Notice of Privacy Practices

THIS NOTICE OF PRIVACY PRACTICES (THIS “NOTICE”) DESCRIBES HOW YOUR PROTECTED HEALTH INFORMATION MAY BE USED AND DISCLOSED WHEN YOU USE SERVICES PROVIDED THROUGH INNER BALANCE, LLC. AND ITS AFFILIATED PRACTICES AND PROVIDERS. “Providers” are professionals contracted or employed by independently owned professional practices that contract with Inner Balance to provide certain healthcare services. Practices that are subject to this Notice include Inner Balance Health, PLLC. The Practices may disclose Protected Health Information (or “PHI”) (as defined by HIPAA) to Inner Balance, LLC. in connection with its role as a business associate and for use consistent with this Notice. In this Privacy Notice, Inner Balance, LLC., the”Practices and Providers, collectively, may be referred to as, “Inner Balance,” “us,” “we”, or “our”). Terms not defined herein shall have the meaning set forth in the Terms of Use.

Inner Balance is committed to maintaining the privacy of your PHI. We are required by law to: (a) provide you with this Notice of our legal duties and privacy practices with respect to your PHI; (b) follow the terms of the Notice currently in effect; and (c) notify you if there is a breach of your PHI. We must also provide you with information regarding: (i) how we may use and disclose your PHI; (ii) your privacy rights; and (iii) our obligations concerning the use and disclosure of your PHI.

This Notice is NOT an authorization. Rather it describes how we, our business associates, and their subcontractors may use and disclose your PHI to carry out treatment, payment, or health care operations, and for other purposes as permitted or required by law. It also describes your rights to access and control your PHI.

I. USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION

A. Routine Uses and Disclosures of Protected Health Information

Inner Balance is permitted under federal law to use and disclose PHI for certain purposes, including treatment, payment, and health care operations. Generally, we do not need your permission for these uses or disclosures under applicable laws. The following are examples of the types of routine uses and disclosures of PHI that we are permitted to make without your permission. Although this list is not exhaustive, it should give you an idea of the routine uses and disclosures we are permitted to make without your permission.

For Treatment: We keep a record of your PHI, which may include lab results, diagnoses, medications, your response to medications or other therapies, and information we learn about your health by providing the Services. We may use and disclose this information and other PHI to provide, coordinate, and/or manage your treatment and inform you of treatment alternatives and other health related benefits, products and services that may be of interest to you. We may use and disclose this information and other PHI to health care professionals (including without limitation Providers) and/or other third parties to provide, coordinate, and manage the delivery of your health care. For example, we may disclose your PHI to a pharmacy to fill a prescription, to a laboratory to order a test, or to another specialist for consultation.

For Payment: We may use and disclose your PHI, as needed, to bill and obtain payment for the health care services provided to you. We may disclose your PHI to health care providers (including without limitation Providers), health plans, and health care clearinghouses for their payment activities. For example, we may use and disclose PHI about you to receive payment for our services, manage your account, and fulfill our responsibilities under your health plan.

For Health Care Operations: We may use or disclose your PHI in order to support the business activities of the Providers. These activities may include, but are not limited to, reviewing our treatment and services, improving the services we provide, training and evaluating the performance of our staff in providing services, and providing customer service. We may also use your PHI to evaluate and improve services provided by our business associates, including those that provide data assessment and management and other services for or on our behalf, such as Inner Balance.

B. Uses and Disclosures That May Be Made Without Your Authorization or Opportunity to Object

Inner Balance may use or disclose your PHI in the following situations without your authorization and without providing you an opportunity to object.

Required by the Secretary of Health and Human Services: We may be required to disclose your PHI to the Secretary of Health and Human Services to investigate or determine our compliance with the requirements of the HIPAA Privacy Rule.

Required By Law: We may use or disclose your PHI to the extent that the use or disclosure is required by federal, state, or local law.

Public Health: We may disclose your PHI for public health activities, such as tracking diseases and/or medical devices, which may include making disclosures to a public health authority or other government agency that is permitted by law to collect or receive the information (e.g., the Food and Drug Administration). These activities generally include the following: (a) to prevent or control disease, injury or disability; (b) to report births and deaths; (c) to report child abuse or neglect; (d) to report reactions to medications or problems with products; (e) to notify people of recalls of products they may be using; or (f) to notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition. If we keep genetic testing information about you, we will release that information only to the state departments that monitor our work or if required by law to release that information.

Health Oversight: We may disclose PHI to a health oversight agency for oversight activities authorized by law, such as audits; civil, administrative or criminal investigations; inspections; licensure or disciplinary actions; civil, administrative or criminal proceedings or actions; or other activities necessary for the oversight of the health care system, government benefit programs or entities subject to government regulations or civil rights laws. Oversight agencies include government agencies that oversee the health care system, government benefit programs, other government regulatory programs and civil rights laws.

Abuse or Neglect: If you have been a victim of abuse, neglect, or domestic violence, we may disclose your PHI to a government agency authorized to receive such information. In addition, we may disclose your PHI to a public health authority that is authorized by law to receive reports of child abuse or neglect.

Judicial and Administrative Proceedings: We may disclose your PHI in response to an order of a court or administrative tribunal, and, in certain conditions, in response to a subpoena, discovery request or other lawful process.

Law Enforcement: We may disclose your PHI, so long as applicable legal requirements are met, for law enforcement purposes, such as providing information to the police about the victim of a crime.

Coroners and Funeral Directors: We may disclose your PHI to a coroner, medical examiner, or funeral director if it is needed to perform their legally authorized duties – for example to identify a deceased person, determine a cause of death, or as authorized by law.

Organ Donation: If you are an organ donor, we may disclose your PHI to organ, eye or tissue donation or procurement organizations as necessary to facilitate organ, eye or tissue donation, procurement or transplantation.

Research: Under certain circumstances, we may use and disclose your PHI for internal and external research purposes to, among other things, develop and improve our services and products. Under certain circumstances, we may disclose your PHI to organizations that support medical research or that find, investigate, or cure diseases.

Serious Threat to Health or Safety: We may disclose your PHI if we believe it is necessary to prevent a serious threat to health or safety of a person or the public and it is to someone we reasonably believe is able to prevent or lessen the threat.

Specialized Government Functions: When the appropriate conditions apply, we may disclose PHI for purposes related to military or national security concerns, such as for the purpose of a determination by the Department of Veterans Affairs of your eligibility for benefits. If you are a member of the armed forces, we may release PHI about you as required by military command authorities. We may also release PHI about foreign military personnel to the appropriate foreign military authority.

National Security and Intelligence Activities: We may disclose your PHI to authorized federal officials for intelligence, counterintelligence, protection of the President, other authorized persons or foreign heads of state, for purpose of determining your own security clearance and other national security activities authorized by law.

Workers' Compensation: We may disclose your PHI to workers' compensation carriers or your employer if you are injured at work, as authorized by, or to the extent necessary, to comply with workers' compensation laws and other similar programs. If you do not want workers’ compensation notified, alternate insurance or payment information must be supplied.

For Appointment Reminders and Health-Related Benefits and Services: We may use your demographic PHI to contact you as a reminder that you have an appointment or to recommend possible treatment options or alternatives that may be of interest to you.

For Marketing Activities: We may use your PHI to contact you in an effort to encourage you to purchase or use a product or service. If we receive any direct or indirect payment for making such a communication, however, we would need your prior written permission to do so unless our communications (a) describes only a drug or medication that is currently being prescribed for you and our payment for the communication reasonably related to the cost of making such communication.

Inmates: We may use or disclose your PHI to a correctional facility if you are an inmate of such correctional facility and we created or received your PHI in the course of providing care to you, which PHI may include information necessary for the correctional facility to provide you with health care or protect your health and safety, the health and safety of others, or the safety and security of the institution.

Business Associates: We may disclose your PHI to persons or entities who perform functions, activities or services to us or on our behalf that require the use or disclosure of PHI. To protect your health information, we require the business associate to appropriately safeguard your information.

De-identified Information: We may de-identify your PHI for any of the purposes described above. PHI that is de-identified in accordance with the HIPAA standards is no longer protected under HIPAA and may be used and disclosed for any lawful purpose, including certain research related purposes.

C. Uses and Disclosures That May Be Made either With Your Agreement or the Opportunity to Object

Unless you specifically object in whole or in part (which you may do at any time), Inner Balance may disclose to a member of your family, a relative, a friend, or any other person you identify (orally or in writing) as being involved in your care or the payment for your health care, such PHI that directly relates to that person's involvement in your health care. If you are unable to agree or object to such disclosure, we may disclose the information that we deem necessary and in your best interest, based on our professional judgment. In addition, we may use or disclose your PHI to notify or assist in notifying a family member, personal representative, or other person responsible for your care, of your location or general condition.

D. Uses and Disclosures of Protected Health Information Based upon Your Written Authorization

Psychotherapy Notes: We must obtain your written authorization for most uses and disclosures of psychotherapy notes.

Marketing: We must obtain your written authorization to use and disclose your PHI for most marketing purposes (as defined by HIPAA), except as noted above.

Sale of PHI: We must obtain your written authorization for any disclosure of your PHI which constitutes a sale of PHI.

Other Uses: Uses and disclosures of your PHI not described above, or otherwise permitted by HIPAA, will be made only with your written authorization unless otherwise permitted or required by law. If you sign an authorization to release your PHI, you may revoke that authorization in writing. Revocation will stop any future release of your PHI, but will not change what was released pursuant to the valid authorization.

To the extent required by law, when using or disclosing your PHI or when requesting your PHI from another covered entity, we will make reasonable efforts not to use, disclose or request more than a “limited data set” (as defined by HIPAA) of your medical information, or, if needed by us, no more than the minimum amount of medical information necessary to accomplish the intended purpose of the use, disclosure or request, taking into consideration practical and technological limitations.

E. We Use an Electronic Health Record to Create, Store and Maintain your Medical Record.

To help improve your medical care, Inner Balance utilizes an electronic health record database (“EHR”) to create, store and maintain your medical record. The EHR allows us to send and potentially receive your PHI to and from other Providers who have treated you and who also use the EHR, but only if the reason we or another Provider seeks your PHI is also to provide you with treatment, obtain payment for your medical treatment, to the pharmacy, or to perform other administrative tasks permitted by the our privacy policies and law. Providers will not send or receive your PHI through the EHR for any other purposes.

II. YOUR RIGHTS REGARDING YOUR PROTECTED HEALTH INFORMATION

You have certain rights regarding your PHI as explained below. You may exercise these rights by submitting a request to support@innerbalance.com.

A. You have the right to inspect and copy portions of your PHI.

If you want to see or get a copy of your PHI that is contained in a designated record set (e.g., medical and billing records), you must make the request in writing. You have the right to request that we provide your PHI to you in either paper or electronic format. We are required to provide you with such PHI within 30 days after receipt of your written request (or less if directed by state law) (with up to a 30-day extension if needed). We may charge you a reasonable fee to cover duplication, mailing and other costs incurred by us in complying with your request. There are certain situations when we may deny your request for access to your PHI; if we do, we will inform you why we denied your request. For example, we may deny your request if we believe the disclosure will endanger your life or that of another person. Depending on the circumstances of the denial, you may have the right to have this decision reviewed.

B. You have the right to request that we restrict how we use or disclose your PHI.

You have the right to request a restriction or limitation on the PHI we use or disclose about you for purposes of treatment, payment or health care operations. You also have the right to request a limit on the PHI we disclose about you to someone who is involved in your care or the payment of your care, like a family member or friend. Your request must state the specific restriction requested and to whom you want the restriction to apply. We are not required to agree to a requested restriction except that we must agree to not disclose your PHI to your health plan if the disclosure (a) is for payment or health care operations (and not treatment purposes) and is not otherwise required by law and (b) relates to a health care item or service for which we have been paid in full out-of-pocket. If we agree with (or are required to honor) your request, we will put any limits in writing and abide by them except in emergency situations. You may not restrict any use or disclosure of your PHI if we are legally required to release such PHI.

C. You have the right to request to receive confidential communications from us by alternative means or at an alternative location.

You have the right to request that we communicate with you in a certain way (for example, email instead of regular mail) or at a certain location (for example, sending information to your work address rather than your home address). We will accommodate reasonable requests as long as we can easily provide it in the format you requested. Any additional expenses will be passed on to you for payment.

D. You have the right to request a correction or update of your PHI.

If you believe there is a mistake in your PHI or that a piece of important information is missing, you have the right to request that we correct the existing or add the missing information.) We can do this for as long as we maintain the PHI. You must provide the request and your reason for the request in writing. We will respond to your request within 60 days (or less if directed by state law) of receiving your request (with up to a 30-day extension if needed). If we approve your request, we will make the change to your PHI, tell you that we have done it, and tell others who need to know about such change or amendment. If we determine that your PHI is accurate and complete, we may deny your request. If we deny your request, we will send you a written explanation stating our reasons and explain your right to file a written statement of disagreement. Any denial of a request for correction of update of PHI will include an explanation in writing of such denial within 60 days of receipt of such request. If you do not file a written statement of disagreement, you have the right to request that your request and our denial be attached to all future uses or releases of your PHI. If you are a California resident, you have the right to submit a 250-word addendum about anything in your record you disagree with. If you tell us to, we will put this addendum in your medical record. We may add a written rebuttal to the addendum, and we will supply you with a copy of this rebuttal.

E. You have the right to receive a list of when and to whom we have disclosed your PHI (an “accounting of certain disclosures”).

This accounting will not include disclosures made for treatment, payment, and health care operations purposes or any disclosures we may have made directly to you. If you request an accounting, you must specify the time-period, which may not be longer than 6 years. You have the right to one free request within any 12-month period and we may charge you for any additional requests in the same 12-month period. We will notify you of any such charges and you are free to withdraw or modify your request in writing before any charges are incurred. We will respond to your request within 60 days (with up to a 30-day extension if needed). In addition, we will notify you, as required by law, if there has been any breach of your PHI.

F. You have the right to ask for a copy of the Notice at any time.

Even if you have agreed to receive the Notice electronically, you will receive a paper copy if requested. Medical powers of attorney i) a third party may exercise a customer’s right or make choices about a customer’s health information if the customer has given the third party a medical power of attorney or if the third party is the customer’s legal guardian and (ii) the third party needs to verify that they have this authority and act on behalf of the customer prior to Inner Balance providing a copy.

CHANGES TO THIS NOTICE

We reserve the right to modify this Notice and our privacy practices as described herein at any time. Any revision or amendment to this Notice will be effective for all of your records that we created or maintained in the past and for any of your records that we may create or maintain in the future. Our current Notice is available at any time by emailing support@innerbalance.com.

COMPLAINTS

If you have questions about this Notice of Privacy Practices, you believe that we have violated your privacy rights, or you disagree with a decision we made about access to your PHI, please contact Inner Balance at support@innerbalance.com.

NO RETALIATION

We will not retaliate against you in any way for filing a complaint with us, the Secretary, or any state agency.

Privacy Policy

At Inner Balance, we take your privacy seriously. This privacy policy explains how we access, use and share your personal data. By accessing or using our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you consent to our collection, use and sharing of your information as described in this Privacy Policy.

Your use of Inner Balance’s Services is subject at all times to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions assigned in the Terms of Use.

What this Privacy Policy Covers

This Privacy Policy covers how Inner Balance, LLC and its affiliated entities (collectively “Inner Balance”) may access, use and share your Personal Data when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations.

This Privacy Policy does not cover the practices of third parties and/or companies that Inner Balance doesn’t own or control or people we don’t manage. This Privacy Policy also does not cover Protected Health Information (as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and HIPAA Privacy Rule) collected by the Practice (as defined herein) and providers with whom Inner Balance contracts to facilitate medical care through the Inner Balance platform. Inner Balance currently contracts with these medical groups (the “Practice”), however, the medical groups we contract with may change from time to time. The Inner Balance Notice of Privacy Practices describes how Calibrate and the Practice may use and disclose your Protected Health Information. If you do not agree to those terms, you should not access or use Inner Balance services.

Personal Data
Categories of Personal Data We May Collect as well as examples:
Profile or Contact Data
Examples: First and last name, email and phone number
Identifiers
Examples: driver’s license number and gender
Payment Data
Examples: Payment card type and billing address
Commercial Data
Examples: Purchase history and consumer profile
Device/IP Data
Examples: IP address and type of device
Web Analytics
Examples: web page interactions, referring webpage/source
Consumer Demographic Data
Examples: Zip code, gender and date of birth
Geolocation Data
Examples: IP address-based location information
Health Data:
Examples: Medical conditions
Program Data:
Examples: Goals and expectations
Other identifying information that you voluntarily choose to provide
Examples: identifying information in emails or communications you send us

We may share this personal data with third parties, such as service providers, advertising partners, analytics partners, business partners, or parties you authorize, access or authenticate.

Categories of Sources of Personal Data

We may collect Personal Data about you from the following categories of sources:

1. You

When you provide information directly to us by:
• creating an account or use our Services.
• providing information in free-form text boxes through the Services or through responses to surveys or questionnaires.
• sending us an email or other electronic message.

When you use the Services and information is collected automatically:
• through Cookies (as defined in the “Tracking Tools, Advertising and Opt-Out” section below).
• if you use a location-enabled browser, we may receive information about your location.

2. Third Parties

Vendors
• We may use analytics providers to analyze how you interact and engage with the Services.
• We may use third parties to help us provide you with customer support.
• We may use vendors to obtain information to generate leads and create user profiles.

Employers
• If your employer makes the Services available to you as a benefit of employment, we may receive certain information from them about you to enable your account and/or facilitate provision of or payment for the Services.

Affiliates
• We may receive information about your participation in the Services from our affiliates. Advertising Partners
• We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.

Social Networks
• If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

Our Commercial or Business Purposes for Collecting Personal Data: Providing, Customizing and Improving the Services

• Creating and managing your account.
• Processing orders or other transactions; billing.
• Providing you with the prescription or services.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Services.
• Improving the Services, including testing, research, internal analytics and product development.
• Personalizing the Services, website content and communications based on your preferences.
• Doing fraud protection, security and debugging.
• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

Marketing the Services

• Marketing and selling the Services.
• Showing you advertisements, including interest-based or online behavioral advertising.

Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Inner Balance.
• Sending emails and other communications with content that we think will interest you.

Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property or safety of you, or Inner Balance.
• Enforcing any agreements with you.
• Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without updating this policy.

How We Share Your Personal Data

We may disclose your Personal Data to the categories of service providers and other parties described in this section. Depending on applicable state law, some of these disclosures may constitute a “sale” of your Personal Data. Additional information is provided in the state-specific sections below.

Service Providers.

These parties help us provide the Services or perform business functions on our behalf. They include:

• Hosting, technology and communication (including email) providers.
• Security and fraud prevention consultants.
• Support and customer service vendors.
• Pharmacy fulfillment and delivery providers.
• Data analytics providers.
• Payment processors. Our payment processing partner Stripe, Inc. (“Stripe”) collects your voluntarily-provided payment card information necessary to process your payment. Please see Stripe’s terms of service and privacy policy for information on its use and storage of your Personal Data.

Advertising Partners.

These parties help us market our services and provide you with other offers that may be of interest to you. They include:

• Ad networks.
• Marketing providers.

Analytics Partners.

These parties provide analytics on web traffic or usage of the Services. They include:

• Companies that track how users found or were referred to the Services.
• Companies that track how users interact with the Services.

Business Partners.

These parties partner with us in offering various services. They include:

• Businesses that you have a relationship with.
• Companies that we partner with to offer joint promotional offers or opportunities.

Parties You Authorize, Access or Authenticate.

• Third parties you access through the services.
• Social media services.

Legal Obligations
We may share any Personal Data we collect with third parties to assist in “Meeting Legal Requirements and Enforcing Legal Terms” as described in “Our Commercial or Business Purposes for Collecting Personal Data” above.

Business Transfers
All your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should such an event occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools, Advertising and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies: • Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable. • Functional 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 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 Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. 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. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on athttps://tools.google.com/dlpage/gaoptout/. • 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. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://www.allaboutcookies.org/.

Information about Interest-Based Advertisements:

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

We comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based on a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, atwww.networkadvertising.org/choices/or www.aboutads.info/choices.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure by using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Minors

Inner Balance Services are only available to individuals age 35 or older and we do not knowingly collect or solicit Personal Data about children under 13 years of age. If you are a child under the age of 13, do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as soon as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, contact us.

California Resident Rights

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting or selling your Personal Data.
• The categories of third parties with whom we have shared your Personal Data.
• The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or to complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Exercising Your Rights

To exercise the rights described above, you or your Authorized Agent (as defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (first and last name and email address and you may be asked to provide your telephone number or address), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request by emailing us at support@innerbalance.com or sending a request to Inner Balance, LLC, 827 E Park Blvd, Suite 200, Boise, ID 83712.

Your Authorized Agent may exercise your rights on your behalf. We may request a copy of such Authorized Agent’s written permission or authority when they make a request on your behalf.

Personal Data Sales Opt-Out and Opt-In

Calibrate does not receive remuneration from third parties for your Personal Data and has not over the last 12 months. To our knowledge, we do not sell any Personal Data of minors under 16 years of age.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under this Privacy Policy, the CCPA, or other applicable law. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under this Privacy Policy, the CCPA or other applicable law. However, we may offer different tiers of Services as permitted by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Other State Law Privacy Rights

California Resident Rights

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

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at support@innerbalance.com with the subject line “Nevada Do Not Sell Request” and providing us with your full name and the email address associated with your account.

Connecticut, Colorado, Utah and Virginia Resident Rights

If you are a resident of Connecticut, Colorado, Utah or Virginia, you may have the right to opt-out of the sale of certain Personal Data to certain third parties. You can exercise this right by contacting us at support@innerbalance.com with the subject line “Do Not Sell Request” and providing us with your state of residence, full name and the email address associated with your account.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time; when we do, we will post the updated Privacy Policy on the Inner Balance website. The updated Privacy Policy will be effective immediately upon posting; if you continue to use the Services after the Privacy Policy has been updated, that means you agree to all of the changes. If you object to any update of the Privacy Policy, your sole recourse is to stop using the Services.

Contact Information

If you have any questions about this Privacy Policy, the ways in which we collect and use your Personal Data, and/or your choices and rights regarding such collection and use, please emailsupport@innerbalance.com or contact us at Inner Balance, 827 E Park Blvd, Suite 200, Boise, ID 83712.