Privacy Policy

This privacy notice for Journey Health Services, Inc (doing business as Journey

Health) ("we," "us," or "our"), describes how and why we might collect, store, use,

and/or share ("process") your information when you use our services ("Services"),

such as when you:

Visit our website at http://www.journeyhealth.io, or any website of ours that

links to this privacy notice

Engage with us in other related ways, including any sales, marketing, or

events

Questions or concerns? Reading this privacy notice will help you understand your

privacy rights and choices. If you do not agree with our policies and practices, please

do not use our Services. If you still have any questions or concerns, please contact

us at info@journeyhealth.io.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find

out more details about any of these topics by clicking the link following each

key point or by using our table of contents below to find the section you are

looking for.

What personal information do we process? When you visit, use, or navigate our

Services, we may process personal information depending on how you interact with

us and the Services, the choices you make, and the products and features you use.

Learn more about personal information you disclose to us.

Do we process any sensitive personal information? We do not process sensitive

personal information.

Do we receive any information from third parties? We do not receive any

information from third parties.

How do we process your information? We process your information to provide,

improve, and administer our Services, communicate with you, for security and fraud

prevention, and to comply with law. We may also process your information for other

purposes with your consent. We process your information only when we have a valid

legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information?

We may share information in specific situations and with specific third parties. Learn

more about when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical

processes and procedures in place to protect your personal information. However, no

electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,

cybercriminals, or other unauthorized third parties will not be able to defeat our

security and improperly collect, access, steal, or modify your information. Learn more

about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the

applicable privacy law may mean you have certain rights regarding your personal

information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by

submitting a data subject access request, or by contacting us. We will consider and

act upon any request in accordance with applicable data protection laws.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express

an interest in obtaining information about us or our products and Services, when you

participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect

depends on the context of your interactions with us and the Services, the choices you

make, and the products and features you use. The personal information we collect

may include the following:

• names
• email addresses
• contact preferences
• phone numbers

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate,

and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or

browser and device characteristics — is collected automatically when you visit our

Services.

We automatically collect certain information when you visit, use, or navigate the

Services. This information does not reveal your specific identity (like your name or

contact information) but may include device and usage information, such as your IP

address, browser and device characteristics, operating system, language

preferences, referring URLs, device name, country, location, information about how

and when you use our Services, and other technical information. This information is

primarily needed to maintain the security and operation of our Services, and for our

internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar

technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic,

usage, and performance information our servers automatically collect when

you access or use our Services and which we record in log files. Depending on

how you interact with us, this log data may include your IP address, device

information, browser type, and settings and information about your activity in

the Services (such as the date/time stamps associated with your usage, pages

and files viewed, searches, and other actions you take such as which features

you use), device event information (such as system activity, error reports

(sometimes called "crash dumps"), and hardware settings).

• Device Data. We collect device data such as information about your computer,

phone, tablet, or other device you use to access the Services. Depending on

the device used, this device data may include information such as your IP

address (or proxy server), device and application identification numbers,

location, browser type, hardware model, Internet service provider and/or

mobile carrier, operating system, and system configuration information.

• Location Data. We collect location data such as information about your

device's location, which can be either precise or imprecise. How much

information we collect depends on the type and settings of the device you use

to access the Services. For example, we may use GPS and other technologies

to collect geolocation data that tells us your current location (based on your IP

address). You can opt out of allowing us to collect this information either by

refusing access to the information or by disabling your Location setting on your

device. However, if you choose to opt out, you may not be able to use certain

aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our

Services, communicate with you, for security and fraud prevention, and to comply

with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on

how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOUR

PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section

and/or with the following third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Analytics. We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include: Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

4. DO WE USE COOKIES AND OTHER TRACKING

TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store

your information.

We may use cookies and similar tracking technologies (like web beacons and pixels)

to access or store information. Specific information about how we use such

technologies and how you can refuse certain cookies is set out in our Cookie Notice.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes

outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the

purposes set out in this privacy notice, unless a longer retention period is required or

permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal

information, we will either delete or anonymize such information, or, if this is not

possible (for example, because your personal information has been stored in backup

archives), then we will securely store your personal information and isolate it from

any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of

organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational

security measures designed to protect the security of any personal information we

process. However, despite our safeguards and efforts to secure your information, no

electronic transmission over the Internet or information storage technology can be

guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,

cybercriminals, or other unauthorized third parties will not be able to defeat our

security and improperly collect, access, steal, or modify your information. Although

we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the

Services within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years

of age.

We do not knowingly solicit data from or market to children under 18 years of age. By

using the Services, you represent that you are at least 18 or that you are the parent

or guardian of such a minor and consent to such minor dependent’s use of the

Services. If we learn that personal information from users less than 18 years of age

has been collected, we will deactivate the account and take reasonable measures to

promptly delete such data from our records. If you become aware of any data we

may have collected from children under age 18, please contact us at

info@journeyhealth.io.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

Withdrawing your consent: If we are relying on your consent to process your

personal information, which may be express and/or implied consent depending on

the applicable law, you have the right to withdraw your consent at any time. You can

withdraw your consent at any time by contacting us by using the contact details

provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

below.

However, please note that this will not affect the lawfulness of the processing before

its withdrawal nor, when applicable law allows, will it affect the processing of your

personal information conducted in reliance on lawful processing grounds other than

consent.

Cookies and similar technologies: Most Web browsers are set to accept cookies

by default. If you prefer, you can usually choose to set your browser to remove

cookies and to reject cookies. If you choose to remove cookies or reject cookies, this

could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at

info@journeyhealth.io.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications

include a Do-Not-Track ("DNT") feature or setting you can activate to signal your

privacy preference not to have data about your online browsing activities monitored

and collected. At this stage no uniform technology standard for recognizing and

implementing DNT signals has been finalized. As such, we do not currently respond

to DNT browser signals or any other mechanism that automatically communicates

your choice not to be tracked online. If a standard for online tracking is adopted that

we must follow in the future, we will inform you about that practice in a revised

version of this privacy notice.

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC

PRIVACY RIGHTS?

In Short: If you are a resident of California, you are granted specific rights regarding

access to your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve

(12) months:

We may also collect other personal information outside of these categories through

instances where you interact with us in person, online, or by phone or mail in the

context of:

Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

Learn about how we use your personal information in the section, "HOW DO WE

PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a

written contract between us and each service provider. Learn more about how we

disclose personal information to in the section, "WHEN AND WITH WHOM DO WE

SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for

undertaking internal research for technological development and demonstration. This

is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a

business or commercial purpose in the preceding twelve (12) months. We will not sell

or share personal information in the future belonging to website visitors, users, and

other consumers.

California Residents

California Civil Code Section 1798.83, also known as the "Shine The Light" law

permits our users who are California residents to request and obtain from us, once a

year and free of charge, information about categories of personal information (if any)

we disclosed to third parties for direct marketing purposes and the names and

addresses of all third parties with which we shared personal information in the

immediately preceding calendar year. If you are a California resident and would like

to make such a request, please submit your request in writing to us using the contact

information provided below.

If you are under 18 years of age, reside in California, and have a registered account

with the Services, you have the right to request removal of unwanted data that you

publicly post on the Services. To request removal of such data, please contact us

using the contact information provided below and include the email address

associated with your account and a statement that you reside in California. We will

make sure the data is not publicly displayed on the Services, but please be aware

that the data may not be completely or comprehensively removed from all our

systems (e.g., backups, etc.).

CCPA Privacy Notice

This section applies only to California residents. Under the California Consumer

Privacy Act (CCPA), you have the rights listed below.

The California Code of Regulations defines a "residents" as:

(1) every individual who is in the State of California for other than a temporary or

transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the

State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and

obligations regarding your personal information.

Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your

personal information, we will respect your request and delete your personal

information, subject to certain exceptions provided by law, such as (but not limited to)

the exercise by another consumer of his or her right to free speech, our compliance

requirements resulting from a legal obligation, or any processing that may be

required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell or share personal information to third parties;
• the categories of personal information that we sold, shared, or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
• the business or commercial purpose for collecting, selling, or sharing personal information; and
• the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete

consumer information that is de-identified in response to a consumer request or to re-

identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not process consumer's sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are

the same person about whom we have the information in our system. These

verification efforts require us to ask you to provide information so that we can match it

with information you have previously provided us. For instance, depending on the

type of request you submit, we may ask you to provide certain information so that we

can match the information you provide with the information we already have on file,

or we may contact you through a communication method (e.g., phone or email) that

you have previously provided to us. We may also use other verification methods as

the circumstances dictate.

We will only use personal information provided in your request to verify your identity

or authority to make the request. To the extent possible, we will avoid requesting

additional information from you for the purposes of verification. However, if we cannot

verify your identity from the information already maintained by us, we may request

that you provide additional information for the purposes of verifying your identity and

for security or fraud-prevention purposes. We will delete such additionally provided

information as soon as we finish verifying you.

Other privacy rights

• You may object to the processing of your personal information.
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by submitting a data subject access

request, by email at info@journeyhealth.io, or by referring to the contact details at the

bottom of this document. If you have a complaint about how we handle your data, we

would like to hear from you.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant

laws.

We may update this privacy notice from time to time. The updated version will be

indicated by an updated "Revised" date and the updated version will be effective as

soon as it is accessible. If we make material changes to this privacy notice, we may

notify you either by prominently posting a notice of such changes or by directly

sending you a notification. We encourage you to review this privacy notice frequently

to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at

info@journeyhealth.io or contact us by post at:

Journey Health Services, Inc

2323 Broadway

Oakland, CA 94612

United States

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE

DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request

access to the personal information we collect from you, change that information, or

delete it. To request to review, update, or delete your personal information, please fill

out and submit a data subject access request.