Privacy Policy for Ubie

Ubie, Inc. ("Ubie", "we", "us" or "our") understands the importance of protecting the privacy of those who provide us with their information.
This Privacy Policy (this "Policy") describes how we may collect, use, disclose, store, transfer, and otherwise process your Personal Data (defined in clause 1.1 below) when you:

1. access or use our website and applications (mobile, web-based, or otherwise), including AI Health Assistant and AI Symptom Checker (collectively, the "Applications"), our Ubie Account (mobile, web-based, or otherwise) ("Ubie Account"), and other services we provide; and/or
2. provide us with your Personal Data, regardless of the medium through which such Personal Data is provided.

Please read this Policy to understand how we handle your Personal Data. By accessing or using any of our services, including the Applications or Ubie Account, you agree to have read, understood, and consented to our collection, use, and disclosure (including transfer) of your Personal Data in accordance with this Policy. If you do not agree to this Policy, please do not access or use our services, including any Applications or Ubie Account.

This Policy may be available in languages other than English. To the extent of any inconsistency or conflict, the English language version of this Policy shall prevail.

1. Information We Collect
   1. For the purposes of this Policy, "Personal Data" shall mean data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including but not limited to name, identification number, birth date, address, postal code, and contact information. Such Personal Data shall also refer to that which is already in our possession or that which shall be collected by us in the future.
   2. We may collect your Personal Data directly or indirectly, through various channels, such as when:
      1. you access or use the Applications;
      2. you use our services or enter into transactions with us;
      3. you contact us by telephone, email, via our Applications, or any other means;
      4. we seek information about you and receive your Personal Data in connection with your relationship or business dealings with us;
      5. you register for and/or attend events organized by us; and/or
      6. you provide us with your Personal Data for any other reason.
   3. The information we obtain about you may include:
      1. name, age, gender, date of birth, pronoun, ethnicity, state of residence, telephone number, e-mail address, occupation, external app's ID connected with the Ubie Account, and other information that can identify you;
      2. medical/health-related information that you input or answer in the Applications, including symptoms, symptoms’ frequency, medical history, course of treatment, drug dosage, date of diagnosis, medical test scores, medication you have taken in the past, the medication you are taking currently, prescription drugs prescribed, and prescription-related information;
      3. information in relation to the medical/healthcare institution that you have visited or regularly visit, including the name of the medical/healthcare institutions, departments, and physicians, the date and time of your past and future appointments;
      4. contents that you accessed in the Applications, history of use, frequency, online action when using the Applications, usage- or browsing-related information, including the time and date of your visit, your IP Address, Cookie (defined in clause 2.8 below), the pages and files of our site that you visit, website from which access is obtained (also known as Referrer URL), various statistics such as the time you spend on certain pages on our sites, device, operating system, location, browser, browser language, and other user's communication-related information;
      5. account-related information including login ID and password;
      6. information related to healthcare insurance in which you enroll; and
      7. any such information as we deem reasonably necessary or appropriate from time to time in connection with the Applications to be provided to you.
2. Collection, Use, Transfer and Disclosure of Personal Data
   1. We collect your Personal Data when (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your Personal Data to us (your "authorized representative") after (i) you (or your authorized representative) have been notified of the purposes for which the Personal Data is collected, and (ii) you (or your authorized representative) have provided consent to the collection and usage of your Personal Data for those purposes, or (b) collection and use of Personal Data without consent is permitted or required by any applicable laws. We shall seek your consent before collecting any additional Personal Data and before using your Personal Data for a purpose which has not been notified to you (except where permitted or authorized by law).
   2. We may collect, use and store your Personal Data for any or all of the following purposes:
      1. offer our services, including the Applications or the Ubie Account and conduct user verification;
      2. provide users with reference information, which means the information that we provide for users' reference in the Applications, including health-related information;
      3. provide users with information in relation to medical/healthcare institutions;
      4. enable users to view their own information in the Applications or the Ubie Account;
      5. facilitate users inputting information to other connected services or information sharing between services;
      6. carry out research, improvement and development of our services, including new services;
      7. carry out marketing or business development of our products and services and/or those of our business partners;
      8. provide our business partners or customers (including pharmaceutical companies and insurance companies) with our services within the scope specified in this Policy;
      9. enable user to connect the Applications or the Ubie Account with other services requested by users;
      10. facilitate sales, promotion, and purchase of our goods and services and/or those of our business partners;
      11. provide user support and respond to queries;
      12. inform users of the changes of the terms or conditions of the Applications or the Ubie Account or other services we offer;
      13. display our or third party's advertisements, carry out measurement of advertising effectiveness;
      14. any other purposes for which you have provided the information; and/or
      15. any other purposes directly related to and/or reasonably required to achieve the above.
   3. We may disclose or transfer your Personal Data:
      1. where such disclosure or transfer is necessary for performing obligations in the course of or in connection with our provisions of the services requested by you;
      2. where such disclosure or transfer is required by any applicable laws, regulations, codes of practice, guidelines or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and
      3. to any third parties such as below, whether in your country or abroad, for the purposes listed in clause 2.2 above;
         1. any related and associated companies, affiliates, and subsidiaries of Ubie, including those established in the future and those in your country;
         2. any data intermediaries processing your Personal Data on our behalf;
         3. where applicable, third parties who provide related services or products in connection with our business such as our vendors (including the providers of digital analytics tools), business partners, pharmaceutical companies, insurance companies, and any party assisting us in carrying out the purposes above;
         4. our business partners (including pharmaceutical companies and insurance companies) which conduct sales, marketing, and business development;
         5. any agent, contractor, or service provider who provides administrative, order processing, payment clearing, credit reference, debt collecting, or other services necessary to the operation of our business;
         6. organizations including professional service providers and relevant regulatory authorities whether within or outside your country, in connection with the acquisition, disposition, and/or intended acquisition or disposition of Ubie's assets and/or Ubie itself whether directly or indirectly;
         7. any party or organization who are bound by confidentiality agreements with us;
         8. any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any applicable law; including, but not limited to government agencies, statutory authorities, and industry regulators; and
         9. our auditors, consultants, accountants, lawyers, or other financial or professional advisers.
   4. The third parties set out above may be situated in your country or elsewhere. You fully understand and unambiguously consent that we may transfer your Personal Data to any location outside of your country for the purposes set out above. We are committed to implementing measures to safeguard your Personal Data when it is transferred across jurisdictions. We aim to ensure that your Personal Data receives an adequate level of protection regardless of the jurisdiction to which it is transferred.
   5. As the accuracy of your Personal Data depends largely on the information you provide to us, you warrant and represent that Personal Data which you disclose to us shall be accurate and complete. If you provide us with Personal Data relating to a third party, you warrant and represent to us that you have obtained the consent of the third party and are authorized by the third party to do so. Please kindly update us as soon as possible if there are any errors or if there have been any changes to your Personal Data by informing our Data Protection / Grievance Officer in writing or via email at the contact details provided in clause 9 below.
   6. We may use your Personal Data for the purposes of marketing our products and services and those of our business partners (e.g., informing you of our latest activities, special offers, and promotions). In order for us to market products and services which are of special interest and relevance to you, we may analyze and rely on your overall interaction with us (such as but not limited to your participation in promotions or events and your interactions with us).
   7. The decision to provide us with your Personal Data is solely yours to make, but you acknowledge that we require certain types of Personal Data so that we can provide our services to you and if you decline to provide us with such Personal Data, or request us to delete it, we may not be able to provide our services to you.
   8. We may use cookies ("Cookies"), pixels, software development kids, or other tracking technologies on the Applications to track website or application visitorship and experience. Most web browsers are designed to accept Cookies. If you do not wish to receive any Cookies, you may set your browser to refuse them. However, this may affect the functionality of the Applications.
   9. We use Google Analytics provided by Google LLC on our Applications or the Ubie Account to research and analyze the usage of our Applications or Ubie Account. Google Analytics uses cookies and other mechanisms to track your usage and other information. If you do not want your data to be used by Google Analytics, please use the Google Analytics opt-out add-on provided by Google, available at:https://tools.google.com/dlpage/gaoptout?hl=en.
   10. Please be informed that when you use any Applications, such Applications may acquire information such as your location, device identification details, as well as mobile device information, if you permit us to do so. If you do not wish to provide us with such information, you may activate the function to disable location on your mobile device at any time. However, this may affect the functionality of the Applications.
3. Withdrawing Your Consent
   1. The consent that you provide for the collection, use, and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed in clauses 2.2 and 2.3 above by submitting your request in writing or via email to our Data Protection / Grievance Officer at the contact details provided in clause 9 below. Termination of your Ubie Account does not automatically constitute withdrawal of your consent.
   2. Upon receipt of your request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
   3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be able to continue providing our goods or services to you because your Personal Data may be necessary to process your request. Accordingly, withdrawal of your consent may result in the termination of your Ubie Account. We shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 3.1 above.
   4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclosure without consent is permitted or required under applicable laws.
4. Retention of Personal Data
   1. We retain your Personal Data for as long as we reasonably need the Personal Data to fulfill the purposes for which we collected it, to satisfy our business and/or legal purposes, including audit, accounting, or reporting requirements, or as otherwise permitted or required by applicable laws.
   2. In some circumstances, we may deidentify your Personal Data so that it can no longer be associated with you, in which case we are entitled to retain and use such data as non-Personal Data. We will maintain such deidentified data in deidentified form and will not reidentify such data, except in accordance with the requirements of applicable law.
5. Protection of Personal Data
   1. While precautions will be taken to protect the Personal Data you provide against unauthorized or unintended access, we cannot be held responsible for unauthorized or unintended access that is reasonably beyond our control.
   2. To safeguard your Personal Data from unauthorized access, collection, use, disclosure, or similar risks, we, to the extent required by relevant laws, have introduced appropriate administrative, physical, and technical measures such as up-to-date antivirus protection and disclosing Personal Data both internally and to our authorized third-party service providers and agents only on a need-to-know basis.
   3. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. It is your obligation to protect your access credentials (e.g., user ID and password) from unauthorized access.
6. Use of Aggregate Data

   Ubie may use your Personal Data on an aggregate basis to create statistical data based on which individuals cannot be identified.
   
   Given the nature of such aggregate data not being able to be associated with specific individuals, Ubie may use such aggregate data as non-Personal Data for various statistical purposes. We will maintain such aggregate data in aggregate form and will not reidentify such data, except in accordance with the requirements of applicable law.

7. Your Rights to Access, Limit and Correct Your Personal Data

   If you have any inquiries, complaints or questions about this Policy, you may contact us using the contact details provided in clause 9 below at any time, and applicable laws may allow you to:

   1. check whether we hold or use your Personal Data and request access to such data;
   2. request that we correct any of your Personal Data that is inaccurate, incomplete, or out-of-date;
   3. request that we limit the processing of your Personal Data;
   4. request for information concerning the ways your Personal Data has been or may have been used or disclosed by us within a year before the date of your request;
   5. request the transfer of certain of your Personal Data to another party under certain conditions;
   6. request that we specify or explain our policies and procedures in relation to Personal Data and the categories of Personal Data collected, used, and disclosed by us; and/or
   7. withdraw, in full or in part, your consent given previously, in each case subject to any applicable legal restrictions, contractual conditions, and a reasonable time period.

   Please address all requests and/or questions or concerns which you may have regarding the subject matter in writing or via email to our Data Protection / Grievance Officer at the contact details provided in clause 9 below.

8. Minor's Personal Data

   If and to the extent regulated under the applicable laws and regulations of your country, we do not knowingly collect, process, use, disclose, store, transfer, and/or otherwise deal with Personal Data of children under the age prescribed in the relevant laws and regulations of your country ("Minor") without advance parental or guardian's consent. In the event that we gain actual knowledge that certain Personal Data was provided to us by the Minor without required consent, we will delete such Personal Data.

9. Data Protection / Grievance Officer

   If you have any grievances or inquiries or wish to make any request relating to your Personal Data, you may contact our Data Protection / Grievance Officer at:

   Name: Kota Kubo

   Address: 1460 Broadway, New York, NY 10036

   Email: privacy@ubiehealth.com

10. Do Not Track

    Some web browsers may have a "Do Not Track" setting that transmits a "Do Not Track" header to the websites you visit with information indicating that you do not want your activity to be tracked. We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed.

11. California Shine the Light

    Within the meaning of California's "Shine the Light" law (Cal. Civ. Code § 1798.83), we do not disclose personal information to third parties for their own direct marketing purposes.

12. Changes of This Policy

    We may update this Policy from time to time, and the updated Policy applies to you after the “Last Updated” date stated in the updated Policy. Your continued access to or use of our services (including the Applications or Ubie Account) after the date of the updated Policy constitutes your acceptance of the updated Policy. If you do not agree to the updated Policy, you must stop accessing or using our services. If we change the Policy in a material way, we will provide appropriate notice to you pursuant to applicable law.