PILLO HEALTH PRIVACY POLICY

1. Introduction
Welcome to Pillo Health!

The services offered on our website, www.pillohealth.com (the “Site”), on the Pillo mobile application (the “App”) and through the Pillo device (the “Device”) (collectively the “Service”) are owned and operated by Pillo, Inc. (“Pillo”, “we”, “us”, “our”, or the “Company”). Please read this Privacy Policy (this “Privacy Policy”) and our Terms of Service (the “Terms”) carefully, as you are agreeing to be bound by both documents by using our Service.

This Privacy Policy applies to all Users of the Service, including all visitors, browsers, vendors, advertisers, and/or contributors of content (“Users”). If you do not agree with any part of this Privacy Policy, you must not use the Service. Your continued use of the Service will constitute your acceptance of this Privacy Policy. Any new features or tools which are added to the current Service shall also be subject to this Privacy Policy. You can review the most recent version of this Privacy Policy at any time here. We reserve the right to update, change, or replace any part of this Privacy Policy by posting updates and/or changes. It is your responsibility to check the Service periodically for changes. Your continued use of the Service following the posting of any changes constitutes acceptance of those changes.

2. Information Collected
Information We Collect Directly From You: We receive personal data directly from you (and from such other persons as you authorize to use the Services through your Account) when you (or such third parties) provide us with such personal data. You represent and warrant that you have all necessary authorizations, permissions and consents necessary to provide us with such information, including without limitation the following:

Membership Registration Information: We collect the information you supply when you create an Account, for example, your name, address, e-mail address, login name, voice, picture, and the password you select. This information may be edited at any time by logging into your Account.
Preferences and Suggestions: We collect information and suggestions that you give to us, including information about your preferences.
User Content: We collect user content that you provide to or through our Services, for example, voice commands, photographs (including for facial recognition), audio and video, medications (including dosing and timing), and such user content can include personal data if you include personal data in such content.
Financial Information: you are required to provide financial information in the form of a valid credit card number and billing address.

Non-Identifying Information: Whenever you use our Service, we may collect non-identifying information from you, such as your IP address, referring URL, operating system, cookie information, and Internet Service Provider. Without a subpoena, voluntary compliance on the part of your Internet Service Provider, or additional records from a third party, this information alone cannot usually be used to identify you.

Mobile: When you download or access the Services via a mobile device, we may receive information about your location (based on your IP address) and your mobile device, including various unique identifiers associated with your device, hardware type, and the version of your operating system.

Information From Our Advertising Partners: We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications.

Cookies: Like many websites and mobile application operators, we collect certain information through the use of “cookies,” which are small text files that are saved by your browser when you access our Services. Cookies can either be “session cookies” or “persistent cookies”. Session cookies are temporary cookies that are stored on your device while you are visiting our Website or using our Services, whereas “persistent cookies” are stored on your device for a period of time after you leave our Website or Services. We use persistent cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Service, and how your use of the Services varies over time. We also use persistent cookies to measure the effectiveness of advertising efforts. Through these cookies, we may collect information about your online activity after you leave our Services. For more information on cookies, including how to control your cookie settings and preferences, visit http://ec.europa.eu/ipg/basics/legal/cookies/index_en.htm, https://ico.org.uk/for-the-public/online/cookies/ and http://www.allaboutcookies.org/.

Some cookies are placed by a third party on your device and may provide information to us and third parties about your browsing habits (such as your visits to our Services, the pages you have visited and the links and advertisements you have clicked). These cookies can be used to determine whether certain third party services are being used, to identify your interests, to retarget advertisements to you and to serve advertisements to you that we or others believe are relevant to you. We do not control third party cookies.

The Services uses the following cookies:

Essential Cookies: Essential cookies are required for providing you features or services that you have requested. For example, certain cookies enable you to log into secure areas of our Site or use a shopping cart feature within our Services. Disabling these cookies may make certain features and services unavailable.
Functionality Cookies: Functional cookies are used to record your choices and settings regarding our Services, maintain your preferences over time, and recognize you when you return to our Services. These cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
Performance/Analytical Cookies: Performance/analytical cookies allow us to understand how visitors use our Site and Services such as by collecting information about the number of visitors to the Site, what pages visitors view on our Site, and how long visitors are viewing pages on the Site. Performance/analytical cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising.
Retargeting/Advertising Cookies: Retargeting/advertising cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.
Third Party Cookies: We may use various third-party services that may use cookies, web beacons, and similar technologies to collect information. Such services include, but not limited to, web analytics services, advertisement services, and social media services. This Policy does not cover cookies practices used by third-party service providers. We will do our best to maintain links to privacy policies of the third-party service providers that we use in this document.

Do Not Track: Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time.

Online Behavior Advertising: Some of our advertising (“Behavioral Advertising”) involves using cookies, clear gifs (a.k.a. web beacons/web bugs), and other tracking tools and technological methods (collectively, “Tracking Tools”) to collect information about a user’s online activities over time and across non-affiliated websites and applications and providing ads to the user based the user’s interests (as inferred from the user’s online activity) or use of our Services. Behavioral Advertising may appear on our Services or on other websites or services. We work with third parties to provide Behavioral Advertising, such as advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers, and other third-party service providers collectively (“Advertising Service Providers”). Advertising Service Providers perform services such as facilitating targeting of advertisements and measuring and analyzing advertising effectiveness on the Services (collectively, all such services, “Targeting Services”). Targeting Services help us display Behavioral Advertising, prevent you from seeing repeated ads, and enable us to research the usefulness of ads.

3. Use of Your Information

We may use your information to:

• Provide the Services (including, without limitation, sharing your likeness, voice, pictures, and video to certain third parties and third party service providers as necessary to provide the Services).

• Enhance or improve User experience or our Service.

• Send e-mails about our Service or respond to inquiries.

• Send e-mails and updates about the Company, including newsletters and notifications of amendments to legal documents such as this Privacy Policy and our Terms.

• Perform any other function that we believe in good faith is necessary to protect the security or proper functioning of our Service.

• Track user activity so that we may better understand your preferences.

• Personalize website content and communications based on your preferences.

• Respond to user inquiries.

• Create and manage user profiles.

• Provide support and assistance for the Services.

• Meet contract or legal obligations.

• Fulfill User requests.

• Comply with our legal or contractual obligations.

• Resolve disputes.

• Protect against or deter fraudulent, illegal or harmful actions.

• Enforce the Terms of Use.

4. Accessing, Editing, and Removing Your Information

Users may in some cases be able to review and edit the personal information they have provided to us by logging into your account and editing their account. Although most changes may occur immediately, information may still be stored in a web browser’s cache. We take no responsibility for stored information in your cache, or in other devices that may store information, and disclaim all liability of such. In addition, we may, from time to time, retain residual information about you in our backup and/or database.

5. How, and with whom, is your Information Shared?

We share personal data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or the Terms. These parties include:

● Credit card payment processing company to bill you for Services

● Fraud prevention service providers

● Ad networks

● Analytics service providers

● Staff augmentation and contract personnel

● Hosting service providers

● Co-location service providers

● Telecommunications service providers

● Facial recognition providers

● Voice to text providers

We also share personal data when necessary to complete a transaction initiated or authorized by you or provide you with a product or Service you have requested. In addition to those set forth above, these parties also include:

● Other users

● Social media services (if you interact with them through your use of the Services)

● Third party business partners who you access through the Services

● Other parties authorized by you

We also share Personal Data when we believe it is necessary to:

● Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies

● Protect us, our business or our Users, for example to enforce our Terms, prevent spam or other unwanted communications and investigate or protect against fraud, or

● Maintain the security of our products and services

We also share information with third parties when you give us consent to do so.

Sharing with Other Users: We may share your information to facilitate contact between you and other Users.

Business Transfers: Furthermore, if we choose to buy or sell assets, we may share and/or transfer personal data in connection with the evaluation of and entry into such transactions. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share personal data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your personal data as set forth in this policy.

Aggregate Data: We provide aggregate usage information to our partners (or allow partners to collect that information from you), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience. We also, from time to time, de-identify your personal data so that you are not identified as an individual, and provide that information to our partners.

What Happens if You Disclose Your Personal Data in Public Areas on the Site? If you disclose your personal data in public areas, it may be collected and used by third parties, without our or your knowledge.

6. Third Party Websites

We may post links to third party websites on our Service. Additionally, other materials made available through our Service may contain third party website links or files. We do not screen third-party websites or files for privacy or security issues, and you release us from any liability for the conduct or content of these third parties.
Please be aware that this Privacy Policy, and any other policies in place, in addition to any amendments, does not create rights enforceable by third parties or require disclosure of any personal information relating to members of the Service. We bear no responsibility for the information collected or used by any advertiser or third-party website. Please review the privacy policy and terms of service for each site you visit.

7. Third Party Access to Your Information

Although you are entering into an agreement with us to disclose your information to us, we do use third party individuals and organizations to assist us, including contractors, advertising partners, web hosting companies, and others.

Throughout the course of our provision of our Service to you, we may delegate our authority to collect, access, use, and disseminate your information. For example, our web host stores the information that you provide us, and we may hire outside contractors to perform maintenance or assist us in securing our Service.

It is therefore necessary that you grant the third parties we may use in the course of our business the same rights that you afford us under this Privacy Policy. For this reason, you hereby agree that for every authorization which you grant to us in this Privacy Policy, you also grant to any third party that we may hire, contract, or otherwise retain the services of for the purpose of operating, maintaining, repairing, or otherwise improving or preserving our Service or its underlying files or systems. You agree not to hold us liable for the actions of any of these third parties, even if we would normally be held vicariously liable for their actions, and that you must take legal action against them directly should they commit any tort or other actionable wrong against you.

Without limiting the generality of the foregoing, you authorize us to collect, share, store, exchange, and otherwise use your information in conjunction with the Service.

8. Release of Your Information for Legal Purposes

At times, it may become necessary or desirable, for legal purposes, to release your information in response to a request from a government agency or a private litigant. You agree that we may disclose your information to a third party where we believe, in good faith, that it is desirable to do so for the purposes of a civil action, criminal investigation, or other legal matter. In the event that we receive a subpoena affecting your privacy, we may elect to notify you to give you an opportunity to file a motion to quash the subpoena, or we may attempt to quash it ourselves, but we are not obligated to do either. We may also proactively report you, and release your information to, third parties where we believe that it is prudent to do so for legal reasons, such as our belief that you have engaged in fraudulent activities. You release us from any damages that may arise from or relate to the release of your information to a request from law enforcement agencies or private litigants.

9. Commercial and Non-Commercial Communications

By providing information to the Service that forms the basis of communication with you, such as contact information, you waive all rights to file complaints concerning unsolicited email from us since, by providing such information, you agree to receive communication from us or anyone else covered under this Privacy Policy. However, you may unsubscribe from certain communications by notifying us that you no longer wish to receive solicitations or information and we will endeavor to remove you from the database.

10. Security Measures

We take certain measures to enhance the security of our Service, including using SSL certificates. However, we make no representations as to the security or privacy of your information. It is in our interest to keep our Service secure, but we recommend that you use anti-virus software, firewalls, and other precautions to protect yourself from security threats. Furthermore, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and personal data by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

11. Your California Online Privacy Rights

We permit residents of California to use our Service. Therefore, it is our intent to comply with the California Business and Professions Code §§ 22575-22579. If you are a California resident you may request certain information regarding our disclosure of personal information to any third parties for their direct marketing purposes. Various provisions throughout this Privacy Policy address requirements of the Californian privacy statutes. In summary, you must presume that we collect electronic information from all visitors. You may contact us at support@pillohealth.com with any questions.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of personal information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@pillohealth.com.

California residents are entitled to ask us for a notice identifying the categories of personal information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: support@pillohealth.com

12. International Transfer

Your information may be transferred to—and maintained on—computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, we transfer Personal Information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. By using the Services, you acknowledge that personal data about you, regardless of whether provided by you or obtained from a third party, is being provided to us in the United States and will be hosted on United States servers, and you authorize us to transfer, store and process your information to and in the United States, and possibly other countries. You hereby consent to the transfer of your data to the United States as set forth herein.

13. Children

The Children’s Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13. We do not knowingly collect or solicit personally identifiable information from a child under 13 without obtaining verifiable consent from that child’s parent or guardian (“Parental Consent”), except for the limited amount of personally identifiable information we need to collect in order to obtain Parental Consent (“Required Information”). Until we have received Parental Consent, we will only use Required Information for the purpose of obtaining Parental Consent. If you are a child under 13, please do not attempt to send any personal information about yourself to us before we obtain Parental Consent, except for the Required Information in the context of the Parental Consent process. If you believe that a child under 13 has provided us with personal information (beyond the Required Information) without our obtaining Parental Consent, please contact us at support@pilloheath.com.

14. Amendments
We may amend this Privacy Policy from time to time. When we amend this Privacy Policy, we will post the changes here. Your continued use of our Service shall constitute your acceptance of such changes.
Last Updated October 25, 2018

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