Privacy Policy

Wellup Technologies, Inc., together with its affiliates (“Wellup”, “we”, “us”, or “our”), provides the Wellup Platform, the Wellup Administrative Portal, the Member App, and related websites, tools, mobile applications, and associated functionality (collectively, the “Services”). We are committed to protecting you (“you”, “your”, or “user”) and your privacy in connection with Social Determinants of Health (“SDOH”) coordination, referrals, case-management workflows, and community-resource interactions accessed directly by Members and/or supported by Navigators and Administrators (“Admins”). Our Terms of Service are expressly incorporated herein by reference. By accessing or using the Services, you agree to this Privacy Policy. If you do not agree, do not use the Services.

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This Privacy Policy sets forth our policy with respect to information that we collect from you, on or through the Services, that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you (“Personal Information” or “Personal Data”). By accessing or using the Services, or otherwise interacting with us, you are agreeing to this Privacy Policy. Please read it carefully. If you do not agree herewith, do not access or use the Services.

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For purposes of this Privacy Policy, “Users” include all: (i) Administrators (“Admins”) authorized by a customer to access the Wellup Administrative Portal; and (ii) other Authorized Users who access the Wellup Platform and/or the Member App under either a free or paid subscription plan.

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1. Changes to this Policy. We may change this Privacy Policy from time to time by publication of an updated version on our Services, which shall become effective immediately upon publication. We encourage you to review our Privacy Policy whenever you access or otherwise use the Services. Your continued access or use of the Services constitutes your acceptance of any updated version of this Privacy Policy, as published.

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2. How We Collect Information. We may collect information about you by and/or through the following means:

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(i) Directly from you, when you provide information to us or interact with us;

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(ii) Automatically when you access, utilize or interact with our Services; or

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(iii) From social networks and other sources of publicly available data.

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3. What Information We Collect.

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3.1 Generally. The types of information we collect varies depending on whether you are an ‘Admin’ or other classification of ‘Authorized User’.

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3.2 Wellup Admin. When an Admin accesses our Services, views our Platform, or otherwise interacts with us, we may collect and process the following types of Personal Data in the usual course of business:

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(i) Usage Details about your interaction with our Services and Platform, such as the pages which you visited on our website and about the features you used within the website.

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(ii) Device Information, including the IP address and other details of the device that you use to access our Services and Platform (such as the Internet Service Provider, operating system, browser type, browser activity, timestamps, and/or mobile network information).

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(iii) Location Information, as we may use publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address.

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(iv) Contact Information, such as your name, phone number, e-mail address, physical/mailing address, and any other information you choose to include when you interact and/or communicate with us through our Services and Platform, including through any interactive feature, online contact form, by e-mail, or any other communication mechanism.

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(v) Survey Information in response to surveys or questionnaires that we may send, including for feedback and research purposes.

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(vi) Social Media Data, whereby when you interact with any of our pages on social media services, like Facebook, X (formerly Twitter), Instagram, and LinkedIn (our “Social Media Pages”), we will collect the Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

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(vii) Mobile and App Data. If you use the Member App or mobile features, we may collect device identifiers, OS and version, configuration details, app and feature usage, crash and diagnostics data, limited network information, and related telemetry necessary to operate, secure, and troubleshoot the Services.

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(viii) Location & Push (if enabled). With your permission, we may access location information to support workflow requirements (e.g., visit verification, proximity-based functions) and send push notifications related to your account, tasks, or Services features. You can manage these permissions in your device settings.

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3.2 Wellup Subscribed Authorized User. If you are a subscriber Authorized User other than an Admin, including authorized representatives of a subscribing entity, we may collect and process the following types of Personal Data via the provision of the Services, including when accessing and/or using the Platform:

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(i) Transactional Information, including payment information and payment history if you engage in transactions through the Services or with us generally. All credit card information is stored by a third-party payment processor selected by us, from time to time, and such payment services are governed by such third-party payment processor’s terms of service and privacy policy. For the avoidance of doubt, your credit card information is never stored by the Company or on the Company’s servers.

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(ii) Contact Information, such as your name, company name, e-mail address, phone number, physical/mailing address, account information and any other information you choose to include when you interact and/or communicate with us through our Services, including through any interactive feature, online contact form, by e-mail, or any other communication mechanism.

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(iii) Account, Profile, and Subscription Information, such as your username and password, name, phone number, e-mail address, and physical/mailing address, when you subscribe to, register for access to the Platform, and/or sign up for an account through the Services.

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(iv) User Data, as certain features and functionalities of the Services may allow you to upload, deliver, submit, store, transmit, integrate or otherwise make available certain information, documents, text, files, images, graphics, data, and other materials and which, for the avoidance of doubt, may include certain Personal Data of the User.

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(v) Usage Details about your access to, use of, and interaction with our Services and about the features you use within the Services as well as the amount of the Services that you use, and the amount of time spent on the Services.

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(vi) Device Information, including the IP address and other details of the device that you use to access our Services (such as the Internet Service Provider, operating system, device name, browser type, browser activity, timestamps, and/or mobile network information).

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(vii) Location information, as we may use publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address.

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(viii) Crash and Error Information, whereby if the Services crash or return an error, we may collect certain data to determine the cause of the error using first or third-party services. The crash or error information collected may include, e.g., the following: device IP address, device name, operating system version, application configurations(s), timestamps, and other statistics.

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(ix) Survey Information in response to surveys or questionnaires that we may send, including for feedback and research purposes.

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(x) Social Media Data, whereby when you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

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4. Additional Information We May Obtain. We may obtain information about you from third-parties who help us provide the Services and from publicly available sources. Where we combine such information with Personal Information, we will treat the combined data as Personal Information and handle it in accordance with this Privacy Policy.

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5. Cookies and Other Technologies. Our Services may use “cookies” or “other technologies” (such as “pixel tags”, “web beacons”, “clear GIFs”, links in e-mails, JavaScript, device IDs assigned by Google or Apple, or similar technologies) to collect information and support certain features of our Services. Cookies and other technologies allow us and third-parties to obtain information about your visits to our Services, including analyzing your visiting patterns. Although you are not required to accept cookies when you visit our Services, you may be unable to use all of the functionality of our Services if your browser restricts our cookies. We use this information to process your requests and to deliver content, messages, and online advertisements from us and others that are specific to your interests. The information we collect from your web browser and from cookies and other technologies does not identify you personally but in some cases, we may link it to personally identifiable information.

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6.1 Cookies. Below, we explain the different types of cookies that may be used on the Services.

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6.1.1 Necessary Cookies. Necessary cookies are essential to enable your use of the Services, such as assisting with your account login, so we can show you the appropriate experience and features, service/transaction history and other account settings. They may also provide authentication and site security.

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6.1.2 Performance Cookies. Performance cookies are used to remember your settings and preferences, and to improve your experience on our Services.

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6.1.3 Session Cookies. Session cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser. We use session cookies to support the functionality of our Services and to understand your use of thereof, which pages that you visit, which links you use, and how long you stay on each page.

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6.1.4 Analytics Cookies. Analytics cookies help collect information about your use of our Services and enable us to improve the way it works. These cookies give us aggregated information that we use to monitor site performance, count page visits, spot technical errors, see how users reach the Services, and measure the effectiveness of marketing (including e-mails and text messages).

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6.1.5 Marketing Cookies. Marketing cookies are used to measure the performance of our advertising campaigns and to help us optimize our advertising resources. Unlike targeting cookies that build detailed user profiles, the marketing cookies which we employ are not used to track you across unrelated websites or to create personal behavioral profiles. Instead, these Marketing Cookies allow us to understand whether our ads are effective, how often they are clicked, and which campaigns generate results. The information is used solely for internal measurement and advertising/marketing campaign optimization purposes.

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6.1.6 Unclassified Cookies. Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

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6.2 Other Technologies. In addition to cookies, we may use other similar technologies, like pixel tags (also known as web beacons and clear GIFs), to, among other things, track the actions of users of the Services (about usage including e-mail recipients), measure the success of our marketing campaigns, and compile statistics of the Services and response rates.

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7. How We Use Your Information.

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7.1 For Our Legitimate Business Interests. We may use the Personal Data that we collect for our legitimate interests and the limited purpose of providing the Services and as permitted by applicable law. These purposes include circumstances where it is necessary to provide or fulfill the Services requested by or for you or where you have given us your express consent. As such, we may use your Personal Data to:

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(i) To provide, coordinate, and document SDOH-related navigation, referrals, and care-team workflows through the Wellup Platform, Administrative Portal, and Member App for authorized Navigators and Admins;

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(ii) To complete transactions between you and the Company;

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(iii) Provide the information and Services that you request;

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(iv) Create personalized materials and suggestions;

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(v) Service your account and provide you with effective customer service;

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(vi) Better understand your needs and interests, and provide you with a personalized experience when you use our Services;

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(vii) Contact you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);

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(viii) Contact you with information that you have requested, and notices related to your use of our Services;

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(ix) Send you commercial or marketing/advertising messages, including, without limitation, messages, including via newsletters and phone, text message (SMS), and e-mail communications about our offerings and Services;

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(x) Invite you to participate in surveys and to provide feedback to us (in accordance with any privacy preferences you have expressed to us);

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(xi) Improve our Services, develop new services, improve our marketing and promotional efforts, and improve the content, functionality, and usability of the Services;

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(xii) Enforce our other policies or agreements, such as any agreement between us and a specific customer or Authorized User with respect to such customer’s or Authorized User’s subscription or ability to receive certain access to and use of the Services;

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(xiii) Promote security and protect against and prevent fraud, claims, and other liabilities;

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(xiv) Verify the information that you provide to us as well as the representations and warranties that you make to us in a certain agreement or via the Services;

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(xv) Meet our internal and external audit obligations; and

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(xvi) To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third-parties.

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7.2 With Your Consent. In some cases, we will ask you for consent to use your Personal Data for specific purposes. If we do, we will make sure that you can revoke your consent in accordance with the “Your Choices” Section below.

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7.3 Other Purposes. If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to, or at the time that, the Personal Data is collected, or we will obtain your consent subsequent to such collection, but prior to such use.

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7.4 HIPAA, PHI & Business Associate Agreements. If you are a HIPAA Covered Entity or Business Associate and require the processing of Protected Health Information (“PHI”) in the Services, you must execute a Business Associate Agreement (“BAA”) with the Company before submitting PHI. In the absence of a BAA, you will not submit PHI to the Services. Where a BAA applies, the BAA governs with respect to PHI, and the Company may de-identify PHI in accordance with HIPAA (Safe Harbor or Expert Determination). De-identified data is treated as Aggregated/De-identified Data under this Policy.

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7.5 Aggregated Personal Data. We may aggregate and/or de-identify information collected through the Services and from other sources so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use de-identified or aggregated analytics to operate, support, improve, and develop the Services, AI features, and program-level insights; such analytics do not identify you, and we do not attempt to re-identify them.

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8. How We Share and Disclose Information.

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8.1 We Do Not Sell Personal Data. We do not ‘sell’ or ‘share’ your Personal Data for monetary consideration. This means that we do not exchange your Personal Data with third-parties in return for payment, nor do we disclose it for purposes that would constitute a “sale” or “sharing” under applicable privacy laws. As such we only disclose Personal Data that we collect about you as described herein or otherwise disclosed to you at the time the Personal Data is collected.

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8.2 Service Providers; Business Partners. We provide access to or share your Personal Data with select third-parties, including, but not limited to, business partners, service providers, subcontractors, and sub-processors (collectively, the “Service Providers”), who perform services on our behalf. Pursuant to our instructions, these third-parties will access, process, or store Personal Data in the course of performing their duties to us. We take commercially reasonable steps to ensure that our Service Providers adhere to the security standards that we apply to your Personal Data. Our Service Providers provide a variety of services to us, including, for example, billing, accounting, sales, marketing, analytics, data storage, payment processing, and legal services.

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8.3 Your Consent. We may ask for your consent to share your Personal Data with certain other third-parties and your ability to use and/or receive the Services may be impacted by your denial of any requested consent. We may share your information for other purposes pursuant to your consent or with your further direction.

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8.4 Settings. We may share information consistent with your setting selections within the Platform, as such settings functionality may be in effect from time to time.

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8.5 Aggregate/De-Identified Data. From time to time, we may share Aggregate/De-Identified Information about the use of the Services, such as by publishing a report on usage trends. Such analytics do not identify you, and we do not attempt to re-identify them. Certain Aggregated/De-identified analytics may be made available in a read-only De-identified Data Repository for eligible customers, subject to strict restrictions (e.g., no re-identification, no redistribution) in the applicable service terms.

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8.6 Legal Reasons. We may also disclose your Personal Data when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose your Personal Data, e.g., to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our Services; to enforce or apply our policies or other agreements; or to protect our own rights or property or the rights, property, or safety of our users or others. We will attempt to notify our users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague, or lack proper authority.

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8.7 Sale, Merger, or Other Business Transfer. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), Personal Data may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, your Personal Data would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable law, we will comply with such restrictions.

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9. Your Choices.

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(a) If you have registered for an Account, you may access, review, update, or delete certain Personal Data that you have provided to us by logging into your account and using available features and functionalities or by contacting us in accordance with the “Contact Us” Section below. You may also contact us to delete your Account. Please note that we will need to verify that you have the authority to delete the account and certain activity generated prior to deletion may remain stored by us and may be shared with third-parties as detailed in this Privacy Policy.

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(b) In certain circumstances, providing Personal Data is optional. However, if you choose not to provide any Personal Data that is needed to use some features of our Services, then you may be unable to use those features, which could affect your ability to perform your required duties as a Navigator or Admin. We will tell you what Personal Data that you must provide in order to receive the Services.

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(c) You can manage cookies through your browser and device settings and via industry tools such as www.allaboutcookies.org and www.aboutads.info/choices. Disabling cookies may limit some features. You may opt-out of marketing emails by clicking ‘unsubscribe’, and you may stop SMS by replying ‘STOP’. We may still send administrative or transactional communications. We do not respond to browser ‘Do Not Track’ (“DNT”) signals at this time. If you granted location or push permissions on a device, you can change those settings in your device OS at any time.

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10. Data Processing and Data Transfers. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries and territories, which may have different privacy laws from your country of residence. In such instances, we shall ensure that the transfer of your Personal Information is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place.

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11. Security. We take security seriously and have implemented administrative, physical, and technological measures to protect your information from unauthorized access, loss, misuse, disclosure, alteration and destruction. If you wish to report a security concern or if you have a question around security, please submit your inquiry to us in accordance with the “Contact Us” Section below.

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12. European Residents.

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12.1 Generally. If you are a resident of the European Economic Area, you may have certain rights regarding the Personal Data we maintain about you. We offer you certain choices about what Personal Data we collect from you, how we use that information, and how we communicate with you. If at any time you wish to exercise your rights, please reach out to us in accordance with the “Contact Us” Section.

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12.2 Information and Access. You can request to see which Personal Data we process from you. We can inform you how and why we process this data unless restricted by law, or if we are unable to verify your identity.

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12.3 Submitting Information. You may refrain from submitting information directly to us, although doing so may impact our ability to provide the services and information you request and/or affect your ability to access, use, and/or receive the Services.

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12.4 Rectification. You may request to update or correct the Personal Data that we maintain for you.

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12.5 Right to be Forgotten/Request Deletion. You may request deletion of your Personal Data. We may ask you for additional information to verify your identity and will process your request subject to and in accordance with the law.

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12.6 Restriction. You may request the limitation on the processing of your Personal Data.

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12.7 Restricting Cookies. Generally, if you do not wish to receive cookies, you may set your browser to deny cookies or to alert you when a cookie is placed on your computer.

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12.8 Objection. You may remove your consent for the processing of your Personal Data.

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12.9 Transferability. You may request to transfer your Personal Data.

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13. Additional Information for Residents of Certain U.S. States. If you are a U.S. resident, we process your Personal Data in accordance with applicable U.S. state data privacy laws. Depending on where you live, you may be entitled to certain rights with respect to your Personal Information, as further described in Exhibit A.

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14. Personal Data Retention. We retain Personal Information only as long as necessary to provide the Services, meet legal requirements, enforce agreements, resolve disputes, or support permitted operational uses (such as maintaining Aggregated/De-identified Data). Afterward, we delete or de-identify data consistent with our retention policies.

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15. Links to Third-party Websites. The Services may contain links to other websites not operated or controlled by us, including social media services (“Third-party Websites”). The information that you share with Third-party Websites will be governed by the specific privacy policies and terms of service of the Third-party Websites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these websites. Please contact the Third-party Websites directly for information on their privacy practices and policies.

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16. Privacy of Children. The Services are intended for Users who are eighteen (18) years of age or older. We do not knowingly collect Personal Information from children under the age of thirteen (13). If we learn that a child under such age has provided Personal Information, we will delete it.

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17. Contact Us. If you have any questions or concerns about our Privacy Policy, please contact us via e-mail at info@wellup.io.

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EXHIBIT A

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U.S. State-Specific Privacy Information

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This Exhibit A is designed to be consistent with California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, Minnesota, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia privacy laws, and provides you with certain U.S. State-specific disclosures and rights which may be applicable and afforded to you depending on your U.S. State of residency.

Additional Information for California Residents

If you are a resident of the State of California, you may have certain rights afforded to you under the California Consumer Privacy Act or the “CCPA”, as amended by the California Privacy Rights Act.

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We collect Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section, and we share Personal Information with the categories of third-parties described in “How We Share and Disclose Information” Section. We do not ‘sell’ (as such term is defined in the CCPA) the Personal Information that we collect (and will not sell it without providing you with a right to opt-out).

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California law, if applicable to us, provides some California residents with the rights listed below:

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(i) You may have the right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices.

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(ii) You may have the right to request that we delete your Personal Information that we have collected from you.

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(iii) You may have the right to request that we correct your inaccurate Personal Information.

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(iv) You may have the right to exercise control over our collection and processing of certain sensitive Personal Information.

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(v) You have the right not to receive retaliatory or discriminatory treatment for exercising these rights.

To request access to or deletion of your Personal Information, or to exercise any other privacy rights under California law, please contact us via any method which may be specified in the “Contact Us” Section. In order to verify your request, we may require you to provide us with certain information to be used solely for the purpose of verifying your identity.

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Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.

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Additional Information for Colorado Residents

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The Colorado Privacy Act, if applicable to us, provides some Colorado residents with the rights listed below:

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(i) You may have the right to know and see what Personal Information we have collected about you in a portable format.

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(ii) You may have the right to request that we correct your inaccurate Personal Information.

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(iii) You may have the right to request that we delete the Personal Information we have collected about you.

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(iv) You may have the right to opt out of targeted advertising and the sale of Personal Information, as each is defined under Colorado law; however, please note that we do not currently perform or conduct any of the foregoing.

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To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Colorado law, please contact us via any method which may be specified in the “Contact Us” Section.

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Please note that to respond to some rights we may need to verify your request by asking you to verify your identity by providing certain information about yourself. You may designate another person to serve as your authorized agent and to exercise your opt-out right on your behalf; however, we may request certain information in order to verify your identity and the authorized agent’s authority to act on your behalf.

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Additional Information for Connecticut Residents

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The Connecticut Data Privacy Act, if applicable to us, provides some Connecticut residents with the rights listed below:

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(i) You may have the right to know and see what Personal Information we have collected about you in a portable format.

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(ii) You may have the right to request that we correct your inaccurate Personal Information.

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(iii) You may have the right to request that we delete the Personal Information we have collected about you.

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(iv) You may have the right to opt-out of targeted advertising, the sale of Personal Information, and automated profiling, as each is defined under Connecticut law; however, please note that we do not currently perform or conduct any of the foregoing.

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To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Connecticut law, please contact us via any method which may be specified in the “Contact Us” Section.

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Additional Information for Delaware Residents

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If you are a Delaware resident, pursuant to the Delaware Personal Information Privacy Act, we must share with you that:

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(i) We collect Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section;

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(ii) We may share your Personal Information to third-parties as described in the “How We Share and Disclose Your Information” Section; and

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(iii) We collect the categories of Personal Information described in the “What Information We Collect” Section.

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Delaware law, if applicable to us, provides some Delaware residents with the rights listed below:

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(i) You may have the right to know and see what Personal Information we have collected about you in a portable format.

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(ii) You may have the right to request that we correct inaccuracies in the Personal Information we have collected about you.

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(iii) You may have the right to request that we delete the Personal Information you provided or that we have collected about you.

(iv) You may have the right to opt-out of targeted advertising, the sale of Person Data, and automated profiling, as each is defined under Delaware law; however, please note that we do not currently perform or conduct any of the foregoing.

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(v) You may have the right to obtain a list of the specific third-parties to which the Personal Information was disclosed.

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To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Delaware law, please contact us via any method which may be specified in the “Contact Us” Section.

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Additional Information for Florida Residents

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If you are a Florida resident, pursuant to the Florida Digital Bill of Rights, we must share with you that:

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(i) We collect Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section;

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(ii) We may share your Personal Information to third-parties as described in the “How We Share and Disclose Information” Section; and

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(iii) We collect the categories of Personal Information described in the “What Information We Collect” Section.

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Florida law, if applicable to us, provides some Florida residents with the rights listed below:

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(i) You may have the right to know and see what Personal Information we have collected about you in a portable format.

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(ii) You may have the right to request that we correct inaccuracies in the Personal Information we have collected about you.

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(iii) You may have the right to request that we delete the Personal Information you provided or we have collected about you.

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(iv) You may have the right to opt-out of targeted advertising, the sale of Personal Information, and automated profiling, as each is defined under Florida law; however, please note that we do not currently perform or conduct any of the foregoing.

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(v) You may have the right to opt-out of the collection and processing of sensitive data, as defined under Florida law.

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To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Florida law, please contact us via any method which may be specified in the “Contact Us” Section.

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Please note that to respond to some rights we may need to verify your request by asking you to verify your identity by providing certain information about yourself.

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Additional Information for Indiana Residents

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If you are an Indiana resident, pursuant to the Indiana Consumer Data Protection Act, we must share with you that:

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(i) We collect Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section;

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(ii) We may share your Personal Information to third-parties as described in the “How We Share and Disclose Information” Section; and

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(iii) We may share the categories of Personal Information described in the “How We Share and Disclose Information” Section; and

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(iii) We collect the categories of Personal Information described in the “What Information We Collect” Section.

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Indiana law, if applicable to us, provides some Indiana residents with the rights listed below:

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(i) You may have the right to know and see what Personal Information we have collected about you and receive either a copy or representative summary of such Personal Information in a portable format.

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(ii) You may have the right to request that we correct inaccuracies in the Personal Information we have collected about you.

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(iii) You may have the right to request that we delete the Personal Information you provided or that we have collected about you.

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(iv) You may have the right to opt-out from our processing of your Personal Information for any of the following purposes: (a) targeted advertising, (b) selling your Personal Information, or (c) profiling in furtherance of decisions that produce legal effects or effects of similar significance; however, please note that we do not, at this time, process your Personal Information for any of the above-mentioned purposes.

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To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Indiana law, please contact us via any method which may be specified in the “Contact Us” Section. If you would like to appeal our refusal to take action on a prior submitted request, you may do so by submitting an appeal to us via any method which may be specified in the “Contact Us” Section.

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Please note that to respond to some rights we may need to verify your request by asking you to verify your identity by providing certain information about yourself.

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Additional Information for Iowa Residents

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If you are an Iowa resident, pursuant to the Iowa Consumer Data Protection Act, we must share with you that:

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(i) We collect Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section;

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(ii) We may share your Personal Information to third-parties as described in the “How We Share and Disclose Information” Section; and

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(iii) We collect the categories of Personal Information described in the “What Information We Collect” Section.

Iowa law, if applicable to us, provides some Iowa residents with the rights listed below:

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(i) You may have the right to know and see what Personal Information we have collected about you in a portable format.

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(ii) You may have the right to request that we delete the Personal Information you provided or that we have collected about you.

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(iii) You may have the right to opt-out of the sale of Personal Information, as such is defined under Iowa law; however, please note that we do not currently sell Personal Information.

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To request deletion of your Personal Information, or to exercise any other privacy rights under Iowa law, please contact us via any method which may be specified in the “Contact Us” Section.

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Please note that to respond to some rights we may need to verify your request by asking you to verify your identity by providing certain information about yourself.

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Additional Information for Kentucky Residents

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If you are a Kentucky resident, pursuant to the Kentucky Consumer Data Protection Act, we must share with you that:

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(i) We collect Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section;

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(ii) We may share your Personal Information to third-parties as described in the “How We Share and Disclose Information” Section;

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(iii) We may share the categories of Personal Information described in the “How We Share and Disclose Information” Section; and

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(iv) We collect the categories of Personal Information described in the “What Information We Collect” Section.

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Kentucky law, if applicable to us, provides some Kentucky residents with the rights listed below:

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(i) You may have the right to know and see what Personal Information we have collected about you in a portable format.

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(ii) You may have the right to request that we correct inaccuracies in the Personal Information we have collected about you.

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(iii) You may have the right to request that we delete the Personal Information you provided or that we have collected about you.

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To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Kentucky law, please contact us via any method which may be specified in the “Contact Us” Section. If you would like to appeal our refusal to take action on a prior submitted request, you may do so by submitting an appeal to us via any method which may be specified in the “Contact Us” Section.

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Please note that to respond to some rights we may need to verify your request by asking you to verify your identity by providing certain information about yourself.

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Additional Information for Montana Residents

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If you are a Montana resident, pursuant to the Montana Consumer Data Privacy Act, we must share with you that:

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(i) We collect Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section;

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(ii) We may share your Personal Information to third-parties as described in the “How We Share and Disclose Information” Section; and

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(iii) We collect the categories of Personal Information described in the “What Information We Collect” Section.

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Montana law, if applicable to us, provides some Montana residents with the rights listed below:

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(i) You may have the right to know and see what Personal Information we have collected about you in a portable format.

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(ii) You may have the right to request that we correct inaccuracies in the Personal Information we have collected about you.

‍

(iii) You may have the right to request that we delete the Personal Information you provided or that we have collected about you.

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(iv) You may have the right to opt out of targeted advertising, the sale of Personal Information, and automated profiling, as each is defined under Montana law; however, please note that we do not currently perform or conduct any of the foregoing.

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(v) You may have the right to obtain a list of the specific third-parties to which the Personal Information was disclosed.

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To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Montana law, please contact us via any method which may be specified in the “Contact Us” Section.

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Additional Information for Minnesota Residents

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If you are a Minnesota resident, pursuant to the Minnesota Consumer Data Privacy Act, we must share with you that:

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(i) We collect and process the categories of Personal Information described in the “What Information We Collect” Section;

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(ii) We process Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section;

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(iii) We may share the categories of Personal Information described in the “How We Share and Disclose Information” Section; and

(iv) We may retain Personal Information according to the “Personal Information Retention” Section.

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Minnesota law, if applicable to us, provides some Minnesota residents with the rights listed below:

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(i) You may have the right to receive confirmation as to whether we are processing your Personal Information and the right to access such Personal Information.

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(ii) You may have the right to request that we correct inaccuracies in the Personal Information we have collected about you; however, in deciding whether to comply with such request, we may take into account the nature of the Personal Information and the purpose(s) for processing the Personal Information.

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(iii) You may have the right to request that we delete the Personal Information you provided or that we have collected about you.

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(iv) If the such data is available in a digital format, you may have the right to receive a copy of your Personal Information that you previously provided to us in a portable format and, to the extent technically feasible, in a readily usable format that allows you to transmit the data to another controller without hinderance where the processing is carried out by automated means.

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(v) You may have the right to opt-out from our processing of your Personal Information for any of the following purposes: (a) targeted advertising, (b) the sale of your Personal Information, or (c) profiling in furtherance of automated decisions that produce a legal or similarly significant effect concerning yourself; however, please note that we do not, at this time, process your Personal Information for any of the above-mentioned purposes.

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(vi) If the right in the above (v) is exercised, you may have the right to question the result of the profiling, to be informed of the reason that the profiling resulted in the decision, and, if feasible, to be informed of what actions you might have taken to secure a different decision and the actions you might do to secure a different decision in the future. You have the right to review your Personal Information used in profiling. If the decision is determined to have been based upon inaccurate Personal Information, taking into account the nature of the Personal Information and the purpose(s) of the processing, you have the right to have the data corrected and the profiling decision reevaluated based on the corrected data. However, please note that we do not, at this time, process your Personal Information for targeted advertising, the sale of your Personal Information, or profiling in furtherance of automated decisions that produce a legal or similarly significant effect concerning yourself.

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(vii) You may have the right to obtain a list of specific third-parties to which we have disclosed your Personal Information, if available, and, if not available, a list of specific third-parties to which we have provided any consumer’s Personal Information.

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To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Minnesota law, please contact us via any method which may be specified in the “Contact Us” Section.

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Please note that to respond to some rights we may need to verify your request by asking you to verify your identity by providing certain information about yourself. You may designate another person to serve as your authorized agent and to exercise your opt-out right on your behalf concerning processing for the purposes of targeted advertising and the sale of your Personal Information; however, we may request certain information in order to verify your identity and the authorized agent’s authority to act on your behalf.

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Additional Information for Nebraska Residents

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If you are a Nebraska resident, pursuant to the Nebraska Data Privacy Act, we must share with you that:

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(i) We collect Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section;

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(ii) We may share your Personal Information to third-parties as described in the “How We Share and Disclose Information” Section; and

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(iii) We collect the categories of Personal Information described in the “What Information We Collect” Section.

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Nebraska law, if applicable to us, provides some Nebraska residents with the rights listed below:

‍

(i) You may have the right to know and see what Personal Information we have collected about you in a portable format.

‍

(ii) You may have the right to request that we correct inaccuracies in the Personal Information we have collected about you.

‍

(iii) You may have the right to request that we delete the Personal Information you provided or that we have collected about you.

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(iv) You may have the right to opt-out of targeted advertising, the sale of Personal Information, and automated profiling, as each is defined under Nebraska law; however, please note that we do not currently perform or conduct any of the foregoing.

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To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Nebraska law, please contact us via any method which may be specified in the “Contact Us” Section.

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Please note that to respond to some rights we may need to verify your request by asking you to verify your identity by providing certain information about yourself.

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Additional Information for Nevada Residents

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If you are a Nevada resident, under Privacy and Security of Personal Information Chapter of the Nevada Revised Statutes Section 603A, we are required to provide you with the following:

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(i) We may collect certain covered information (as defined under Nevada Law) when you use or visit our Website and/or receive our Services, including, but not limited to first and last name, home or other physical address, e-mail address, and telephone number;

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(ii) We may share your covered information to third-parties as described in the “How We Share and Disclose Information” Section; and

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(iii) Third-parties may collect covered information about your online activities over time and across different internet websites or online websites when you use our Website and/or receive our Services.

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Under Nevada law, certain Nevada consumers may opt-out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has provided “personally identifiable information” to us via the Services, you may submit a request to opt-out of any potential future sales under Nevada law by contacting us via any other which may be specified in the “Contact Us” Section. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

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Additional Information for New Hampshire Residents

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If you are a New Hampshire resident, pursuant to Title LII, Chapter 507-H: Expectation of Privacy of the New Hampshire Revised Statutes Annotated, we must share with you that:

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(i) We collect Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section;

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(ii) We may share your Personal Information to third-parties as described in the “How We Share and Disclose Information” Section; and

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(iii) We collect the categories of Personal Information described in the “What Information We Collect” Section.

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New Hampshire law, if applicable to us, provides some New Hampshire residents with the rights listed below:

‍

(i) You may have the right to know and see what Personal Information we have collected about you in a portable format.

‍

(ii) You may have the right to request that we correct inaccuracies in the Personal Information we have collected about you.

‍

(iii) You may have the right to request that we delete the Personal Information you provided or that we have collected about you.

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(iv) You may have the right to opt-out of targeted advertising, the sale of Personal Information, and automated profiling, as each is defined under New Hampshire law; however, please note that we do not currently perform or conduct any of the foregoing.

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To request access to or deletion of your Personal Information, or to exercise any other privacy rights under New Hampshire law, please contact us via any method which may be specified in the “Contact Us” Section.

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Additional Information for New Jersey Residents

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If you are a New Jersey resident, pursuant to Title 56, Chapter 266 of the New Jersey Revised Statutes, we must share with you that:

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(i) We collect Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section;

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(ii) We may share your Personal Information to third-parties as described in the “How We Share and Disclose Information” Section; and

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(iii) We collect the categories of Personal Information described in the “What Information We Collect” Section.

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New Jersey law, if applicable to us, provides some New Jersey residents with the rights listed below:

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(i) You may have the right to know and see what Personal Information we have collected about you in a portable format.

(ii) You may have the right to request that we correct inaccuracies in the Personal Information we have collected about you.

‍

(iii) You may have the right to request that we delete the Personal Information you provided or that we have collected about you.

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(iv) You may have the right to opt-out of targeted advertising, the sale of Personal Information, and automated profiling, as each is defined under New Jersey law; however, please note that we do not currently perform or conduct any of the foregoing.

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To request access to or deletion of your Personal Information, or to exercise any other privacy rights under New Jersey law, please contact us via any method which may be specified in the “Contact Us” Section.

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Additional Information for Oregon Residents

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If you are an Oregon resident, pursuant to the Oregon Consumer Privacy Act, we must share with you that:

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(i) We collect and process the categories of Personal Information described in the “What Information We Collect” Section;

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(ii) We process Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section; and

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(iii) We may share the categories of Personal Information described in the “What Information We Collect” Section with the categories of third-parties set forth in the “How We Share and Disclose Information” Section.

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Oregon Law, if applicable to us, provides some Oregon residents with the rights listed below:

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(i) You may have the right to receive confirmation as to whether we are processing or have processed your Personal Information and the categories of Personal Information that we are processing or have processed.

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(ii) You may have the right to receive, at our option and sole discretion, a list of specific third-parties, other than natural persons, to which the we have disclosed your specific Personal Information to or any Personal Information to, generally.

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(iii) You may have the right to receive a copy of all of your Personal Information that we have processed or are processing in a portable format.

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(iv) You may have the right to request that we correct inaccurate Personal Information; however, in deciding whether to comply with such request, we may take into account the nature of the Personal Information and the purpose(s) for processing the Personal Information.

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(v) You may have the right to request that we delete your Personal Information, including your Personal Information which you have provided to us, your Personal Information which we have obtained from another source, and derived data.

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(vi) You may have the right to opt-out from our processing of your Personal Information for any of the following purposes: (a) targeted advertising, (b) selling your Personal Information, or (c) profiling in furtherance of decisions that produce legal effects or effects of similar significance; however, please note that we do not, at this time, process your Personal Information for any of the above-mentioned purposes.

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To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Oregon law, please contact us via any method which may be specified in the “Contact Us” Section. If you would like to appeal our refusal to take action on a prior submitted request, you may do so by submitting an appeal to us via any method which may be specified in the “Contact Us” Section.

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Please note that to respond to some rights we may need to verify your request either by asking you to log in and authenticate your account or otherwise verify your identity by providing information about yourself or your account. You may designate another person to serve as your authorized agent and to act on your behalf to opt-out of the processing of your Personal Information under specifically Section (vi) above; however, we may request certain information in order to verify your identity and the authorized agent’s authority to act on your behalf.

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Additional Information for Rhode Island Residents

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If you are a Rhode Island resident, pursuant to the Rhode Island Data Transparency and Privacy Protection Act, we must share with you that:

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(i) We collect Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section;

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(ii) We may share your Personal Information to third-parties as described in the “How We Share and Disclose Information” Section;

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(iii) We may share the categories of Personal Information described in the “How We Share and Disclose Information” Section; and

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(iv) We collect the categories of Personal Information described in the “What Information We Collect” Section.

‍

Rhode Island law, if applicable to us, provides some Rhode Island residents with the rights listed below:

‍

(i) You may have the right to know and see what Personal Information we have collected about you in a portable format.

‍

(ii) You may have the right to request that we correct inaccuracies in the Personal Information we have collected about you.

‍

(iii) You may have the right to request that we delete the Personal Information you provided or that we have collected about you.

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(iv) You may have the right to opt-out from our processing of your Personal Information for any of the following purposes: (a) targeted advertising, (b) selling your Personal Information, or (c) profiling in furtherance of solely automated decisions that produce legal effects or effects of similar significance; however, please note that we do not, at this time, process your Personal Information for any of the above-mentioned purposes.

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To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Rhode Island law, please contact us via any method which may be specified in the “Contact Us” Section. If you would like to appeal our refusal to take action on a prior submitted request, you may do so by submitting an appeal to us via any method which may be specified in the “Contact Us” Section.

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Additional Information for Tennessee Residents

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If you are a Tennessee resident, pursuant to the Tennessee Information Protection Act, we must share with you that:

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(i) We collect and process the categories of Personal Information described in the “What Information Do We Collect” Section;

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(ii) We process Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section; and

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(iii) We may share your Personal Information to/with third-parties as described in the “How We Share and Disclose Information” Section.

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Tennessee law, if applicable to us, provides some Tennessee residents with the rights listed below:

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(i) You may have the right to receive confirmation as to whether we are processing your Personal Information and the right to access such Personal Information.

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(ii) You may have the right to request that we correct inaccuracies with respect to your Personal Information; however, in deciding whether to comply with such request, we may take into account the nature of the Personal Information and the purpose(s) for processing the Personal Information.

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(iii) You may have the right to request that we delete your Personal Information which you provided or that we have collected about you; however, we may not delete information that we maintain or use as aggregate or de-identified data provided it is not linked to a specific consumer.

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(v) You may have the right to opt-out from our selling of your Personal Information; however, please note that we do not currently sell Personal Information.

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(vi) If we sold or disclosed your Personal Information, you may request that we share: (a) the categories of Personal Information shared, (b) the categories of third-parties to which the Personal Information was sold, and (c) the categories of Personal Information we disclosed for a business purpose; however, please note that we do not currently sell Personal Information.

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To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Tennessee law, please contact us via any method which may be specified in the “Contact Us” Section. If you would like to appeal our refusal to take action on a prior submitted request, you may do so by submitting an appeal to us via any method which may be specified in the “Contact Us” Section.

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Please note that to respond to some rights we may need to verify your request by asking you to verify your identity by providing information about yourself.

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Additional Information for Texas Residents

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If you are a Texas resident, pursuant to the Texas Data and Privacy Security Act, we must share with you that:

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(i) We collect and process the categories of Personal Information described in the “What Information We Collect” Section;

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(ii) We process Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section; and

‍

Texas law, if applicable to us, provides some Texas residents with the rights listed below:

‍

(i) You may have the right to receive confirmation as to whether we are processing your Personal Information and the right to access such Personal Information.

‍

(iii) You may have the right to request that we delete your Personal Information which you provided or that we have collected about you.

‍

(v) You may have the right to opt-out from our processing of your Personal Information for any of the following purposes: (a) targeted advertising, (b) the sale of your Personal Information, or (c) profiling in furtherance of decisions that produce a legal or similarly significant effect concerning yourself; however, please note that we do not, at this time, process your Personal Information for any of the above-mentioned purposes.

‍

To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Texas law, please contact us via any method which may be specified in the “Contact Us” Section. If you would like to appeal our refusal to take action on a prior submitted request, you may do so by submitting an appeal to us via any method which may be specified in the “Contact Us” Section.

‍

Please note that to respond to some rights we may need to verify your request by asking you to verify your identity by providing information about yourself. You may designate another person to serve as your authorized agent and to act on your behalf to opt-out of the processing of your Personal Information under specifically Section (v)(a)-(b) above; however, we may request certain information in order to verify your identity and the authorized agent’s authority to act on your behalf.

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Additional Information for Utah Residents

‍

If you are a Utah resident, pursuant to the Utah Consumer Privacy Act, we must share with you that:

‍

(i) We collect Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section;

(ii) We may share your Personal Information to third-parties as described in the “How We Share and Disclose Information” Section; and

‍

(iii) We collect the categories of Personal Information described in the “What Information We Collect” Section.

‍

Utah law, if applicable to us, provides some Utah residents with the rights listed below:

‍

(i) You may have the right to know and see what Personal Information we have collected about you in a portable format.

‍

(ii) You may have the right to request that we delete the Personal Information we have collected about you.

‍

(iii) You may have the right to opt-out of targeted advertising and the sale of Personal Information, as each is defined under Utah law; however, please note that we do not currently perform or conduct any of the foregoing.

‍

To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Utah law, please contact us via any method which may be specified in the “Contact Us” Section.

‍

Additional Information for Virginia Residents

‍

If you are a Virginia resident, pursuant to the Virginia Consumer Privacy Act, we must share with you that:

‍

(i) We collect Personal Information for the business and commercial purposes described in the “How We Use Your Information” Section;

‍

(ii) We may share your Personal Information to third-parties as described in the “How We Share and Disclose Information” Section; and

‍

(iii) We collect the categories of Personal Information described in the “What Information We Collect” Section.

‍

Virginia law, if applicable to us, provides some Virginia residents with the rights listed below:

(i) You may have the right to know and see what Personal Information we have collected about you.

‍

(ii) You may have the right to request that we correct your inaccurate Personal Information.

‍

(iii) You may have the right to request that we delete the Personal Information we have collected about you.

‍

(iv) You may have the right to opt-out of targeted advertising, the sale of Personal Information, and automated profiling, as each is defined under Virginia law; however, please note that we do not currently perform or conduct any of the foregoing.

‍

To request access to or deletion of your Personal Information, or to exercise any other privacy rights under Virginia law, please contact us via any method which may be specified in the “Contact Us” Section.

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[End of Exhibit A]

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[End of Privacy Policy]

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