MANZANILLA SOPHIA PRIVACY POLICY

Effective February 1^st, 2022

This Privacy Policy (“Privacy Policy”) describes the information that we collect about you on the website from which you linked (“site”); or when you access or use other Labs Sophia websites, mobile or desktop applications, and/or additional online services (collectively with the Site, the “Services”); how your information may be used and disclosed; how you can control the use and disclosure of your information; and how your information is protected. Except as specifically provided below in the California Residents Section, this Privacy Policy does not apply to any other information collect by Labs Sophia USA, Inc. (hereinafter as “Labs Sophia,” “we,” “us,” and “our”) by or through any other means, such as information collected offline. When we refer to ourselves as “we”, we mean Labs Sophia USA Inc. and all of its subsidiary companies. Our site may contain links to third party websites/content/services that are not owned or controlled by Labs Sophia. Labs Sophia is not responsible for how these properties operate or treat your personal data so we recommend that you read the privacy policies and terms associated with these third party properties carefully.

By accessing and/or using any Services, you accept, agree, and affirmatively consent to be bound by all of the terms of this Privacy Policy without limitation or qualification, including our collection, storage, and processing of your personal information in the United States (“U.S”) and in any other country to which we may transfer your personal information in accordance with the terms of this Privacy Policy. Please be sure to read this entire Privacy Policy before using this Site or any Services or providing any information to us. If you disagree with or do not accept any part of this Privacy Policy, do not use this Site or any Services or provide us with any information.

The Privacy Policy is a part of, and subject to, the Labs Sophia Legal Notice (“Legal Notice”). The Privacy Policy and the Legal Notice are legally binding on all users of this Site and any Services. If you have any questions, please contact us using one of the methods set out in the “Contact Us” section at the end of this Privacy Policy.

California Residents: For information relating to California residents, please reach below on the California Residents Section

INFORMATION WE COLLECT AND USE

We may collect personal information (collectively, “Personal Information”) you choose to provide, e.g., through registrations, applications and surveys, and in connection with your inquiries and purchases In addition, we may gather information about you automatically through your use of the Site, e.g., your IP address and how you navigate our Site See also, the Section below on Cookies and Other Tools.

If you submit any personal data relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

This information is collected for our legitimate business purposes and may be used as described below in Section How we use and disclose information.

1. Active Collection Of Information We may actively collect certain Personal Information you choose to provide including: (a) name; (b) contact information, such as email address, postal address, zip code, and telephone number; (c) user name and password; (d) demographic information, such as gender or date of birth; (e) information about whether you are over the age of 13 and a U.S. resident; (f) any email communications, comments, suggestions, or other information that you provide on, though, or relating to this Site or any Services and/or that relates to us or our products or services; (g) health-related information, including conditions, medications, prescription data, and/or anticipated medical treatments; (h) personal information we collect when you report a possible side effect associated with one of our products; (i) responses to surveys; (j) your search queries; (k) credit card or bank account information, billing/payment terms, credit limit, and credit status; (l) job title and professional affiliations; (m) hobbies and areas of interest; (n) communications preferences; (o) product preferences; (p) if you are a health care provider, information such as your state license number and specialty; (q) responses to questionnaires and employment application information; (r) information you provide when you subscribe to one of our mailing lists or newsletters, or (s) other types of information described to you at the point of collection.
2. Automatic Collection of Information Please refer to Cookies Section below.

1. Information from Other Sources To the extent permitted by applicable law, we may collect or receive additional information about you, such as demographic data or fraud detection information, from third-party service providers and/or partners. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers for our fraud prevention and risk assessment efforts. We may also collect public personal information about you when we monitor other websites. For example, we may monitor conversations on public platforms concerning Labs Sophia or the pharmaceutical industry more generally. We may combine information about you from various sources. If you link, connect, or log in with a third-party service (such as Google, Facebook, or LinkedIn), the third-party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service. We do not control, supervise, or respond regarding the processing of your personal data by these third-party services. Any information request regarding the use or disclosure of such personal data by these third parties should be directed to the respective third party. Labs Sophia is not responsible for how these third parties operate or treat your Personal Information, so we recommend that you read the privacy policies and terms associated with these third party carefully

HOW WE USE AND DISCLOSE INFORMATION

Your personal information is collected for our legitimate business purposes, including to effectuate, monitor, evaluate, and improve our business relationship with you, tailor our marketing programs and campaigns. We use, store, and process the information we collect about you to, among other things, provide, understand, improve, and develop our Site and Services; communicate with you; fulfill your requests; facilitate our engagement with you; provide you, in case of your prior acceptance, with newsletters, articles, alerts, announcements, invitations, and other information about products, brands, health topics and disease states; and comply with our legal obligations. As such, we may use and/or disclose your Personal Information that we collect in connection with this Site or any Services as follows:

1. With Your Consent. Where you have provided consent, we may use and disclose your Personal Information as described at the time of consent.

1. Our Business Purposes. We may use your Personal Information for our business purposes, such as to (a) provide products, services, and information you request including through our affiliates; (b) communicate updates, promotions, or news about us, including our products, services, or events, through email, direct mail, or otherwise; (c) engage in market research; (d) maintain or administer the Services, perform business and/or healthcare analyses, or for other internal purposes to improve the quality of our business, the Services, and other products and services we offer and to better understand how visitors are interacting with the Services; (e) protect our company, our customers, and/or the Services; (f) prepare government reports; (g) process employment applications and inquiries; (h) customize and personalize your use of the Site or the Services; (i) market our products and services, (j) monitor and conduct reviews of our products and services, (k) help us improve our current products or develop new products, (l) collect demographic and geographic information about the users of the Site and our products, (m) communicate administrative or legislative related information, (n) respond to your requests; (o) respond to reports you make of a possible side effect associated with one of our products, monitor the safety of our products, and engage in adverse event reporting; and (p) as otherwise described to you at the point of collection.

1. Third-Party Providers. We use a variety of third-party service providers to help us provide services related to the Site, the Services, and our business. Such service providers may include, without limitation, (a) our professional advisors, auditors, and business partners, (b) our vendors that host the Site, manage databases, perform analyses or data analytics, process payments, provide technical or customer support, or send communications for us; and (c) companies with which we have promotional, marketing, advertising, or other commercial relationships, including financial institutions and companies that perform fulfillment and/or delivery services. These service providers may be located inside or outside of the U.S. In each case, we take reasonable precautions to help protect your Personal Information from unauthorized use or disclosure. For example, we enter into written agreements that commit such service providers to keep your information confidential and to use appropriate security measures with respect to such information. In addition, these service providers’ access to your Personal Information is limited to that necessary or advisable to perform tasks on our behalf.

1. Business Transactions. We may transfer any information collected, including Personal Information, in the event of (a) a sale, assignment, or other transfer of ownership or control of all or any portion of our business to which such information relates; (b) other business transactions involving Labs Sophia, such as an internal restructuring, buying or selling subsidiaries, or engaging in joint ventures with third parties; and (c) a bankruptcy or similar event involving Labs Sophia; provided, however, we will require such third parties to use and protect your personal data consistent with this Privacy Policy and will make reasonable efforts to notify you of the terms and conditions of the new Privacy Policy your Personal Information will be subjected to. We may also use your Personal Information to perform a contract to which you are a party.

1. Compliance with Law or Regulatory Action or Requests. We may disclose your information, including Personal Information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary to: (a) comply with applicable law, regulation, or guidance; (b) comply with legal process and/or to respond to claims asserted against us; (c) respond to requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability; (d) protect the rights, property, and/or personal safety of Labs Sophia, its employees, or members of the public; and/or (e) comply with or respond to an investigation or request for information or cooperation by a regulatory, governmental, or other entity, whether or not legally required. Where appropriate, we may notify you about legal requests unless providing such notice is prohibited by the legal process itself, by court order, or by applicable law, or we believe that providing such notice would be futile, ineffective, create a risk of injury or other harm to an individual or group, or create or increase a risk of liability upon Labs Sophia.

1. Subsidiaries and Affiliates. We may disclose your information to our subsidiaries and other affiliates for a variety of reasons, including for business, operational, marketing purposes and in general, the purposes set forth in this Privacy Policy.

1. Aggregated Information. We may share aggregated information (information about our users that we combine so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

1. Tell-A-Friend Features. We may disclose your name and email address to your friend if you use a tell-a-friend feature to send that friend information about Labs Sophia products or services.

1. Enforcement of Legal Notice. We may disclose Personal Information in order to enforce our Legal Notice available on [*]

We will not sell, rent, or lease your Personal Information to any third party unless disclosed to you at the time of your submission of such information.

USER RIGHTS

In addition to the rights set forth elsewhere in this Privacy Policy, you may be entitled to some or all the rights identified below.

1. Managing Content. You have the right to subscribe or unsubscribe to content from the Company by contacting us using one of the methods set out in the “Contact Us” section at the end of this Privacy Policy.

1. Opt-Outs. You may “opt out” of receiving marketing and promotional emails from us by following the opt-out procedure described in each email we send or by contacting us using one of the methods set out in the “Contact Us” section at the end of this Privacy Policy. However, even if you opt out of receiving marketing and promotional emails, we may continue to email you for other administrative or informational purposes, including follow-up messages regarding any content you have submitted to a Site or in connection with any Services.

1. Withdrawing Consent. When you have provided your consent to our processing of your Personal Information, you may withdraw your consent at any time by sending a communication to the Company (using one of the methods set out in the “Contact Us” section at the end of this Privacy Policy) specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

1. Data Access; Copies; Transfer; Correction. Applicable law may entitle you to request the following with respect to Personal Information that we hold about you: (a) that we provide you with access to such Personal Information; (b) that we provide you with copies of such Personal Information in a structured, commonly used, and machine-readable format and/or request that we transmit this information to another service provider (where technically feasible); and/or (c) that we correct inaccurate or incomplete Personal Information about you.

1. Restriction of Processing. Applicable law may give you the right to limit the ways in which we use your Personal Information, in particular where (a) you contest the accuracy of your Personal Information; (b) the processing of your Personal Information is unlawful and you oppose the erasure of such information; (c) we no longer need your Personal Information for the purposes of the processing, but you require the information for the establishment, exercise, or defense of legal claims; or (d) you have objected to the processing and a determination of whether our legitimate grounds override your own is pending.

1. Objection to Processing. Applicable law may entitle you to require us not to process your Personal Information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, we will no longer process your Personal Information for these purposes unless we can demonstrate compelling legitimate grounds for such processing, or such processing is required for the establishment, exercise, or defense of legal claims. Where your Personal Information is processed for direct marketing purposes, you may, at any time, ask us to cease processing your data for these direct marketing purposes.

1. Erasure. If you no longer want us to use your information, you can request that we erase your Personal Information. Please note that if you request the erasure of your Personal Information: (a) we may retain some of your Personal Information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety; (b) we may retain and use your Personal Information to the extent necessary to comply with our legal obligations; (c) some copies of your Personal Information (such as log records) may remain in our database, but are disassociated from personal identifiers; and (d) residual copies of your Personal Information may not be removed from our backup systems for a limited period of time.

1. Lodging Complaints. You have the right to lodge complaints about the data processing activities carried out by us before the applicable data protection authorities.

For information relating to California residents, see the California Residents Section below.

USER RESPONSIBILITIES

In addition to the responsibilities set forth elsewhere in this Privacy Policy, you must comply with the ones identified below. We cannot and will not be responsible for any liability or other problems that may arise from your failure to comply with these requirements.

1. Complete, Current, Truthful, And Accurate Information. It is your responsibility to provide complete, current, truthful, and accurate information. It is also your responsibility to contact us as described at the end of this Privacy Policy to update or correct your Personal Information whenever deemed necessary. If you submit any personal data relating to other people, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

1. Use of Services. You are solely responsible and liable for your activity, behavior, use, and conduct on the Site and in connection with any Services.

1. Confidentiality; Reporting. You are responsible for maintaining the confidentiality of any account usernames and/or passwords you may have that are associated with the Site or the Services and for any access to or use of the Services using such account usernames and/or passwords, whether or not authorized by you. You must notify us immediately of any unauthorized use of such account usernames and/or passwords or any other breach of security.

DATA SECURITY

We maintain reasonable technical, physical, administrative, and procedural security precautions to help protect against loss, misuse, unauthorized access, disclosure, alteration, interception, or destruction of the information you provide to us. Please note, however, that no such precautions are 100% effective. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us, and we are not responsible for the theft, destruction, interception, or inadvertent disclosure of your Personal Information. Therefore, any transmission of Personal Information is at your own risk.

We do not and will not send you emails asking you to provide or confirm personal information. A technique known as “phishing” attempts to steal personal identity data and financial account credentials from consumers. “Phishers” use “spoofed” emails to lead consumers to sham websites which trick recipients into divulging personal information including credit card numbers, account usernames, passwords, and social security numbers. If you receive such an email communication purporting to be from the Site or in connection with any Services, please forward it immediately to privacy@sophiaint.com and then delete it from your computer.

We reserve the right to deny to any user access and/or use privileges, including without limitation use of any services, features, or functions of one of our sites, if there is a question regarding the identity of the person accessing or attempting to access any services, features, or functions.

RETENTION OF PERSONAL INFORMATION

We generally retain your personal information for as long as necessary for our legitimate business interests or to comply with legal obligations. If you no longer want us to use your information, you may request that it be erased. Please see paragraph 7 of the “User Rights” section above for more detail about such erasure.

The criteria used to determine our retention periods include: the length of time we have an ongoing relationship with you and provide the Site to you; whether there is a legal obligation to which we are subject; or whether retention is advisable in light of our legal position (such as in regard to the enforcement of the Site Legal Notice and Terms of Use, applicable statuses of limitations, litigations or regulatory investigations).

USER GENERATED CONTENT

From time to time on certain areas of the Site or Services you may be able to submit written posts and certain other materials (collectively, “User Content”). Any User Content that you submit to or for use on the Site or in connection with any Services may become public information. You should exercise caution if any such User Content includes information about yourself or others, including any Personal Information. We are not responsible for the results of such submissions and cannot prevent such information from being used by third parties in a manner that may violate this Privacy Policy, the law, or your personal privacy and safety. By submitting any such User Content, you signify your acceptance of, and agreement to follow and be bound by, this Privacy Policy and the Legal Notice.

SOCIAL NETWORKING SERVICES

You may be able to link an account from a social networking service (such as Facebook, Google+, or LinkedIn) to an account through our Services. This may allow you to use your credentials from the other site or service to sign into certain features on our Services. If you link your account from a third-party site or service, these social networking services may be able to collect information about you, including your activity on our Services.

We also may work with certain third-party social media providers to offer you their social networking services through our Services. For example, you may be able to use third-party social networking services, including but not limited to Facebook, Twitter, and others to share information about your experience on our Services with your friends and followers on those social networking services. These social networking services may be able to collect information about you, including your activity on our Services. These third-party social networking services also may notify your friends, both on our Services and on the social networking services themselves, that you are a user of our Services or about your use of our Services, in accordance with applicable law and their own privacy policies. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services.

As with all links to non-Pfizer websites/content/services, we recommend that you read the privacy policies and terms associated with third party properties carefully.

CHILDREN’S PRIVACY

Labs Sophia respects the privacy of children. This Site is not directed to individuals under the age of thirteen (13), ad we do not knowingly collect personal data from children under the age of 13. If you believe that we have received any such Personal Information as a guardian authority of a children, please contact us using one of the methods set out in the “Contact Us” section at the end of this Privacy Policy.

LINKS TO THIRD PARTY SITES

This Site and any Services may provide links to other websites on the Internet that are operated and maintained by third parties. These websites operate independently from Labs Sophia and are not under our control or responsibility. In addition, you may be required to download certain programs, products, or services from such third parties, including without limitation in order to access coupons to certain Labs Sophia products or services. The existence of such links to other websites does not constitute an endorsement by Labs Sophia of those other websites, the content displayed therein, the programs, products, or services thereon, or the persons or entities associated therewith. When you visit any such third-party websites, you will exit our Site and not be using the Services, and Labs Sophia accepts no responsibility or liability with respect to any such website or any other website that is not under our control. We encourage you to review the privacy policies and terms of use of those third-party websites. You accept sole responsibility for and assume all risk arising from your use of any such websites.

GLOBAL OPERATIONS

The Site is controlled and operated by us from the U.S. If you are visiting this Site from a country other than the U.S., your Personal Information collected on this Site will be transferred outside of your country. This Site is designed to comply with the laws, rules, and regulations of the U.S. and is not intended to subject us to the laws, rules, or regulations of any jurisdiction other than the U.S.

Nevertheless, to facilitate our global operations, Personal Information that we collect may be transferred, stored, and/or processed between and accessed from other jurisdictions throughout the world. Laws in these other jurisdictions may differ from and may not provide an equivalent level of data privacy, security, and protection as, the applicable laws in your country. However, we will handle your Personal Information in accordance with this Privacy Policy and applicable law regardless of where we transfer, store, process, or access such information.

COOKIES

We may collect information about you by using cookies, tracking pixels and other technologies (collectively, “Cookies”). We use this information to better understand, customize and improve user experience with our websites, services and offerings as well as to manage our advertising. For example, to help us to understand how visitors engage with and navigate our Site, how and when this Site is visited and by how many visitors. We are also able to offer our visitors a more customized, relevant experience on our sites using these Cookies by delivering content and functionality based on your preferences and interests. If we have collected your Personal Information (through registration, survey or request), we may associate this personal data with information gathered through the Cookies. This may allow us to offer increased customization and functionality on the Site.

Your web browser can be set to allow you to control whether you will accept, reject or notify you each time a Cookie is sent to your browser. If your browser is set to reject Cookies, websites that are cookie-enable will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies. To find out more about cookies, visit www.aboutcookies.org

Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language and Internet browser type and version. We use this information to ensure that services function properly.

Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Site, along with the time of the visit and the pages visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Site. We may also derive your approximate location from your IP address.

We may use Google Analytics, which uses Cookies and similar technologies to collect and analyze information about use of the Site and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-put browser add-on, available at https://tools.google.com/dlpage/gaoptout .

We may use Flash Local Shared Objects (Flash LSOs”) and other technologies to collect and store information about your use of the Site. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html . You can also control Flash LSOs by going to http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager03.html and follow the instructions, which may include how to prevent Flash LSOs from being placed on your device without being asked, and how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time. Please note that setting Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including those used in connection with the Site.

INTEREST-BASED ADVERTISING AND THE ADVERTISING OPTION ICON

Labs Sophia hopes to deliver to you advertising for products and services you need or want. There are many ways to do this in the online advertising world. E.g., Labs Sophia may partner with websites and applications with whom you have shared your interests, conditions and concerns directly and asks that they serve our ads to users who have expressed an interest in Labs Sophia’s products or health conditions that our products treat. We may also partner with advertising companies that may place or recognize a unique cookie on your browser (including through the use of pixel tags), or use other technologies, to serve you ads based on your web browsing activity, purchases, interests and/or other information – a practice commonly referred to as interest-based advertising (“IBA”) or online behavioral advertising (“OBA”). These advertising companies may also use these types of technologies to recognize you across the devices you use, such as a mobile phone or laptop, serve you ads on websites you visit and applications you use. You can read more about IBA at a site offered by the advertising industry’s Digital Advertising Alliance (“DAA”), http://www.aboutads.info    

We want it to be easy for you to understand how we and our associated third parties use information to serve ads tailored for you and to opt-out from targeting based on IBA. To this end, we want you to learn how to opt-put of having the information collected from you used for IBA purposes on the particular device on which you are accessing this Privacy Policy, please visit: http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/choices. If you have any question about our use of IBA or the DAA Self-Regulatory Program, please do not hesitate to contact us at privacy@sophiaint.com

At this time, we do not respond to browser do-not-track signals. We will update this Privacy Policy if we recognize “do not track” instructions in the future. If you have any questions regarding the use of Cookies on our sites, or wish to change or revoke your consent to the use of Cookies, please refer to Section Cookies above or, in case of doubt, contact us using one of the methods set out in the “Contact Us” Section at the end of this Privacy Policy.

CALIFORNIA RESIDENTS

The following provisions apply to the personal data of California residents collected by Labs Sophia, whether collected online or offline. These provisions supplement the other sections of the Privacy Policy.

We do not sell personal data about California residents.

During the past 12 months we may have engaged in delivering online advertising that was tailored to your interests, which might be deemed to be a sale of data under the California Privacy Act, but we do not disclose data that would identify you by name, address or phone number.

Listed below are the categories of personal data about California residents that we may collect and may have collected in the preceding 12 months; and may have disclosed for a business purpose in the preceding 12 months. For more information about how we disclose your personal data, refer to the “How we use and disclose information” Section above.

Categories of personal data we collect and disclose

1. Name, contact information and identifiers: Identifiers such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, username, social security number, tax ID, driver’s license number, passport number, or other similar identifiers.

Applicable California Residents: Health care providers; investigators; patients; clinical trial participants; caregivers; website visitors.

1. Customer and other records: Paper and electronic customer records containing personal data, such as name, signature, physical characteristics or description, address, telephone number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medial information, or health insurance information.

Applicable California Residents: Patients; clinical trial participants; caregivers.

1. Protected Classifications: Characteristics of protected classifications under California or federal law such as race, color, sex, gender, age, national origin, disability, and citizenship status.

Applicable California Residents: Health care providers; investigators; patients; clinical trial participants; caregivers.

1. Purchase History and Tendencies: Commercial information, including records of products or services considered, purchased or owned.

Applicable California Residents: Health care providers; investigators; patients; caregivers.

1. Biometric Information: Physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, fingerprint, diagnostic or lab results, imagery or the face from which an identifier template can be extracted, and sleep, health or exercise data that contain identifying information.

Applicable California Residents: Clinical trial participants; patients.

1. Usage data: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application or advertisement.

Applicable California Residents: Health care provider; investigators; patients; caregivers; website visitors.

1. Geolocation data: Precise geographic location information about a particular individual or device.

Applicable California Residents: Health care providers; patients; caregivers; website visitors.

1. Audio/Visual: Audio, electronic, or visual recordings, or similar information.

Applicable California Residents: Health care providers; investigators; patients; clinical trial participants; caregivers.

1. Employment history: Professional or employment-related information

Applicable California Residents: Investigators; caregivers; job applicants.

1. Education Information: Information that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).
   Applicable California Residents: Health care providers; investigators; clinical trial participants; caregivers, job applicants.
2. Profiles and Inferences: Inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Applicable California Residents: Health care providers; patients; clinical trial participants; caregivers; website visitors.

This preceding categories of collected information may have been disclosed to Labs Sophia subsidiary companies and/or service providers.

As described in the “Information we collect and use” Section above, we collect this Personal Information from you and from other categories of sources, such as, public databases; social media platforms; and other third parties, when they share the information with us. For example, we may use such third-party information to confirm contact or financial information, to verify licensure of healthcare professionals, or to better understand your interests by associating demographic information with the information you have provided.

Also as described in the “How we use and collect information” Section we may use this Personal Information to serve you; to connect you with third parties; to validate your ability to access and/or use certain products, services and information; to improve products and services; to protect patients and consumers; and in accordance with any special program terms.

Individual rights of California Residents

Subject to certain exceptions, California residents have the right to make the following requests, at no charge:

1. Copy: You may request, up to twice every 12 months, a copy of the specific pieces of personal data that we have collected, used or disclosed about you in the prior 12 months and to have this delivered, free of charge, either by mail or electronically in a portable and, to the extent technically feasible, readily useable format that allows you to transmit this information to another entity without hindrance.
2. Deletion: You may request deletion of your personal data that we have collected about you.
3. Know: You may request, up to twice every 12 months, that we provide you certain information about how we have handled your personal data in the prior 12 months, including the Categories of personal data collected; categories of sources of personal data; business and/or commercial purposes for collecting your personal data; categories of third parties/with whom we have disclosed or shared your personal data; and categories of personal data that we have disclosed or shared with a third party for a business purpose.

You have the right to be free from unlawful discrimination for exercising your rights under the California Consumer Privacy Act.

Submitting Requests. You may submit requests to delete, access a copy and/or know Personal Information we have collected about you by accessing our Request form at [*], or by contacting us at the channels signaled in the “Contact us” Section. You will be asked to provide certain personal information when submitting you request including your relationship with Labs Sophia, first and last name, email address, telephone number and postal address for us to determine if your information is in our systems.

We will further verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may need to request additional personal information from you, such as your date of birth or government identifier, in order to protect against fraudulent or spoofed requests. If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide us with proof that you have been authorized by the California resident on whose behalf you are making the request, which may include signed permission provided by such California resident.

Please contact us according to the “Contact Us” Section below, if you have any questions regarding this Section for California residents.

NOTIFICATION OF CHANGES

Labs Sophia may from time to time update this Privacy Policy. Any changes will be effective when we post the revised Privacy Policy This Privacy Policy was last updated as of the effective date listed above. If the Privacy Policy changes in a way that significantly affects how we handle personal data, we will not use the personal data we previously gathered in the manner described in the new policy without providing notice and/or obtaining your consent, as appropriate. Minor changes to the policy may occur that will not significantly affect our use of Persona Information without notice or consent. We encourage you to periodically review this page for the latest information on our privacy practices.

CONTACT US

If you have any questions, requests, or concerns related to this Privacy Policy or would like to exercise any of the rights described herein, you may contact us by emailing us at privacy@sophiaint.com or by writing to us at the following address: Labs Sophia, Trademark/Legal Department/Area 1790 Hughes Landing Boulevard Suite 400 The Woodlands, TX, 77380, or by electronic mail at privacy@sophiaint.com

Contact Title: Privacy Manager

Telephone number: 866-282-8871