Respin Health Privacy Notice

Last Updated Date: Oct 15, 2024

This Privacy Notice applies to the processing of personal information by Respin Health, Inc. (“Respin Health,” “Company,” “we,” “us,” or “our”) including on our website available at respin.health and our other online or offline offerings which link to, or are otherwise subject to, this Privacy Notice (collectively, the “Services”).

We may change this Privacy Notice from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Notice regularly to stay informed about our information practices and the choices available to you.

1. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

• Pendo Analytics. For more information about how Pendo uses your personal information, please visit Pendo's Privacy Policy. To learn more about how to opt-out of Pendo's use of your personal information, please visit Your Choices or via email to gdpr@pendo.io.
• Posthog Analytics. For more information about how Posthog uses your personal information, please visit Posthog's Privacy Policy. To learn more about how to opt-out of Posthog's use of your personal information, please visit Your Choices or via email to privacy@posthog.com.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

• Account Information. We may collect personal information in connection with the creation or administration of your account. This personal information may include, but is not limited to, your name, email address, phone number, and other information you store with your account.
• Purchases. We may collect personal information and details associated with your purchases, including payment information.
• Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email or our web chat tool.
• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.
• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features.
• Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer.
• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use the Services.

• Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information).
• Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.
• Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services.
  • Cookies. Cookies are small text files stored in device browsers.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

  See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

• Biometric Information. If you consent to our collection of biometric information or if our collection of biometric information is otherwise permitted, we may collect biometric information such as gait patterns and sleep, health, and/or exercise data to provide you with more comprehensive or additional Services. Your biometric information may be shared with our service providers, business partners, and others involved in providing you with our Services. Where required by law, your biometric information will be stored for no more than three (3) years from your last interaction with our Services.

C. Personal Information Collected from Third Parties

We may collect personal information about you from third parties. For example, if you access the Services using a Third-Party Service (defined below), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings.

2. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

A. Provide the Services

We use personal information to fulfill our contract with you and provide the Services, such as:

• Managing your information;
• Providing access to certain areas, functionalities, and features of the Services;
• Answering requests for support;
• Communicating with you;
• Sharing personal information with third parties as needed to provide the Services;
• Processing your financial information and other payment methods for products and Services purchased;
• Processing applications if you apply for a job we post on our Services; and
• Allowing you to register for events.

B. Administrative Purposes

We use personal information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research, and development (including marketing research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Carrying out analytics;
• Measuring interest and engagement in the Services;
• Improving, upgrading, or enhancing the Services;
• Developing new products and services;
• Creating de-identified and/or aggregated information;
• Ensuring internal quality control and safety;
• Authenticating and verifying individual identities;
• Debugging to identify and repair errors;
• Enforcing our agreements and policies;
• Carrying out activities that are required to comply with our legal obligations.

C. Marketing

We may use personal information to tailor and provide you with marketing and other content. We may provide you with these materials as permitted by applicable law.

Some of our marketing activities may be considered a “sale” or “targeted advertising” under applicable privacy laws.

If you have any questions about our marketing practices, you may contact us at any time as set forth in “Contact Us” below.

3. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information to third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide the Services

We may disclose any of the personal information we collect to the categories of third parties described below.

• Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features.
• Other Users You Share or Interact With. The Services may allow for Respin Health users to share personal information or interact with other users of the Services.
• Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a Third-Party Service).
• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.
• Affiliates. We may share your personal information with our corporate affiliates.
• Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day).

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.

4. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices

The privacy choices you may have about your personal information are described below.

• Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails.
• Text Messages. You can opt out by following the instructions in the text message you have received from us or by contacting us.
• Mobile Devices. You can opt out of push notifications and location services via your device settings.
• Cookies. You can adjust your browser settings to reject cookies, though this may affect Services functionality.
• Do Not Track signals and Global Privacy Control. Our websites will recognize GPC Signals for website users differently, based on the location of the user when they access our websites.

5. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

6. SUPPLEMENTAL NOTICE FOR EU/UK GDPR COMPLIANCE

This Supplemental Notice for EU/UK GDPR only applies to our processing of personal information that is subject to the EU or UK General Data Protection Regulation.

In some cases, providing personal information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter into a contract. If you choose not to provide personal information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the personal information.

If we process personal information that is considered a “special category of personal data”, then our processing of this personal information may be supported by one or more of the following conditions:

• Explicit Consent: You may have provided your explicit consent for our processing of your personal information.
• Necessary for Employment, Social Security, or Social Protection Law Purposes: Our processing of your personal information may be necessary for the purposes of carrying out obligations and exercising specific rights in the field of employment, social security, and/or social protection law.
• Necessary to Protect Vital Interests: Our processing of your personal information may be necessary to protect the vital interests of you if you are physically or legally incapable of giving consent.
• Necessary for Medical Purposes: Our processing of your personal information may be necessary for the purposes of preventive or occupational medicine, medical diagnosis, or pursuant to contract with a health professional.

7. CHILDREN'S PERSONAL INFORMATION

The Services are not directed to children under 16 years of age (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below.

8. THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

9. SECURITY

We implement appropriate technical and organizational measures to protect your personal information.

10. CONTACT US

Respin Health, Inc. is the controller of the personal information we process under this Privacy Notice.

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us by:

Email: support@respin.health

Our online submission form: Click here

Postal mail:

Respin Health
3402 Pico Boulevard
Santa Monica, 90405

ANNEX A – SUPPLEMENTAL CONSUMER HEALTH DATA PRIVACY NOTICE

Effective Date: May 17, 2024

Respin Health, Inc. (“Respin Health,” “Company,” “we,” “us,” or “our”) are committed to respecting your privacy. Our Privacy Notice describes how we handle your personal information generally. This Consumer Health Data Privacy Notice (“Notice”) supplements our Privacy Notice and applies to the collection of “Consumer Health Data” as defined in relevant comprehensive consumer health data privacy laws.

Categories and Uses of Consumer Health Data We Collect

We only collect your Consumer Health Data as needed to provide you with the products or services you request or with your explicit consent.

We may collect the following categories of Consumer Health Data:

• Individual health condition, treatment, disease, or diagnosis information;
• Social, psychological, behavioral, and medical intervention information;
• Health-related surgery or procedure information;
• Use or purchase of prescribed medication information;
• Bodily function, vital sign, symptoms, or measurement of health information;
• Diagnosis or diagnostic testing, treatment, or medication information;
• Biometric data;
• Information about your access to healthcare, including precise location information that could reasonably indicate an attempt to acquire or receive health services or supplies;
• Information processed to associate or identify an individual with the data listed above that is derived or extrapolated from non-health information.

Sources of Consumer Health Data

We collect Consumer Health Data from the following sources:

• Directly from you, if you:
  • request health-related products and services;
  • enroll in our biometric access programs;
  • register to use our health or wellness-related apps;
  • join our email lists or loyalty programs;
  • volunteer the information in connection with surveys or promotions.
• Indirectly from you, if you:
  • interact with us by using our apps, accessing our systems, or entering our facilities;
  • enable certain mobile app functions, such as location tracking;
  • enable data syncing between our website and your enrolled health-related app;
  • make your health data publicly available on social media or other websites;
  • like, follow, or comment about health-related products on our social media sites.
• From our vendors, suppliers, consultants, professional advisers, and other third parties, when:
  • Business contact information, financial information, and other data is necessary for the purpose of managing and operating our business.
• Health Insurance Companies or other payors, when:
  • Information is necessary for the purpose of providing our products and services;
  • Information is necessary to determine program eligibility;
  • Information is necessary to comply with legal and regulatory obligations.

How We May Share Consumer Health Data

We only share or disclose your Consumer Health Data as needed to provide you with the products or services that you request, or with your explicit consent. We may share or disclose any or all the above categories of Consumer Health Data to the following entities:

• Business Collaborators
• Product co-promotion partners
• Product co-development partners
• Marketing and Advertising Agencies
• Social Media Companies and Platforms
• Service Providers (including those hosting or analyzing data on our behalf)
• Emergency Personnel
• Health insurance companies, health plans, and/or other payors
• Authorized/legal representatives, family members, and caregivers
• Company lawyers, auditors, and consultants
• Legal and regulatory bodies

Your Consumer Health Data Privacy Rights

Subject to certain legal limitations and exceptions, you have the following rights:

• The right to confirm whether we are collecting, sharing, or selling your Consumer Health Data
• The right to review and request corrections to your Consumer Health Data
• The right to withdraw consent from our collection or sharing of your Consumer Health Data
• The right to request that we delete your Consumer Health Data

You may submit a request pursuant to any of these rights:

• by completing and submitting our online form, or
• by contacting us at support@respin.health

Nevada Supplemental Consumer Health Data Privacy Notice

This Supplement applies to Nevada consumers for purposes of providing additional disclosures required by Nevada's Consumer Health Data Privacy Law. We collect, use, process, and share Consumer Health Data for the purposes and manners described above in our Consumer Health Data Privacy Notice.

Third Party Collection of Consumer Health Data on Company Websites

We limit third party collection of Consumer Health Data over time and across different Internet websites or online services when Nevada consumers use our websites or online services. We do this by disabling certain cookies or by ensuring that entities whose cookies, web beacons, pixels, and other online trackers we use on our websites and online services are our service providers or processors under applicable U.S. state privacy or consumer health data privacy laws.

ANNEX B – CONSUMER HEALTH DATA AUTHORIZATION

This Consumer Health Data Privacy Authorization (“Authorization”) supplements Respin Health, Inc.'s (“Respin Health,” “Company,” “we,” “us,” or “our”) Privacy Notice, Supplemental Consumer Health Data Privacy Statement, and the respin cookie banner and applies only to “consumer health data” subject to the Washington My Health My Data Act (“MHMDA”) or Nevada Consumer Health Data Privacy Law (“NVCHDPL”) (as applicable).

If you opt-in to “personalized marketing” through the respin.health cookie banner, you allow us to “sell” your consumer health data as described below:

• Specific consumer health data intended for “sale”: Consumer health data collected via cookies and similar technologies including but not limited to browsing activity on our website; however, consumer health data does not include PHI of current or potential Respin Health users.
• Purpose of the “sale” of consumer health data: To tailor and deliver personalized advertisements to you.
• How consumer health data purchasers gather and use the data: Consumer health data purchasers will gather the data via cookies and other tracking technologies when you visit the respin.health website. These purchasers may use the data to assist us to deliver personalized advertisements to you and in accordance with their privacy policies linked below.
• Consumer health data purchasers' contact information:
  • Facebook/Meta: Privacy Policy
  • Google: Privacy Policy
  • Instagram: Data Policy
  • Microsoft: Privacy Statement
  • Reddit: Privacy Policy
  • Snapchat: Privacy Center
  • TikTok: Data Policy
  • X Advertising: Privacy Policy
• Contact information for Respin Health: support@respin.health

Please note:

• The provision of goods or services may not be conditioned upon you accepting the terms of this authorization.
• Purchasers may re-disclose the consumer health data sold under this authorization and such data may no longer be protected by the MHMDA and/or NVCHDPL.
• You may revoke this authorization at any time through the respin.health cookie banner. To do so, please be sure the box next to “Personalize marketing” is unchecked and click “Save my choices.” You may also click “Decline all” to decline our use of all cookies not required to operate our website.
  • A revocation will not impact previously sold consumer health data. In addition, if you use different browsers or devices, you must indicate your choices on each browser/device used to access support@respin.health.
  • If you have any questions about how to revoke your authorization, please contact support@respin.health.
• This authorization will expire one year after accepting it.