Welcome to Sandy Health. Your privacy is important to us. This privacy policy (the “Privacy Policy”) helps you better understand our privacy practices, as well as your rights with respect to your data, for your use of the technology and services provided by Sandy AI, Inc., d/b/a Sandy Health (referred to herein as “Sandy Health”, “we”, “our”, or “us”). This Privacy Policy describes how and why Sandy Health might collect, store, use and/or share (collectively, “process”) and protect your personal information when you visit our websites, including but not limited to, https://sandyhealth.ai/, including any subdomains (the “Website(s)”), and any other websites or interfaces that link to https://sandyhealth.ai/ or this Privacy Policy (together with the Websites, the “Products”).

You should read this Privacy Policy carefully as it governs your use of the Products. By accessing or using any of the Products, you acknowledge that you have read, understand, and agree to be bound by this Privacy Policy in its entirety. If you do not agree, you are not authorized to access or use any of our Products and should not use our Products.

By accessing any of the Products, you agree that your personal information will be handled as described in this Privacy Policy. Your use of our Products, and any dispute over privacy, is subject to this Privacy Policy, including its applicable limitations on damages and the resolution of disputes. If you do not agree, you are not permitted to access or use any of the Products.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Policy, but you can find out more details about any of these topics below.

What personal information do we process? When you visit, use, or navigate our Products, we may process personal information depending on how you interact with us and the Products, the choices you make, and the specific services and features you use.

Do we process any sensitive personal information? We do not knowingly process sensitive personal information.

Do we receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources.

How do we process your information? We process your information to provide, improve, and administer our Products, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have implemented organizational and technical safeguards, processes, and procedures to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We use industry-leading identity management, database, and web services to store your information.

Please be aware that despite our best efforts, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is to submit a request by contacting us via email at legal@sandyhealth.ai. We will consider and act upon any request in accordance with applicable data protection laws.

Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Products. If you still have any questions or concerns, please contact us at legal@sandyhealth.ai.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT? 3

2. HOW DO WE PROCESS YOUR INFORMATION? 4

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION? 5

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION? 5

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? 6

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY? 6

7. HOW LONG DO WE KEEP YOUR INFORMATION? 6

8. HOW DO WE KEEP YOUR INFORMATION SAFE? 7

9. CONTROLS FOR DO-NOT-TRACK FEATURES 7

10. DO WE COLLECT INFORMATION FROM MINORS? 7

11. WHAT ARE YOUR PRIVACY RIGHTS? 8

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE DATA WE COLLECT FROM YOU? 12

13. DO WE MAKE UPDATES TO THIS NOTICE? 13

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE? 13

1. WHAT INFORMATION DO WE COLLECT?

We collect personal information that you voluntarily provide to us when you register using any of the Products, express an interest in obtaining information about us or our Products, when you participate in activities using the Products, or when you otherwise contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Products, the choices you make, and the Products you use. The personal information we collect may include the following:

• Names; 

• Email Addresses;

• Usernames;

• Passwords;

• Contact Preferences;

• Contact or Authentication Data;

• Any Feedback you provide us; and/or

• Other information you specifically provide us. 

If you specifically provide us with information (such as your email address), we may use that information for the purposes described when you provide it to us.

Sensitive Personal Information. We do not knowingly process any sensitive personal information via our Products, such as personal identification (ID) numbers or credit or financial data.

Information Automatically Collected

We automatically collect certain information when you visit, use, or navigate our Products. This information does not reveal your specific identity (like your name or contact information), but may include device, system, and usage information such as your IP address, browser type, device name, type and characteristics, operating system, language preferences, referring URLs, country, location, information about how and when you use our Products, and other technical information. This information is primarily needed to maintain the security and operation of our Products, to comply with applicable law, to verify your eligibility to access and use the Products, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.

The information we collect may include:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Websites and when we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, settings, and information about your activity in a Website (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).

• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access any Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider, operating system, and system configuration information.

• Location Data. We collect location data such as information about your device’s location based on your IP address. How much information we collect depends on the type and settings of the device you use to access a Website. You can opt out of allowing us to collect this information either by refusing access to the information, however if you choose to opt out, you may not be able to use certain aspects of the Websites or the Products.

Information Collected From Other Sources

We may collect limited data from public databases, marketing partners, and other outside sources. In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your information for purposes including:

• To provide, improve, and administer our Products.

• To personalize your experience using our Products.

• To communicate updates, promotions, or important information.

• To comply with legal obligations.

• For security and fraud prevention.

• For analytics and research to improve website performance and user experience.

With your consent, we may also process your information for other purposes depending on how you interact with our Products, including:

• To facilitate account creation and authentication and otherwise manage user accounts. For example, we may process your information so you can create and log in to your account, and keep your account in working order.

• To deliver and facilitate delivery of Products to the user. We may process your information to provide you with your requested Products.

• To respond to user inquiries or offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested Products.

• To send you administrative information to you, such as details about our products and services, changes to our terms and policies, and other similar information.

• To request your feedback and to contact you about your use of our Products.

• To protect our Products as part of our efforts to keep our Products safe and secure, including fraud monitoring and prevention.

• To save or protect when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal bases) to do so under applicable law. For example, with your consent, to comply with laws, to provide you with the Products, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests. Jurisdiction specific legal bases and discussion can be found below.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share information with third parties or in specific situations as described in this section:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Business Affiliates. We may share your information with our affiliates such as our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

• Business Partners. We may share your information with our business partners for purposes such as joint marketing campaigns, collaborative projects, and similar business purposes.

• Service Providers. We may share your information with our third-party service providers such as website hosting, payment processing, email communication, analytics, and other services necessary to operate our business.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and other tracking technologies (like web beacons and pixels) to process or store your information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookies Notice, available at https://sandyhealth.ai/cookies.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

We may transfer, store, and process your information in countries other than your own. Our servers are located in the United States. If you are accessing our Products from outside the United States, please be aware that your information may be transferred to, stored, and processed by us and by those third parties with whom we may share your personal information, in the United States, and other countries.

If you are a resident in the European Economic Area (“EEA”) or United Kingdom (“UK”), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.

European Commission’s Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law. We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). Generally, we will retain your personal information for the period during which you have an account with us, plus a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce our agreements, typically not exceeding one (1) year after account closure unless otherwise required by law.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

We aim to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Products is at your own risk. You should only access the Products within a secure environment.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and applications include a Do-Not-Track (“DNT”) feature/setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is made a requirement by applicable law, we will revise this Privacy Policy.

10. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly process data from or market to children under 18 years of age. By using the Products, you represent that you are at least 18 years of age. If you are the parent or guardian of a minor between the ages of 13 and 18, you may consent to such minor’s use of the Products, subject to your supervision and agreement to be bound by this Privacy Policy on behalf of such minor. If we learn that personal information from users less than 13 years of age has been collected without verified parental consent, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If we learn that personal information from users between 13 and 18 years of age has been collected without parental consent where required, we will take appropriate measures in accordance with applicable law. If you become aware of any such data, please contact us via email at legal@sandyhealth.ai.

11. WHAT ARE YOUR PRIVACY RIGHTS?

In some regions, such as the EEA, UK, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Contact us by email using the contact information provided.

• If applicable, log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Products. To opt out of interest-based advertising by advertisers on our Products visit http://www.aboutads.info/choices/. 

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (“GDPR”) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.

• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Products or at your request prior to entering into a contract with you.

• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests, and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

  • Diagnose problems and/or prevent fraudulent activities; and

  • Understand how our users use our products and services so we can improve user experience

• Legal Obligations. We may process your information where it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

• Vital Interests. We may process your information where it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us express consent to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time by contacting us at legal@sandyhealth.ai.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;

• For investigations and fraud detection and prevention;

• For business transactions provided certain conditions are met;

• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;

• For identifying injured, ill, or deceased persons and communicating with next of kin;

• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;

• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;

• If the collection is solely for journalistic, artistic, or literary purposes; and/or

• If the information is publicly available and is specified by the regulations.

If you are located in the United States, this section may apply to you.

Under some U.S. state laws, residents are granted specific rights regarding access to their personal information.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this Privacy Policy and our Cookies Notice, which are incorporated herein by reference. If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable state law requirements.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to visitors, users, and other consumers of our Products.

Your rights with respect to your personal data.

• Right to Know: The right to request the personal data that we collect, use, or disclose and information about our data practices;

• Right to Request Deletion: The right to request that we delete the personal data we have collected about a user; 

• Right to Opt-Out of Data Sales and Sharing: The right to opt out of the sale or sharing to third parties of a user’s personal data that we have collected; 

• Right to Non-Discrimination: The right to not be discriminated against for exercising any of these rights;

• Right to Correct Information: The right to update or correct the personal data that we collect;

• Right to Limit Use or Disclosure of Sensitive Personal Information: The right to limit the use and disclosure of Sensitive Personal Information (as defined under the CPRA);

• Right to Access Information Related to Automated Decision Making: The right to inquire about our logic involved in automated decision-making applied to personal data we collect; and

• Right to Opt-Out of Automated Decision-Making Technology: The right to request a user’s removal from having automated decision-making applied to a user’s personal data that we collect.

Verification process.

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. Where possible, we will avoid requesting additional information from you for verification purposes. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

You may object to the processing of your personal information. You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the information.

You can designate an authorized agent to make a request under the California Consumer Privacy Act (“CCPA”) or other applicable state privacy laws on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA or other applicable law. Such proof may include a power of attorney or a signed permission from you demonstrating that the authorized agent has been authorized to act on your behalf.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission. To exercise these rights, you can contact us by email at legal@sandyhealth.ai.

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your jurisdiction, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please contact us by email at legal@sandyhealth.ai.

13. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws. We reserve the right to change, revise, update, suspend, discontinue, or otherwise modify our Products at any time. Further, we reserve the right to update this Privacy Policy from time to time. The updated version will be indicated by a “Last Updated” date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. However, we reserve the right to make changes at our sole discretion without note. We have no obligation to update any information on our Websites or this Privacy Policy. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information. Your continued use of our services after any changes to this Privacy Policy constitutes your acceptance of such changes.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at legal@sandyhealth.ai.