Cariloop, Inc. (“Cariloop,” “us,” or “we”) respect your privacy and is committed to protecting it through our compliance with this policy.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website www.cariloop.com (the Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. Our use of your Personal Data may be further limited by a HIPAA Business Associate Agreement entered into between us and the health plan sponsored by your employer when your employer provides access to our Website and our services as part of your benefits. If anything in this Privacy Policy conflicts with HIPAA or a HIPAA Business Associate Agreement, we will comply with the terms of HIPAA and the HIPAA Business Associate Agreement where applicable.

This Privacy Policy applies to information we collect:

– on our Website; and
– in email, text, and other electronic messages (including phone calls) between you and our Website.

It does not apply to information collected by:

– us offline or through any other means, including on any other website operated by Cariloop or any third party; or
– any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

You may use our Website to help you in the care of your loved one of any age. However, our Website is not intended for use by children under 18 years of age. No one under age 18 may directly provide any information to the Website. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Website or on or through any of its features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at through the Contact Information below.

Generally

We collect several types of information from and about users of our Website (“Personal Data”):

• by which you may be personally identified, such as name, postal address, e-mail address, and telephone number;
• that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website, error information clickstream data, and other communication data and the resources that you access and use on the Website; and/or
• about your internet connection, the equipment you use to access our Website and usage details, IP addresses, operating system, and browser type.

We collect this information:

• directly from you when you provide it to us;
• automatically as you navigate through the Website, for example, information collected through cookies, web beacons, and other tracking technologies; and
• from third parties, such as your Healthcare Coach.

Information You Provide to Us

The information we collect on or through our Website is:

• information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, interacting with your Healthcare Coach, or requesting further assistance through our 24/7 caregiver support platform. We may also ask you for information when you report a problem with our Website;
• records and copies of your correspondence (including email addresses), if you contact us; and
• information that you provide in your private case file.

You also may provide information to be published or displayed (hereinafter, “posted”) to be transmitted to a select group of other users of the Website or third parties (collectively, “User Messages”). Your User Messages are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Messages. Therefore, we cannot and do not guarantee that your User Messages will not be viewed by unauthorized persons.

On occasion and solely with your permission, we may also publish feedback about our services and your Healthcare Coach that you provide on our Website or elsewhere.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns as described above.

The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:

• estimate our audience size and usage patterns;
• store information about your preferences, allowing us to customize our Website according to your individual interests;
• speed up your searches; and
• recognize you when you return to our Website.

The automated data collection technologies we use include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Website. You can find more information about cookies at http://www.allaboutcookies.org.
• Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Cariloop, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).
• Third Party Cookies. Some content on our Website is served by third parties, including advertisers, ad networks and servers, content providers, application providers, and social media sites. With your consent, these third parties may use cookies (alone or in conjunction with web beacons or other tracking technologies) to collect information about you when you access our Website. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising and other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about advertisement or other targeted content, you should contact the responsible provider directly. For information on how you can consent or withdraw your consent to receive targeted advertising from many providers, please see Choices About How We Use and Disclose Your Information.

We use information that we collect about you or that you provide to us, including any Personal Data:

• to present our Website and their contents to you;
• to provide you with information, products, or services that you request from us;
• to inform your Healthcare Coach of new information;
• to fulfill any other purpose for which you provide it;
• to provide you with notices about your account, including expiration and renewal notices;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to notify you about changes to our Website or any products or services we offer or provide though them;
• to allow you to participate in interactive features on our Website;
• in any other way we may describe when you provide the information; and
• for any other purpose with your consent.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you wish to opt-out of this use, you may do so at any time by logging into the Website and adjusting our user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email through the Contact Information below. For more information, see Choices About How We Use and Disclose Your Information.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy, including to your employer or the health plan sponsored by your employer. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction, including to your employer or the health plan sponsored by your employer if your employer offers you access to our Website and our services as part of your benefits.

We may disclose Personal Data that we collect or you provide as described in this Privacy Policy:

• to our subsidiaries and affiliates;
• to contractors, service providers, and other third parties we use to support our business;
• to your Healthcare Coach;
• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Cariloop, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Cariloop, Inc. about our Website’s users is among the assets transferred;
• to fulfill the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information; and
• with your consent.

We may also disclose your Personal Data:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Cariloop, Inc., our customers, or others. This includes exchanging information with other companies and organizations such as law enforcement or other regulatory authorities.

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Offers from Cariloop. Unless you opt out, we may use your contact information to promote our own or third parties’ products and services. If you wish to opt-out to such use, you can check the relevant box located on the form on which we collect your Personal Data or otherwise give you this choice. If you wish to change your choice, you may do so at any time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by contacting us through the Contact Information If we have sent you a promotional email, you may click the unsubscribe link to be omitted from future email distributions. This opt out does not apply to information provided to Cariloop as a result of transactions on the Website or communications with your Healthcare Coach.

You can review and change your Personal Data by logging into the Website and visiting your account profile page. You may also contact us through the Contact Information below to request access to, correct or delete any Personal Data that you have provided to us. We cannot delete your Personal Data except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete your Personal Data from the Website, copies of your Personal Data may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Information, is governed by our Terms of Use.

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where you require a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website except where required by law.

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website’ home page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Website’ home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact through the contact information below or through the “Contact Us” page on our Website.