Mnemo Health Notice of Privacy Practices and Privacy Policy

THIS NOTICE DESCRIBES HOW INFORMATION YOU PROVIDE TO MNEMO MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Mnemo Health, Inc. (“Mnemo”) is committed to keeping your information safe. To help you understand your rights to your information, please review this policy. This notice is in four parts to describe our privacy practices. We hope through this policy that we answer any questions you have about how Mnemo maintains your information . The sections are as follows:

1) What information does Mnemo collect?
2) Who does Mnemo share my information with and why?
3) What are my rights to my information?
4) What should I do if I have a question or concern about my collected information?

What information does Mnemo collect?
When you voluntarily give your information to Mnemo through the use of our app, we maintain such information in our secure systems . Examples of information you may provide to Mnemo include:
• When you choose to register for the Mnemo program, you provide your personal information such as your height, weight, and age. • When you use the Mnemo program, we will receive information from you such as your blood glucose readings.

Who does Mnemo share my information with and why?
Mnemo will not share any information with any other entity without your written authorization. We will not use or disclose your information for marketing purposes or sell your information, unless you have agreed to this use or disclosure . You can inform us at any time that you no longer allow us to use or disclose your information for the reasons shown below, but this will not stop any disclosure that we made based on your prior authorization. The law permits us to use and disclose your information for the following purposes: • Treatment: We may use or disclose your information to healthcare professionals for treatment purposes. This includes to the clinical teams at your employer, health plan, and/or pharmacy benefits managers to extent such group sponsors your use of the Mnemo program (i.e., the Mnemo benefit is paid for by your employer, health plan, etc.) . • Healthcare Operations - We may use or disclose your information for activities necessary to support our healthcare operations, such as performing quality checks on our services, internal audits, arr anging for legal services, data analysis or developing reference ranges for our services. De-identifiable and Aggegated Format – We may use and disclose your information in a de - identifiable and aggregated manner to review our impact on all our members health and in hopes of making the Mnemo programs even more effective to help you with your management of your chronic condition. • Research - We may also use and disclose information for research purposes when an Institutional Review Board or privacy board has reviewed the research proposal and established protocols to ensure the privacy of your information and determined that the researcher does not need to obtain your authorization prior to using your information for research purposes. • As Required by Law - We may use or disclose your information as required by law. • Law Enforcement Activities , Legal Proceedings and Court Orders - We may use and disclose your information to prevent or minimize a serious threat to your health and safety or that of another person. We may also provide information to law enforcement officials, for example, in response to a warrant, investigative demand or similar legal process, or for officials to identify or locate a suspect, fugitive, material witness, or missing person. We may also disclose information to appropriate agencies if we reasonably believe an individual to be a victim of abuse, neglect or domestic violence. We may disclose your information if required to do so with a court or administrative order. We may disclose your information in response to a subpoena, discovery request or other legal process during a judicial or administrative proceeding . We may also disclose information to those assisting in disaster relief efforts so that others can be notified about your condition, status and location. • Family and Friends: At your request, we may disclose information to a family member, friend, or anyone else you inform us to provide the information to. • Other Uses and Disclosures: As permitted by HIPAA, we may disclose your information to: • Public Health Authorities • The Food and Drug Administration • Health Oversight Agencies • Military Command Authorities • National Security and Intelligence Organizations • Correctional Institutions • Organ and Tissue Donation Organizations • Coroners, Medical Examiners and Funeral Directors • Workers Compensation Agents

What are my rights to my information?
You have rights to your information that we collect. You can request Mnemo restrict the use and disclosure of your information by sending written request to the address below. You also have the right to receive a list of certain disclosures of your information made by us in the past six years from the date of your written request to us at the address below. Under the law, this does not include disclosures made for purposes of treatment, payment, or healthcare operations or the other certain other purposes we have stated above . Please be aware that we are required as stated in the Health Insurance Portability and Accountability Act (HIPAA) of 1996 to notify you in the event of a breach involving your information and will do so as required by law. You have the right to obtain a paper copy of this Privacy Policy by written request to the address below.

What should I do if I have a question or concern about my collected information?
If you believe your privacy rights have been violated, you have the right to file a complaint with us. You also have the righ t to file a complaint with the Secretary of the U.S. Department of Health and Human Services, Office for Civil Rights. We will not retaliate against any individual for filing a complaint. To file a complaint with us, or should you have any questions about this Privacy Policy and Notice of Privacy Practices, send an email to us at legal @Mnemo.com, or write to us at the following address:

Mnemo Health, Inc.
4139 W Venus Way
Suite 100
Chandler, AZ 85226

Note: We reserve the right to amend the terms of this Privacy Policy and Notice of Privacy Practices to reflect changes in our privacy practices, and to make the new terms and practices applicable to all information that we maintain about you, including information created or received prior to the effective date of the Privacy Policy and Notice of Privacy Practices revision. Our Privacy Policy and Notice of Privacy Practices is displayed on our website and a copy is available upon request. Accordingly, please check back periodically.

Updated : October 25 , 2018