Clinic Commerce Inc. (“CCI”, “we”, “us,” and “our”) are committed to maintaining meaningful privacy protections for all individuals who interact with CCI. This Privacy Notice describes CCI’s practices with respect to your personal information, including the types of information we collect, how we use and share that information, and your choices. This Privacy Notice covers information collected through:

• our public-facing websites that link to this Privacy Notice (“Websites”); and,

• our online applications, services, and tools that can only be accessed with valid login credentials (“Online Services”).

Collection of Information

CCI collects information: (i) directly from you when you provide it to us; (ii) automatically when you interact with our Websites and Online Services; and (iii) from third parties such as our clients and business partners.

Information you provide to us directly includes:

• Contact information, such as name, email address, postal address, locations that you’ve been and telephone number;

• Credentials such as a username and password;

• Correspondence and other information that you send to us; and

• Any other information identified to you at the point of collection.

Information we collect automatically includes:

• Log files reflecting your IP address, browser type, internet service provider, referring and exit web pages, operating system, date/time stamp, and other data reflecting your actions and activities on our Websites and Online Services;

• Other unique identifiers, including mobile device identification numbers; And,

• Information collected through cookies, web beacons, pixel tags, and other similar technologies.

Information we collect from third parties includes:

• Information available from websites, directories, and other public sources;

• Information from our clients about their current, prospective, and former Talent and Crew Members, including name, address, email address, and telephone number.

For lawful and legitimate purposes during the COVID-19 pandemic, CCI may collect, use and transfer to third parties limited health information received from you and/or third parties, such as results of COVID-19 testing and health screenings for COVID-19 symptoms.

Use of Information and Legal Bases for Processing

We use the information collected through our Websites and Online Services to:

• Provide and improve our products and services;

• Understand how you interact with our Websites and Online Services;

• Register users for our Online Services;

• Communicate with you;

• Authenticate users;

• Perform analytics;

• Prevent and detect fraud and misuse;

• Comply with legal requirements;

• Provide customer service support or respond to your inquiries;

• Conduct investigations regarding violations of our policies, terms of use, or other legal rights, in accordance with applicable law; and

• Perform any other function requested by you or our clients.

Some parts of our Websites use cookies to track user traffic patterns in order to determine the usefulness of our Websites’ information to our users and to see how effective our navigational structure is in helping users reach that information.

Information Sharing and Disclosures

CCI shares your information with third parties with your consent or where required in order to provide products or services to you or CCI clients.

We will also disclose your personal information if required to do so by law, in connection to COVID-19, to enforce our Terms of Use, or in urgent circumstances to protect personal safety, the public, or our Websites and Online Services. CCI may also share your personal information when we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to: (1) detect, prevent or otherwise address fraud, security, or technical issues; (2) protect against harm to the rights, property, or safety of CCI, its users, or the public; or (3) if CCI is involved in a merger, acquisition, or sale of all or a portion of its assets requiring the transfer of personal information.

Data Security

We use commercially reasonable technical, organizational, and administrative measures to protect our Websites and Online Services against unauthorized or unlawful access and against accidental loss, theft, disclosure, copying, modification, and destruction, or damage. Nonetheless, we cannot guarantee that transmissions of your information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by us or our service providers. You play an important role in keeping your information secure. You should not share your username, password, or other Online Services account information with anyone. If you believe that the security of our Websites or Online Services have been compromised, please contact us immediately as detailed in the “Contact Us” section, below.

Data Retention

We retain your information for as long as your account is active, for as long as needed to provide you or our clients with the services requested, or as long as needed to comply with our legal obligations, resolve disputes, and enforce any agreements.

Children

Our Websites and Online Services do not target and are not intended to attract children under the age of 13. CCI does not knowingly collect personal information from children under the age of 13 without parental consent. If you believe a child has provided information through our Websites or Online Services without parental consent, please contact us immediately as detailed in the “Contact Us” section, below, so that we can delete their information.

Your Choices

If you prefer not to receive cookies while browsing our Websites, you can set your browser to warn you before accepting cookies and refuse cookies when your browser alerts you to their presence. You can also refuse all cookies by turning them off in your browser, although you may not be able to take full advantage of our Websites if you do so. You may be required to accept cookies in order to complete certain actions on our Websites. Our Websites do not respond to “Do Not Track” signals.

To the extent required by applicable law, we provide you with the ability to access, correct, export, delete, withdraw consent, object to the processing of, or suspend processing of your personal information. You can contact us as detailed in the “Contact Us” section, below to exercise these rights.

Individuals in the European Economic Area (“EEA”): You have the right to lodge a complaint with a supervisory authority if you believe we have processed your personal information in a manner inconsistent with your rights.

California Residents

This Privacy Notice discloses the categories of personal information we have collected from California residents over the past twelve months, the categories of sources from which the information was collected, the business or commercial purposes for which the information was collected, and the categories of third parties with whom we shared that information.

In the past twelve months, we have disclosed the following categories of personal information to third parties for business or commercial purposes:

• Personal identifiers including name and email address

In the past twelve months, we have not sold personal information to third parties and we have no actual knowledge of selling the personal information of minors under 16 years of age.

California residents have the right to opt out of the sale of their personal information.

However, because we do not sell personal information, we do not offer an opt out.

California residents have the right to request that we disclose the categories of personal information we have collected, used, and disclosed about them during the past twelve months, the categories of sources from which their personal information was collected, our business or commercial purposes for collecting their personal information, and the categories of third parties with whom we shared their personal information. California residents also have the right to request the specific pieces of personal information we have collected about them. You or your authorized agent can submit a request in ‘Contact Us’.

California residents also have the right to request deletion of the personal information we have collected from them or maintained about them. You or your authorized agent can submit a deletion request to ‘Contact. We may require additional personal information to match with the information we have on file in order to verify your identity and residency. The personal information that we use to verify your identity and residency will not be used for any other purpose.

California residents have the right to not be discriminated against for exercising their rights under the CCPA. We do not discriminate against California residents who exercise their CCPA privacy rights.

International Transfers

We may transfer your information from your country or jurisdiction to other countries or jurisdictions around the world. When we transfer information from individuals in the EEA to countries that have not received an adequacy finding under Article 45 of the GDPR, including the United States, we rely on alternative adequate safeguards, such as the contractual mechanisms set forth in Article 46 of the GDPR, or derogations for specific situations set forth in Article 49 of the GDPR. Individuals in the EEA can contact us as detailed in the “Contact Us” section, below to request copies of applicable Article 46 transfer agreements. In the limited situations where we rely on Article 49 derogations, we only collect and transfer your information to third countries: (i) with your consent; (ii) to perform a contract with you; or (iii) to establish, exercise, or defend legal claims.

Changes to this Privacy Notice

CCI may amend this Privacy Notice from time to time. We will post any revised Privacy Notice on this Website. We encourage you to periodically review this page for the latest information on our privacy practices. If our changes or amendments to this Privacy Notice are material, we will notify you in accordance with applicable law.

Contact Us

If you have questions, concerns, or complaints about this Privacy Notice please feel free to contact us by email at team@cliniccommerce.com.