Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy ("Health Data Policy") describes how VisageAir™ ("VisageAir," "we," "us," or "our") processes regulated health information and consumer health data (collectively "Consumer Health Data"), as those terms are defined under applicable state privacy law, about consumers who reside in the states of Nevada, New York, Washington, and any other applicable U.S. jurisdiction, in connection with our wellness application (the "Digital Platform") as well as our website, visageair.com (the "Website"). Please read this Health Data Policy carefully; it contains important information concerning your Consumer Health Data and how we use it.

This Health Data Policy relates only to Consumer Health Data. It does not describe how we process your other personal information. For that, please refer to our Privacy Policy.

The information we process

Our collection, use, and disclosure activities may differ depending on your relationship with us. We may collect the following categories of Consumer Health Data:

• A frontal face photo captured with the guided frame, which may constitute biometric information under applicable law;
• Your own face-change measurements over time derived from that photo, and your own face trend over time produced from those measurements;
• Typed details you choose to provide, such as age, sex, height, and weight;
• Any inferences based on the above categories that identify your past, present, or future physical status. We note that your own face trend over time is general wellness and longevity information and is not a medical device.

We may collect Consumer Health Data from the following sources:

• Directly from you when you use the Digital Platform; and
• Through our service providers that support the Digital Platform. We do not "sell" Consumer Health Data as that term is defined under applicable law.

We may collect, process, and disclose Consumer Health Data for the following purposes:

• To provide, operate, maintain, and protect the Digital Platform, including producing your own face trend over time and a summary of your own change over time;
• To display your result to you;
• To analyze and improve the Digital Platform using de-identified data, as described below;
• To communicate with you and respond to your inquiries;
• To protect the security or integrity of the Digital Platform;
• To comply with applicable law, regulation, or legal process, and to protect us, our users, and the public; and
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which data held by us is among the assets transferred.

We do not use face photos to train models without your separate, specific, opt-in consent.

We may disclose the above categories of Consumer Health Data for the purposes described above to the following third parties:

• You;
• Service vendors that support the Digital Platform and similar advisors (such as attorneys, consultants, or accountants), bound by contract;
• As legally required in relevant legal proceedings and otherwise to the extent required or explicitly authorized by applicable law;
• Third parties within the context of a merger or similar business transaction; and
• Other third parties at your express direction.

De-identified data. We may process de-identified data derived from Consumer Health Data. Where we do, we take reasonable measures to ensure the data cannot be associated with any consumer or device, we publicly commit to process such data only in a de-identified fashion and not to attempt to re-identify it, and we contractually obligate any recipient of such data to comply with these same requirements.

Your privacy rights

Depending on your place of residency, you may have some or all of the following rights regarding your Consumer Health Data, subject to applicable law and certain exceptions:

• Right to confirm and access. We will confirm whether we are collecting, sharing, or selling your Consumer Health Data, provide a list of third parties with whom we have shared it, and provide you a copy.
• Right to correct. You may request that we correct inaccurate Consumer Health Data.
• Right to withdraw consent. Where we rely on your consent, you may withdraw it at any time. Withdrawing consent deletes the photo and derived measurements, subject to legal retention requirements.
• Right to delete. You may request that we delete the Consumer Health Data we maintain about you.
• Right to appeal. If we deny your request, you may appeal the decision.

To exercise any of the above rights, you or your authorized agent may contact us as set out below. To process your request, we may ask you to verify your identity by confirming information we have in our records.

Updates to this Health Data Policy

We may update this Health Data Policy from time to time and notify you in accordance with law, which may include email or other notice posted to the Digital Platform or Website. Any changes will become effective when we notify you of the changes.

Contact us

For questions about this Health Data Policy, or to exercise a right described here, email [email protected]. A postal address and telephone number will be published here before any pilot begins.

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