Privacy Policy

At IO health, we are strongly committed to protecting your privacy. To protect your privacy, we provide this notice explaining our data and information practices and the choices you can make about the way your information is collected and used.

This Policy applies to Personal Information (as defined below) that you provide to IO health through the Services. “Personal Information” is any information that can identify you (such as your name, address, passport number, etc.).

Information That We May Collect

1.       We may collect the following types of Personal Information that you voluntarily enter when you visit the IO health Portal and register to access services: name, that you are an adult, gender, and basic contact details including your e-mail address, and mobile telephone number. IO health will store this information on secure servers located in the UAE that comply with all applicable laws. We also may collect additional information, but no additional Personal Information, when you register to access and use additional Services. We do not collect personal sensitive information such as medical data, health status, diagnosis information, or specific location information (apart from which Emirate you live in the UAE) – this is information that you will provide directly to your medical professional and healthcare provider.

2.       On some pages, you may opt to provide IO health information about yourself for example if you are interested in (a) an employment opportunity at IO health; or (b) partnering with IO health. The information requested from you will be based on your area of interest.

3.       On occasion, IO health may request that you voluntarily participate in a survey or poll such as feedback on Content or Services. Your responses will be anonymous unless you opt in to being contacted by email to provide further information regarding the survey.

4.       In order to improve the design and content of the IO health Portal, to enable IO health to better personalize your user experience, and for other purposes outlined in this Policy, we may collect certain technical information when you visit the IO health Portal pages, such as the IP address or the type of browser you are using, the type of operating system you are using, the domain name of your Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.

5.       We may receive information about you from other sources, including through third-party services and organizations to supplement information provided by you. This supplemental information allows IO health to verify information that you have provided to IO health and to enhance our ability to provide you with information about our business, products, and Services. For example, if you access third-party services, such as Facebook or Twitter, to login to the Services or to share information about your experience with IO health, we may collect information from these services.

6.       From time to time, we may provide Services that are specifically designed to be compatible and used on mobile devices. IO health will collect certain information (including Personal Information) that your mobile device sends when you use such Services, like a device identifier, user settings and the operating system of your device. IO health’s Services may require that users log in with an account. In addition, we may enable you to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to IO health to enable you to access your user accounts and to enable IO health to track use of these tools. IO health may use Personal

Terms of Use

Information or non-identifiable information transmitted toIO healthto enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Policy or in other notices IO health provides.

How We May Use Your Information

We acquire, hold, use, and process Personal Information based on the legal grounds and for the legitimate business purposes outlined in this Policy or as otherwise clearly identified at point of collection. Our legitimate business purposes for processing Personal Information include:

·         To provide Services and Content and other information that you are interested in: We use your Personal Information to enable you to receive access to our Content and Services, obtain information about our Services and receive updates, participate in surveys or questionnaires, provide you with opportunities to learn about our other products, programs, or Services that we believe may be of interest to you, and to enable IO health to respond to your requests.

·         For Administrative Purposes: We also may use your Personal Information for our administrative purposes, such as to measure interest in and/or develop our Services, ensure internal quality control, comply with regulatory requirements, prevent potentially prohibited or illegal activities, and enforce the IO health Terms of Use.

·         To Market our product and Services: Our use of Personal Information may also include for purposes of providing you with materials about offers, products, Content, and Services that may be of interest, including new Content or Services. IO health may provide you with these materials by SMS or email, as permitted by applicable law.

·         For Research and Development of new products and Services: IO health may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help IO health to optimally deliver our existing products and Services or develop new products and Services. From time to time, IO health may perform research (online and offline) via surveys. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help IO health better serve individuals by learning more about their needs and the quality of the products and Services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications and/or promotional activities. If you participate in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.

·         For Marketing Purposes: Individuals who provide IO health with Personal Information, or whose Personal Information we obtain from third parties, may receive periodic emails or SMS messages from IO health with information about IO health’s or our business partners’ products and Services or upcoming special offers/events we believe may be of interest. In some cases, we may only contact you with your permission and we always offer the option to decline these communications at no cost to the individual by following the instructions below.

·         Other Purposes: IO health may use Personal Information for other purposes for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information and/or with your consent.

·         To create Anonymous and/or Aggregated Information: IO health may use Personal Information and other information about you to create anonymized and aggregated information, such as de- identified demographic information, de-identified location information, information about the computer or device from which you access IO health’s Services, or other analyses we create.

Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within IO health and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

·         Information You Submit: You agree that IO health is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. IO health will not release your name or otherwise publicize the fact that you submitted materials or other information to IO health unless: (a) you grant IO health permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or

(c) we are required to do so by law.

Sharing Your Information

We may share your Personal Information as described in this Policy (e.g., with our third-party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission. In almost all cases, any information you share with IO health will be masked, de-identified, modified, encrypted, or otherwise anonymized to further protect your privacy to ensure that no third-party will be able to directly identify you and you will remain anonymous except to the extent that such information is required for you to continue to access and use the Services.

·         Vendors and Service Providers: We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the IO health Portal. IO health has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

·         Business Partners: IO health may share Personal Information with our business partners, affiliates, and for our affiliates’ internal business purposes or to provide you with a product or Service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or Services, or whose products or Services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with IO health’s. IO health requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it by any mean or for any purpose other than the means and purpose for which we provided it to them.

·         Displaying to Other Users: The content you post to the Site may be displayed on the Site if you submit a review. In such case, other users of the Site may be able to see some information about you, such as your name. We are not responsible for privacy practices of the other users who will view and use the posted information.

·         Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures): We may access, preserve, and disclose your Personal Information, and other account information, if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce IO health policies or

contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

·         Merger, Sale, or Other Asset Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. Should such an event occur, IO health will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Policy in effect at the time such Personal Information was collected and will comply with any legal or regulatory additional requirements applicable to those transfers.

We do not share personally identifiable information with unrelated third parties who are not covered by this privacy statement without your prior permission, except to the extent reasonably necessary to: (i) correct technical problems and malfunctions; (ii) protect the security and integrity of the IO health Portal; (iii) protect our rights, interests and property and the rights, interests and property of others; (iv) comply with laws or to respond to judicial process; or (v) provide information to law enforcement agencies or for an investigation of a matter as applicable, or otherwise as required or permitted by law.

Data Security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you.

Cookies and other Technologies

We receive IP addresses in the normal course of the operation of the IO health Portal. An IP address is a number assigned to you by your Internet service provider so you can access the Internet.

We, as well as third parties that provide content or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Such Technologies that we may use are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “Device”) that allow certain pieces of information to be recorded and recognize you whenever you visit or interact with the IO health Portal and Content.

·         Cookies: A cookie is a piece of data or file sent to your browser, which may then store it on your Device. Most browsers allow you to block and delete cookies. However, if you do that, the IO health Portal may not work properly or you may not be able to receive personalized content. IO health may use cookies on the IO health Portal in order to:

o    Provide access to our Content: for example, allow you to personalize your experience by keeping you logged in, accessing information, products, and services relevant to your areas of interest.

o    Show Content that is more relevant to you: for example, with your consent, we use tracking technologies to remember Content that has interested. Cookies will also help limit the number of times that you see Content, measure your interest in the Content we show to you. IO health may allow other organizations to use tracking technologies for these same purposes.

o    Analyze and improve your browsing experience on the IO health Portal: for example, to track your session within the IO health Portal so we can learn what content has interested you. We will also use cookies to understand general information about users, such as areas of interest. We also check for bugs and glitches in the Content.

o    Other similar relevant purposes that we may implement in the future.

·         Pixel tags/Web beacons: A pixel tag (also known as a web beacon) is a piece of code embedded on the IO health Portal that collects information about users’ engagement. The use of a pixel allows IO health to record, for example, that a user has viewed certain Content or clicked on a particular link.

·         Social Media Features: The IO health Portal may in the future include social media integrations such as the YouTube “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on the IO health Portal, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a third-party or hosted directly on the IO health Portal. Your interactions with these features are governed by the privacy policy of the company providing it.

Analytics

We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection  and  processing  of  data  generated  by  your  use  of  the  Services  by  going to http://tools.google.com/dlpage/gaoptout.

Our use of such Technologies consists of the following general categories:

·         Operationally Necessary. We may use cookies, web beacons, or other similar Technologies that are necessary to the operation of the IO health Portal, the Services, Content, and other features, functionalities, and tools. This includes Technologies that allow you access to the IO health Portal, the Services, Content, and other features, functionalities, and tools that are required to identify irregular behavior, prevent fraudulent activity, improve security, or that allow you to make use of our functions.

·         Performance Related. We may use cookies, web beacons, or other similar Technologies to assess the performance of the IO health Portal, the Services, Content, and other features, functionalities, and tools, including as part of our analytic practices to help IO health understand how our visitors use the IO health Portal, Services, and Content, determine how you have interacted with the IO health Portal, Services, and Content and determine whether you have viewed an item or link, or to improve the IO health Portal, Services, and Content.

·         Functionality Related. We may use cookies, web beacons, or other similar Technologies that allow IO health to offer you enhanced functionality when accessing or using the IO health Portal, the Services, Content, and other features, functionalities, and tools. This may include identifying you when you sign into the IO health Portal or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of Content on the IO health Portal.

·         Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver Content on the IO health Portal or on third-party sites. This includes using Technologies to understand the usefulness to you of the Content that has been delivered to you.

If you would like to opt-out of the Technologies we employ on the IO health Portal, you may do so by blocking, deleting, or disabling them as your browser or Device permits.

Your Choices

You may be asked, in some cases, to consent to the processing of Personal Information. In any case, you have the right to opt out of certain uses and disclosures of your Personal Information.

Where you have consented to IO health’s processing of your Personal Information, you may withdraw that consent at any time and opt out of further processing by following the instructions in this section. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on the IO health Portal.

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain communications regarding IO health and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Policy).

Your Rights

You may inquire as to whether IO health is processing Personal Information about you, request access to Personal Information, and ask that we limit, restrict, port, correct, amend, or delete your Personal Information.  Where  otherwise  permitted  by  applicable  law,  you  may  send  an  e-mail to [email protected] or use any of the methods set out in this Policy to request access to, receive (port), seek rectification, request erasure of Personal Information held about you by IO health, or exercise any other rights available to you under applicable law. Such requests will be processed in line with local laws.

Although IO health makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which IO health is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. If IO health determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, IO health will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Data Retention

The information you provide to IO health may be archived or stored periodically by IO health according to backup processes and will only be retained for as long as is required for the purposes for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits,

pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. Following the statutory period proscribed by law, IO health will destroy or delete such information in accordance with standard industry practices.

Third-Party Websites

The IO health Portal may contain links to other third-party websites. You should carefully review the privacy policies and practices of other websites, as we cannot control or be responsible for privacy policies or practices of third-party websites.

Notification of Changes

We regularly review and update our privacy statement. If there are any material changes to this Policy, IO health will notify you as required by applicable law. We will post any adjustments to the Privacy Policy and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you continue to access and use the IO health Portal after such changes have been made, you hereby provide your consent to the changes. If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide you with information regarding the new purpose and obtain your consent, if required.

Contacting Us

If you wish to access, correct, update, request removal of or exercise your rights in relation to any of your information you provided to IO health or if you have any questions regarding this statement or would like more information on our privacy practices, please contact IO health at: [email protected].

If you feel that IO health is not abiding by the terms of this Policy, please contact IO health at the contact information provided above.