-aggregated information stored on our Website about their child. In order to request such a deletion, please send us an email at privacy@ingenuityinsights.com.
   • Parents have the right to know about all third-party operators to who Ingenuity Insights may be disclosing children’s personal information. If you would like us to provide you with a list of all third-party operators used by us, please send us an email at privacy@ingenuityinsights.com.
   • Parents shall have the right to revoke Consent by sending an email request to Ingenuity Insights at privacy@ingenuityinsights.com . When revoking Consent, please ensure the subject line of the email read “Revoking Parental Consent.” Upon receiving your request, Ingenuity Insights will delete any non-aggregated information specific to your child within a reasonable period of time. For details regarding our deletion procedure, please review Section 10(c) of this Privacy Policy
5. WHAT INFORMATION DO WE COLLECT?
   • When you register and use our Platform and/or Services, we collect both personally identifiable information (“PII”), which may include your name, contact information, address, phone number,email address, date of birth, social security number, photographs, and personal health information (“PHI”), which may include information about your medical history, information regarding your diabetes and treatment used by you till date, information about your pre- existing health conditions, your health care plans, details regarding the medicines you regularly use, whether you are diabetic or not, etc. The information so collected will be stored on our servers. We collect the following information when you buy our Platform and register and use our Services:
     1. Account Information. When you register to use our Platform or when you create an Account, we will collect your PII. We may also collect information that does not personally identify you such as your geolocation.
     2. PHI Collected Through Platform. When you create an Account on our Website and use our Platform and Service, we collect your PHI either directly from you or from other third-party sources that are linked to our Platform.
     3. Financial Information. We currently do not collect or store any credit cards or bank information. However, we will update this Policy when we start using and storing such information. We will also inform you via reasonable means if we start collection such information from you.
6. HOW DO WE COLLECT INFORMATION?
   • We collect information from our Users in the following ways:
     1. Account Information. We collect personal information upon registration on the Platform and/or Services. We also collect, and store search queries made through your account on either the Platform and/or Services. The information collected will also include usage details as well as other tracking technologies.
     2. User Information. We collect information regarding details and usage of medications and other treatments directly from User. User will have the option to input this information into the Services.
     3. Customer Support Inquiries. If you contact us directly, such as when you contact our customer support team, we will receive and collect the contents of your message or any attachments you may send to us, as well as any additional information you choose to provide. Contact us at privacy@ingenuityinsights.com if you have any questions.

     IF A CHILD UNDER 13 IS THE USER, THEN WE COLLECT ALL THE INFORMATION MENTIONED HEREIN, FROM THEIR PARENTS AND/OR GUARDIANS.

7. HOW WE USE YOUR INFORMATION?
   1. We use the information that you provide to:
      1. Personalize your experience in using our Platform and/or Services;
      2. Provide, operate, maintain, and improve our Platform and/or Services;
      3. Enable you to access your Account;
      4. To notify you about the changes to our Platform and/or Services;
      5. Respond to your comments, questions, and requests and provide customer support;
      6. Personalize and improve our Platform and/or Services, and provide content, features; and/or advertisements that match your interests and preferences or otherwise customize your experience on our Platform and/or Services; and
      7. Send you periodic emails offering our additional Platform and/or Services and other special offers and promotions that we think you will be interested in. If you wish to opt out of email marketing, please follow the instructions on the bottom of our emails or contact us at privacy@ingenuityinsights.com .
8. HOW CAN YOUR INFORMATION BE DISCLOSED?
   1. Disclosure of Information to Third Parties. We do not sell, trade, rent, or otherwise transfer personally identifiable information to others, except:
      1. as provided in this Policy,
      2. to defend against legal claims or otherwise protect our rights,
      3. as required by law, judicial proceeding, court order, or legal process served on us,
      4. for purposes of law enforcement investigations,
      5. to protect rights, property, or safety of our customers, and/or
      6. with your consent.
   2. Google AdSense. We do not collect cookies of any kind from users; however, our ad networks and analytics service providers may collect information about your use of other websites and online services over time through cookies, if those websites and online services also use the same service providers. The information collected in this manner may include IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our Platform and/or Services. We currently use Google Analytics to collect and process certain website usage data. To learn more about Google Analytics and how to opt out, please visit www.policies.google.com/privacy/partners.
   3. Protection of Information. Our Services are reasonably scanned to meet or exceed PCI Compliance. Every time you enter, submit, or access your information, we will implement reasonable security measures.
   4. Authorized Disclosures to Physicians. Upon your authorization, Ingenuity Insights will report any relevant information pertaining to your health and routines to your designated physician. As per Health Information Portability Accountability Act of 1996 (“HIPAA”) regulations, Ingenuity Insights will create a Business Associate Contract with these physicians to safeguard your PHI. We will take all means to protect your PHI from anyone not necessarily required to access such information.
9. OUR COOKIE POLICY
   • Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Policy, we refer to all of these technologies as “Cookies”.
   • We do not use Cookies on our Website and Platform. You can set your browser to refuse all or some browser Cookies, and it will in no way affect your experience. We honor do not track signals and, if one is in place, we will not track, plant cookies, or use advertising.
10. YOUR CALIFORNIA PRIVACY RIGHTS
    • Ingenuity Insights does not sell, trade, or otherwise transfer to outside third parties your personal information. California Civil Code Section § 1798.83 permits users of our Platform and/or Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to privacy@ingenuityinsights.com or write us at

    Attn: Privacy Officer Ingenuity Insights

    4900 Hopyard Road, Suite 100

    Pleasanton, CA 94588.

    Phone: (925) 322-5241

11. DATA SECURITY MEASURES
    • We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform and/or Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform and/or Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform and/or Services.
12. TERRITORIAL RESTRICTION
    • Our Website, Platform and Services are only available for use in the United States (“US”).
    • Please do not access and use our Website, Platform and Services if you reside outside the US. Please be aware that information you provide to Ingenuity Insights while accessing/using our Website, Platform and Services may be processed and transferred to the US and be subject to applicable US laws. The privacy and data protection laws in the US may not be equivalent to such laws in your country of residence.
    • OUR WEBSITE, PLATFORM AND/OR SERVICES ARE NOT AVAILABLE FOR USE AND DOWNLOAD IN THE EUROPEAN UNION.
    • Please do not register for our Services if you live anywhere in the European Union. If we discover any unauthorized registration on our Website, we reserve the right to terminate the registration. By using the Website, Platform and/or the Services, or by providing Ingenuity Insights with your information (as detailed under this Privacy Policy), you consent to this collection, transfer, storage, and processing of information to and in the US.
    • If you have any questions regarding this section, please email us at privacy@ingenuityinsights.com.
13. MODIFICATIONS TO OUR PRIVACY POLICY
    • Ingenuity Insights reserves the right, at its sole discretion, to change or modify this Policy at any time. In the event, we modify this Policy, such modifications shall be binding on you only upon your acceptance of the modified Policy. We will inform you about the modifications via email or comparable means within 15 days of such modification. We will also post the modified version on this page. Your continued use of the Platform and the Services shall constitute your consent to such changes. Ingenuity Insights may change, modify, suspend, or discontinue any aspect of the Platform and the Services at any time without notice or liability.
14. LIST OF THIRD-PARTY SERVICE PROVIDERS
    • Ingenuity Insights uses the following third-part service providers for the provision of Services as detailed under the Terms of Service.

    Serial Number	Name of Third-Party Service Provider	Contact Information
    		Email: Telephone: Address:

    • Additionally, if you have any questions or concerns about our third-party service providers, please email us at privacy@insightsingenuity.com.
    • PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY AND REACH US AT PRIVACY@INGENUITYINSIGHTS.COM IN CASE OF ANY QUESTIONS AND QUERIES.
15. CONTACT US
    • To ask questions or comment about this privacy policy and our privacy practices, contact us at:
      • Privacy Officer
      • Email: privacy@insightsingenuity.com
      • Address: 4900 Hopyard Road, Suite 100, CA 94588.
    • PLEASE NOTE: IF YOU USE OUR WEBSITE, PLATFORM AND/OR SERVICES, YOU HAVE AGREED TO AND ACCEPTED THE PRACTICES DESCRIBED IN THIS POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF SERVICE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS POLICY OR THE TERMS OF SERVICE, PLEASE DO NOT USE OUR WEBSITE, PLATFORM AND/OR SERVICES.
16. HIPAA WAIVER FORM.
    • TO ACCESS AND USE OUR HIPAA WAIVER FORM, PLEASE CLICK HERE.