We at MEDANA Inc. ("MEDANA,""we,""us," or "our") are dedicated to respecting your privacy and recognizing the importance of protecting and managing the information you provide, including when using our website(s) ("Site(s)"). This Privacy Policy outlines our practices for collecting, using, maintaining, protecting, and disclosing your information, including Personal Information."Personal Information"(also "Personal Data" or a similar term under applicable data protection laws) refers to information that identifies, relates to, describes, or can be associated with you. This Privacy Policy also applies to the products and services that MEDANA offers ("Services"), as well as to MEDANA affiliates, but does not cover the practices of companies that MEDANA does not own or control, or individuals that MEDANA does not employ.  By accessing and using the Site or Services, you agree to be bound by MEDANA’s Privacy Policy and the Site’s Terms of Use effective at the time of your use. The terms in this Privacy Policy also apply to Personal Information you provide to us through any other means. This Privacy Policy is non-negotiable. If you do not agree to be bound by any terms in this Privacy Policy or our Terms of Use, disagree with our information collection or disclosure practices, or are not legally able to  contract in your place of residence due to age (you are younger than 18 years old) or other reasons, you should not access or use the Site or our Services for any purpose. Please read these terms carefully. If you do not agree with our policies and practices, your choice is not to use our Site and Services. Nonetheless, nothing in this Privacy Policy should be interpreted as an admission or concession that any specific statute, law, regulation, or legal act applies to MEDANA or the processing of Personal Information.  For the purposes of this Privacy Policy, MEDANA is a controller (i.e., responsible party) of your Personal Information when we manage the Site and Services directly on our own behalf. In certain situations, we also manage the Site and Services on behalf of customers or other third parties. In those instances, MEDANA may act as a processor or service provider to such organizations, and you should review the privacy policy of those third parties with whom you are directly dealing, as they will be responsible for handling your Personal Information.  California Consumer Notice of Collection  This Notice of Collection is provided to all California consumers subject to this Privacy Policy. You can jump to particular topics by referring to the headings below:

WHAT INFORMATION DO WE COLLECT? 

The types of Personal Information we gather about you depend on your interactions with us. Based on the Services you use, the following categories of Personal Information have been collected from you in the past twelve (12) months for our purposes and how we utilize that information. 

Context 

Types of Data 

Primary Purpose for Collection and Use of Data 

Account Registration (ContactInformation/Identifiers) 

When you create an account on our Sites or Apps, we collect your name, account information (username and password), and email address. We may also gather information related to the actions you perform while logged into your account. Additionally, if you choose to provide it, we may collect information such as product and service preferences.  We have a legitimate interest in providing account-related functionalities to our users. Accounts can be used for easy checkout and to save your preferences and transaction history. By registering, you are automatically enrolled in our mailing list. 

Site Behavior & Cookies (Internet or Other Network Activity) 

We use first-party cookies and other methods to track site activity. We also utilize third-party cookies and other methods to track site activity and share it with third parties. Refer to the Cookies and Other Information Collecting Technologies section below for more information.  First-party cookies gather information to facilitate purchases and provide a better shopping experience. Third-party cookies gather information for behavior-based advertising and website analytics. 

Demographic Information (ContactInformation/Identifiers) 

We may collect Personal Information such as your name, address, email, phone number, age, and gender (some of which may include characteristics of protected classifications under state or federal law).  We have a legitimate interest in understanding our users and providing tailored services.

Government Identifiers 

We may collect Personal Information such as your driver’s license number, passport information, and Social Security number. In certain instances, this information may be considered sensitive personal information.  We have a legitimate interest in using this information for identification verification or non-diagnosis or treatment purposes. 

Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information (Identifiers)

We may collect information such as electronic signatures, photographic, or video images.  We have a legitimate interest in using this information for identification verification or non-diagnosis or treatment purposes.  MEDANA does not collect or create biometric information about you. To use our Site, however, we may need to verify your identity. If asked to submit proof of identity (such as a driver’s license or passport), we may share that and the selfie you provide with our identity verification partner. They may create biometric information about your face to verify that your selfie matches your proof of identity. Biometric information is not shared with MEDANA and is deleted by our identity verification partner after completing the verification. MEDANA may receive information extracted from your photos, such as information from your driver’s license and the confidence that there is a “match” between your two photos. We use this information to verify your identity. 

Purchase History (Information Specific to the Services) 

We may collect information about goods or services purchased or obtained.  We have a legitimate interest in using this information to process or fulfill orders and transactions, marketing, customer, or analytics services. 

Health and Medical Information (Identifiers/Sensitive Personal Information) 

We may collect medical history and other information, symptoms, prescription history, insurance policy, and insurance eligibility and coverage. In certain instances, this information may be considered sensitive personal information.  We have a legitimate interest in using this information to process and fulfill orders and transactions and may release such information only when instructed by one of our patients. 

Financial/Payment Information 

We may collect payment information, such as credit card details, from you. We have a legitimate interest in using this information to process or fulfill orders and transactions. 

Email Interconnectivity (Device Information and Other Unique Identifiers) 

If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains, and make purchases.  We have a legitimate interest in using this information to understand how you interact with our communications. 

Feedback & Support(ContactInformation/Information Specific to Services) 

If you provide us feedback or contact us for support, including via the Live Chat feature, we will collect your name and email address, as well as any other content you send to us, to respond.  We have a legitimate interest in using this information to receive and address your feedback or issues. 

Distance Information (Geolocation Data/Device Information and Other Unique Identifiers) 

When you use one of our Apps, we collect your location from the GPS, Wi-Fi, and/or cellular technology in your device to determine your location and distance from our retail locations that sell our products.  We have a legitimate interest in understanding our users and providing tailored services. In some contexts, our use is also based on your consent to provide us with geolocation information. 

Mobile Devices (Device Information and Other Unique Identifiers) 

We collect information from your mobile device such as unique identifying information broadcast from your device.  We have a legitimate interest in identifying unique visitors and understanding how users interact with us on their mobile devices. 

Mailing List(ContactInformation/Identifiers) 

When you sign up for one of our mailing lists, we collect your email address or postal address.  We disclose information about our products and services to individuals who consent to receive such information. We also have a legitimate interest in sharing information about our products or services.

Ratings and Reviews (Information Specific to the Services) 

When you rate or review us or our products, we collect any information you provide as part of that rating or review.  We have a legitimate interest in using this information to improve and provide feedback on products. 

Surveys (ContactInformation/Information Specific to the Services) 

When you participate in a survey, we collect the information you provide through the survey. If the survey is provided by a third-party service provider, their privacy policy applies to the collection, use, and disclosure of your information.  We have a legitimate interest in using this information to understand your opinions and gather information relevant to our organization. 

Website Interactions (Internet or Other Network Activity) 

We use technology to monitor how you access and interact with our Site. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.  We have a legitimate interest in using this information to understand how you interact with our Site, improve it, and understand your preferences and interests to select offerings you might find most useful. We also have a legitimate interest in detecting and preventing fraud. 

Web Logs (Internet or Other Network Activity) 

We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.  We have a legitimate interest in using this information to monitor our networks and understand visitor behavior patterns on our Site. This allows us to improve our browsing and shopping experiences. 

Sensitive Personal Information 

Where permitted and in accordance with applicable law, of the information collected and listed above, username and password, health and medical information, driver’s license number, and Social Security number may be considered sensitive personal information.  We rely on consent when processing sensitive personal information. In addition to the information we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. Providing the Personal Information listed above is voluntary. In certain instances, we will not be able to process your request for our Services without the requested Personal Information. 

HOW AND WHEN DO WE COLLECT INFORMATION? 

MEDANA gathers Personal Information from you in various ways and at different times, including: 

Directly from You 

• When you provide your Personal Information in person, during a phone or video call, via email, survey, or through the Site. 
• When you interact with our Site or Services through features like interactive quizzes, surveys, or third-party platforms, by posting comments or reviews, or by initiating live or video chats with our representatives. 
• When you complete any MEDANA form, whether in person or on our Site, including forms to request the MEDANA Information Kit, schedule a consultation, make a purchase, request service and product information, report issues with our Site or services, receive communications or offers from MEDANA, or participate in sweepstakes, quizzes, games, or surveys. 
• When you correspond with us through email, letters, social media, or other forms of electronic communication. 

Indirectly from You 

• From third parties with whom we have a relationship, including marketing partners, related entities, business affiliates, data brokers, platform providers, internet service providers, operating systems, browsers, and social media programs. MEDANA is not responsible for the accuracy of the information provided by third parties or their collection and use of your Personal Information. 

Through Our Use of Cookies and Other Automatic Data Collection Technologies 

• When you visit our Sites, open or click on emails we send you, or interact with our advertisements, we or third parties collect information using cookies, web beacons, clear GIFs, pixels, internet tags, web server logs, and other data collection tools. For more details, see the “Cookies and Other Information Collection Technologies” section below.

Other Sources 

• Including publicly available sources. 

WHY DO WE COLLECT INFORMATION AND HOW DO WE USE IT? 

We collect and use your information, including Personal Information, for various purposes, such as: 

• Presenting our Site and its contents to you. 
• Contacting you and determining your preferred method of communication, including phone calls, text messages (SMS/MMS), emails, or physical correspondence. ● Delivering any information, offers, promotions, or Services you may have requested. ● Notifying you of MEDANA and our strategic partners' latest offers and promotions. ● Managing our business relationship (e.g., appointment reminders, billing statements, legal agreements, Site or services updates). 
• Tailoring our offers, Site, and Services to your specific needs. 
• Improving the content and administration of our Site, Services, social or networking applications, and marketing content. 
• Ensuring our advertising partners display MEDANA’s offers of interest to you as you browse the internet. 
• Giving you important notices regarding any of the above. 
• Detecting, investigating, preventing, or taking action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent transactions, policy violations, security incidents, and harm to the rights, property, or safety of MEDANA and our users, customers, employees, or others. 
• Fulfilling any other purpose for which you consented or which may have been described to you when you provided the Information. 
• Complying with any legal or regulatory obligations, establishing or exercising our rights, and defending against legal claims. 

Although these are our primary purposes for collecting your information, there may be multiple purposes for certain situations. For example, if you wish to receive Services or more information about our Services, we collect your information to perform those Services and respond to your inquiries. Thus, our collection and processing of your information may be based on your consent, our need to perform services or contractual obligations, legal obligations, and/or our general business interests. 

COOKIES AND OTHER INFORMATION COLLECTING TECHNOLOGIES

In accordance with applicable law, we use cookies, web beacons, and other tracking technologies on our Site. Cookies are small data files transferred to visitors’ web browsers and stored on their devices while browsing. These cookies enable various features and functionalities. We use first-party cookies and similar technologies to enhance the user experience on our Sites and Apps and for marketing and advertising purposes. 

Types of Cookies We May Use on Our Site: 

• Essential Cookies: Necessary for the Site to function, enabling you to use features smoothly. Examples include determining when you are signed in, detecting inactivity, and troubleshooting or security purposes. 
• Analytics Cookies: Help us understand visitor numbers, frequency of visits, and specific page views. These cookies do not reveal personal details like your name or address. We use Google Analytics for this purpose. 
• Advertising Cookies: Placed by us or third parties to allow ad networks to recognize a unique cookie on your device. The collected information may be linked to your device identifier and used for targeting advertisements on our Sites and third-party sites based on your interests. 

HOW DO WE COMMUNICATE WITH YOU? 

At MEDANA, we aim to communicate with you according to your preferences. If we have an existing business relationship, you have consented to receive mail, email, phone, and text messages (as applicable) to manage our business relationship, including appointment and invoice reminders. 

YOUR RIGHTS AND CHOICES 

You may have certain rights regarding your Personal Information, depending on your location. These rights include: 

• Access to Your Personal Information: Request access to the Personal Information we hold about you. 
• Changes to Your Personal Information: Request correction of inaccurate Personal Information. 
• Deletion of Your Personal Information: Request the deletion of your Personal Information, subject to legal obligations and business purposes. 
• Automated Processing: Object to decisions based solely on automated processing under certain circumstances.
• Data Portability: Request to receive your Personal Information in a structured, commonly used, machine-readable format. 
• Commercially Recognized Opt-Out Signal: MEDANA generally recognizes opt-out preference signals (e.g., Global Privacy Controls, Do Not Track). 
• Promotional Emails: Unsubscribe from promotional emails via the unsubscribe instructions or contact us. 
• Promotional Mailings: Remove yourself from mailing lists by emailing us with "NO SNAIL MAIL"in the subject line. 
• Promotional Text Messages: Opt-out of promotional text messages by replying "STOP" or contacting us. 
• Promotional Calls and Follow-Ups: Revoke consent for follow-up calls by contacting us. ● Revocation of Consent: Withdraw your consent to process your Personal Information at any time. 
• Limit Use and Disclosure of Sensitive Personal Information: We do not use or disclose Sensitive Personal Information beyond legal limitations. 
• Rightto Non-Discrimination: We do not discriminate or retaliate against individuals exercising their privacy rights. 
• Opt-Out ofthe “Sale” or “Sharing” of Personal Information: California residents can opt-out of the “sale” or “sharing” of their Personal Information through the “Do Not Sell or Share My Personal Information” button on our Sites. 

Many of these rights are subject to exceptions and limitations. Your rights and our responses may vary based on the request's circumstances. If you choose to assert any of these rights, we will respond within the legally prescribed time. In some cases, we may limit or deny your requests.  For California residents, an authorized representative may submit verifiable requests related to your Personal Information. Verification of the authorized agent’s permission will be required.  To submit a request, please use the contact information provided in the “Contact Us” section of this Privacy Policy.  For current or former California MEDANA employees, please refer to our MEDANA Employee Privacy Policy. For California applicants, please refer to our MEDANA California Applicant Policy. 

INTERNATIONAL TRANSFERS 

The Personal Information we collect or receive about you may be transferred to and processed by recipients located outside of your home country, including in countries not considered to provide an adequate level of protection for Personal Information according to local laws. To safeguard Personal Information during such transfers, we rely on appropriate measures, including but not limited to standard contractual clauses ("SCCs") approved by the European Commission, and the United Kingdom Addendum to the SCCs. Depending on your location, you may request a copy of these safeguards by contacting us as described at the end of this Privacy Policy. 

DISCLOSURE OF PERSONAL INFORMATION 

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations: 

• Social Media Platforms and Networks: Our Site may feature plugins, widgets, or other tools provided by third parties that facilitate information exchange between us and the third party. For instance, if you use Facebook’s “Like” feature, Facebook may register that you "liked" a product and post that information. Social media platforms’ use of your information is governed by their own privacy policies. 
• Analytics Services and Advertising Networks or Providers: When you visit our Site, we may share non-identifiable information about your browsing or usage with certain third parties as per our agreements. These third parties do not change their tracking practices in response to “do-not-track” signals from your web browser, and we do not require them to honor such signals. 
• Affiliates and Acquisitions: We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or assets, we will also share information with that company, including during negotiations. 
• Service Providers: We share your information with service providers who assist us with various functions, including administering our Site, collecting data for analysis, conducting surveys, providing technical support, processing payments, and fulfilling orders. 
• Compliance with Law or Other Legal Processes: We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also disclose your information to establish or exercise our rights, defend against a legal claim, investigate, prevent, or take action regarding possible illegal activities, suspected fraud, the safety of persons or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary. 
• Other Disclosures Without Your Consent: We may disclose information as described above without your consent to comply with legal obligations or for any other purposes mentioned in this Privacy Policy. 
• Disclosure for Purpose: MEDANA may disclose Personal Information for any purpose mentioned in this Privacy Policy when you provide the information. 
• Disclosures with Your Consent: MEDANA may disclose Personal Information for any purpose to which you have consented.
• Terms of Use Enforcement: MEDANA may disclose Personal Information to enforce or apply our terms of use, terms of sale, and other agreements, including for billing and collection purposes. 
• De-identified or Aggregate Information: We may aggregate and anonymize information you provide to us in a way that ensures it can no longer be identified as yours. This data may be used for statistical, analytic, and administrative purposes, including analyzing our website traffic and trends, tailoring our Services, or conducting product analysis. We may disclose anonymized or aggregated data at our discretion, in accordance with applicable laws. 

SECURITY OF YOUR PERSONAL INFORMATION 

We take the privacy of your Personal Information seriously and use commercially reasonable technical, administrative, and physical security measures to protect it, including generally accepted industry standards during transmission and once we receive it. However, no method of transmission over the Internet or electronic storage is 100% secure, so we cannot guarantee absolute security. In the event of a breach that requires notification by law, we may notify you electronically, in writing, or by phone, if permitted by law. If you believe that your interaction with us is no longer secure (e.g., you feel your account security has been compromised), please contact us immediately as detailed under the "Contact Us" section below. 

RETENTION OF YOUR PERSONAL INFORMATION 

The duration for which we retain your Personal Information depends on the context and purpose for which it was collected. We generally retain Personal Information as long as necessary to fulfill the purposes for which it was collected unless a different retention period is required by applicable law. 

OTHER IMPORTANT INFORMATION 

• Changes to this Privacy Policy: MEDANA reserves the right to update this Privacy Policy periodically and will notify users of our Site by posting changes on this Privacy Policy page. If we make material changes to how we treat your Personal Information, we will 

notify you via a notice on the Site home page, or via email to the last email address you provided. You are responsible for ensuring we have your current, active, and deliverable email address and for periodically visiting our Site and this Privacy Policy for updates. The date of the last revision is at the bottom of this Privacy Policy page. By using our Site or entering into an agreement with us for services, you agree to be responsible for checking this Privacy Policy periodically for updates. 

• Links to Third-Party Websites: From time to time, the Site may contain links to other websites not owned or controlled by MEDANA. MEDANA explicitly disclaims

responsibility or liability for the privacy practices or content of websites not under its control. 

• Children: Our Site is intended for adults over the age of 18 and is not intended for minors. We do not knowingly collect age information through our Site. No one under 18 may provide information on the Site. In compliance with the Children’s Online Privacy Protection Act (“COPPA”), MEDANA does not knowingly collect information from children. Children should get parental permission before sending any personal information over the Internet. If you are under 18, do not use or provide any information on this Site. If we learn that we have collected Personal Information from a child under 18 without parental consent, we will delete that information. If you believe we might have information about a child under 18, please contact us as provided below. If you are under 18, stop using the Site and have your parent or guardian contact us on your behalf. 
• Automated Technology Disclosure: By submitting your information on the Site, you agree to receive advertising calls made via an autodialer to your phone, including your cell phone, and automated text messages. You also agree to receive transactional, promotional, and other emails from MEDANA. You may withdraw your consent at any time and are not required to agree to receive advertising calls, texts, or emails to use our services. Opting out of advertising emails will not affect service-related communications. 
• Accessibility: If you are visually impaired, you can access this notice through your browser’s audio reader. 

CONTACT US 

If you wish to contact MEDANA with any questions or comments regarding our Privacy Policy, or if you no longer wish to receive non-Business Communications from MEDANA, please reach out to us: 

By Phone: 

+1 548 761 6936

By Email: 

• For Privacy Policy or Data Use Questions: info@medana.com 
• For Customer Service or to opt-out of receiving information from MEDANA: info@medana.com 

Effective Date: July 2024  Last Updated: July 2024