Privacy Policy

This Privacy Policy applies to your use of WatchRx smartwatch with Watch App (the “Watch”),
a Caregiver Mobile Application (the “App”) and related web interface (the “Site”) owned by
WatchRx Inc. (“we” or “us”). The Watch, App and the Site are referred to together as the
“Application”. ‘You’ refers to any user of the Watch, Application, including individuals who use
the Application to track medication compliance of themselves or on behalf of their care
recipients, healthcare providers who use the Application to monitor compliance of users under
their supervision. If you do not agree to the terms of this Privacy Policy, including with respect
to (a) the collection and processing of Health Information (as defined below), (b) the collection
and processing of your geo location data (c) our cookies policy, (d) cross border transfer of
data and (e) marketing, please do not click “Login” or “Register” and do not use the Application.

We have the highest regard for your privacy and personal information and realize that the
success of our service depends on the trust that users have in the way we handle their
personal information. This policy sets out our commitments and explains the rights that you
have with respect to your personal information.

INFORMATION COLLECTION AND USE

WatchRx respects your right to privacy. While you may use some of the functionality of the
Site without registration, use of the Application and certain tools of the Site require
registration. If you use our Site without registering, we only collect information through the
use of cookies, web beacons and navigational data collection. While we cannot directly
identify you, in some jurisdictions, this information is still subject to applicable data protection
laws and requires your consent to our cookies policy as described below. If you choose to
register with us, you will be asked to provide Personal Information (as defined below) and may
also be asked to input your personal information and/or your care recipient Personal Health
Information. It is your voluntary decision whether to provide us with any such Personal
Information or Health Information, but if you refuse to provide such information, we may not
be able to register you to use the Application or your use of the Application may be limited.

Collecting and Using Your and/or your care recipient Personal Information and Health
Information (Actively Provided Information)

Whenever you submit information via our App or Site, or otherwise in connection with your
use of the Application, including, but not limited to, by telephone or email with customer
service, you consent to the collection and processing of your Health Information and geo
location data and other personal information you provide to us, our cookies policy, cross
border transfer of data, and the use of your data for marketing purposes, all in accordance
with this Privacy Policy. WatchRx respects your right to privacy. Please read this Privacy Policy
for more information about collection, storage, use, processing, combination, deletion, and
disclosure of your Personal Information.

“Personal Information” means information that can be directly associated with a specific
person (and includes Health Information). When you register or update your information on
our Site or through our App, we collect the following information:

first and last name, email address, phone number, address, date of birth, geo-location, patient
image, emergency contacts etc.

If you are a healthcare provider, during registration you will be asked to provide Personal
Information including qualification, title etc.

During registration or subsequently, you may choose to use certain features of the Watch and
the Application that will allow you to input other Personal Information with respect to your or
your care recipient health, such as the medications taken, the date of the prescription, the
number of refills, medication regimen, (“Health Information”). We will send reminders to the
watch to take medications in accordance with this information.

As a caregiver using the caregiver application or Site, you may also send family members or
friends an invitation to be secondary caregivers, so that such caregivers will receive alerts
regarding the care recipient’s compliance with medication regime. By sending such invitation,
you represent that you have the right to contact other caregivers and that you consent to our
sending Personal Information about your care recipient medications and compliance with
medication regime to the caregivers. Sharing of your and or your care recipient Personal
Information in this manner is solely your responsibility.

You may use the Watch and the Application in order to share your Personal Information or
other information with your doctor or healthcare providers. Such sharing may be enabled by
inviting your healthcare provider to monitor your Personal Information, by accepting an
invitation from your healthcare provider to download and use the Application, or otherwise
using the Application settings to share your information with your healthcare
provider; in these cases you consent to our sending Personal Information about your
medications and your compliance with your medication regime with your healthcare providers.
Confirm with your healthcare provider that they have sent you an invitation to download
WatchRx Application. Such sharing of your information is at your discretion and is solely your
responsibility.

If you are a healthcare provider using the Application to invite individuals to monitor patients
under your supervision to use the Application, you agree not to include any Personal
Information about you or your professional qualifications in the text of these invitations. We
may also use your Personal Information in order to provide you with personalized third-party
content or links to third party sites that might interest you, as part of the feed on the
Application. We provide this third-party content and/or links to third party sites for
information purposes only and are not liable for such content or sites. For more information
see the “Links to other Websites or Apps” section below.

We may also use the Personal Information (1) to identify your account for purposes of
providing you with customer services and to respond to your requests, (2) to provide you the
specific services you select (including the requested reminders), (3) to help diagnose problems
with our servers, to make the Application more useful, for other internal purposes or to
customize the Application and personalize its content for you; and (4) to send you texts, emails
or other communications regarding general adherence information, Application maintenance,
updates, or changes to this Privacy Policy or any other relevant agreements. Please note that
we reserve the right to send you such service-related communications without offering you
the opportunity to opt out of receiving them unless you cancel your account.

While we take great care to keep your Personal Information confidential and secure, when
you share your health or medication information with others or provide feedback regarding
health matters, medications and otherwise, including by means of social media sites, or when
you participate in a forum on the Application, any information disclosed that may be
automatically made public, and such information will not be considered Personal Information
by us. You should exercise caution when disclosing any information (including Personal
Information) in such ways, as you do not know who will access or use such information and
for what purposes. Your Personal Information will not be combined with other information
and will not be used for other purposes, except as explained in this policy. Please note that we
are not subject to medical secrecy obligations.

Ensuring the accuracy and completeness of the Personal Information and any other
information that you provide in connection with your use of the Application is important.
Inaccurate or incomplete information will affect the functioning of the Application, as well as
the information you receive from us and our ability to contact you.

AUTOMATIC DATA COLLECTION

Lorem ipsum dolor sit amet, consectetur adipiscing elit. Ut elit tellus, luctus nec ullamcorper mattis, pulvinar dapibus leo.Site: We collect information about your use of the Site (IP address, type of computing or
mobile device you use, language of your operating system, the Internet browser you are using,
geo location and use of the Site) through the use of various technologies, such as cookies, web
beacons and navigational data collection (log files, server logs, clickstream). For more
information on our cookies policy, please see below.
The App may automatically collect certain information about you when you use the App, such
as the type of computing or mobile device you use, your device’s IP address and/or unique
device ID, your device’s operating system, the language of your operating system and the
Internet browser you are using. We may use third party service providers to collect such
information, in order to assist us with the following: pseudonymized installation tracking,
social media recommendations, anonymized crash tracking, anonymized behavior tracking and
testing (including in real time) and anonymized A/B testing. We collect such information in
order to facilitate use and ensure technical functioning of the App, dynamically generate, and
deliver targeted content, statistically monitor usage of the App, and improve the overall quality
of our users’ experiences.

Data collected automatically on the Site or App may be used, for example, to help diagnose
problems with our servers, to make WatchRx more useful, to customize WatchRx and
personalize its content for you.
The App might access a list of installed apps on your device. This is done only to ensure proper
quality of service, as some apps might interfere with the App functionality, such as blocking
notifications, and in such cases, we will notify you. Information about installed apps is not
transmitted and not shared with anyone.

COOKIES

A cookie is a small piece of text that is sent to a visitor’s browser. The browser provides this
piece of text to the device of the originating visitor when this visitor returns. We use cookies
to help personalize your experience. A “persistent” cookie may be used to help save your
settings and customizations. Also, if you log in to the Site, such a cookie will be used to
recognize you as a valid user so you will not need to log in each time you use the Site. Most
Web browsers automatically accept cookies but allow you to modify security settings so that
you can approve or reject cookies on a case-by-case basis or reject all cookies. You can
configure your web browser to remove cookies by following the directions provided in your
Internet browser’s “help” section.
You are free to delete any existing cookies at any time. If you delete or disable cookies from
our Site, some parts or functions of the Site may not work properly for you.

SHARING OF YOUR PERSONAL INFORMATIION WITH THIRD PARTIES AND SERVICE PROVIDERS

We will not publish your Personal Information without your explicit consent. However, we
might share your Personal Information, as is reasonably necessary, without your consent with:
(1) our contractors or consultants who are bound by an obligation of confidentiality, provided
that we will only share Personal Information to the extent necessary with such contractors or
consultants; and 2) affiliates of our company for the purposes of improving our marketing
strategies, for research purposes and for entering into commercial contracts in order to
provide our users with our services. We also require that such contractors and consultants
agree to protect the privacy of your Personal Information and agree not to use or disclose
Personal Information for any purpose other than providing us with products and services and
as required by law.
Additionally, you may choose to share your Personal Information with pharmacies with which
we partner and/or third-party coupon companies, in order that we may send you coupons
and/or provide you with reminders to get your prescription refilled. If you choose to share
your Personal Information in this manner, please note that such information may be disclosed
to the coupon companies and/or pharmacies and will be subject to their privacy practices.

We may share your Personal Information with third parties, such as research institutes,
healthcare systems or doctors, for research purposes and so that they can cross-check such
information with other information that they have about you, for research purposes and for
improvement of our services. We will first obtain your consent for the same. Please note that
we may share your deidentified data with such third parties without obtaining such consent.
From time to time, we may also ask whether you would like us to share your Personal
Information with another company that may want to send you information about their
products or services. If you consent to such transfer by us of your Personal Information to
another company, please note that the information provided will be subject to such company’s
privacy practices and shall not be within our control.
In addition, we may share your personal data with third parties, such as law enforcement
authorities, courts, and tribunals, to respond to law enforcement requests or other legal
requests or pursuant to a requirement imposed by law, order, judgment, or decree.
We may also share your Personal Information with legal advisors, consultants, or courts in
order to protect and defend our rights and property or those of Application users. We may
also transfer your Personal Information in the event of a merger, acquisition or sale of all or a
portion of our assets.

USE OF AGGREGATED DATA

We may analyze all information we receive and/or combine your Personal Information,
including Health Information and information regarding your use of the Application, with
information from other users to create aggregated data that may be disclosed to and utilized
by us, our affiliates and by third parties without restriction, on commercial terms that we can
determine in our sole discretion for purposes of content marketing, for research purposes, in
order to understand behavior patterns and in order to increase adherence to medication
regimens. We also use “Google Analytics” to collect information about the use of the
Application. Google Analytics collects information such as how often users visit the
Application, what pages they visit when they do so, and what other sites they used prior to
coming to the Application. Google Analytics collects only the IP address assigned to you on
the date you use the Application, as well as information regarding your operating system,
language, and information regarding your use of the Application, rather than your name or
other identifying information. We do not combine the information collected through the use
of Google Analytics with Personal Information.
We use the information we get from Google Analytics only to improve the Application.
Google’s ability to use and share information collected by Google Analytics about your use of
the Application is restricted by the Google Analytics Terms of Use located at
http://www.google.com/analytics/terms/us.html and the Google Privacy Policy located at
http://www.google.com/policies/privacy/.

DISABLING THE SERVICE, ACCESS, CORRECTIONS AND DELETION

At any time, you can stop the collection of your information by canceling the subscription and
uninstalling the App and refraining from using the Site. You may also request that your
Personal Information be deleted from our active databases. We cannot restore information
that we have deleted. You are responsible for backing up the data that you store on the
Application. We may retain any data in nonidentified form, subject to applicable law.

You may contact us as specified below under “How to Contact Us” to access information that
we keep about you or update or correct such information or ask for its deletion. We will retain
your information for as long as you continue to use our Site or App and for a reasonable period
of time afterwards.

You have the right to object to direct marketing.

LINKS TO OTHER WEBSITES OR APPS

Our Application may link to or refer to websites or mobile device applications that we do not
control. Any Personal Information you provide on the linked pages is provided directly to this
third party and is subject to this third party’s provider’s privacy policy. This Privacy Policy does
not apply to such other websites or applications, and we are not responsible for the privacy
practices or content of any website or application not controlled by us. If you have any
concerns, we urge you to review the terms of those other websites or applications for more
information about their applicable policies.

SECURITY

We take reasonable steps to protect Personal Information as you transmit it to us and to
protect such information from loss, misuse and unauthorized access, disclosure, alteration, or
destruction. However, you should keep in mind that no Internet transmission is ever
completely secure or errorfree.

If you use and/or access the Application on or from an Android device which you or someone
else rooted or on or from an iOS device which you or someone else jail broke, WatchRx shall
not be responsible for the security of your data, including your Personal Information, and you
shall bear all responsibility for any breach, illegal access, loss and/or corruption of such data.

CHILDREN

Our Application is intended for use by persons 18 years of age and older. Under no
circumstances should the Application be used by children under 18 years of age, and we will
not knowingly collect Personal Information from any person we know to be in this age group.
If you are using the Application for the benefit of a child, please do not provide information
relating to such child unless you have obtained the child’s parents’ or guardians’ consent,
including their consent to this Privacy Policy. If you discover that your child has been using
the Application without your consent, or that someone has been using the Application for or
on behalf of your child without your consent, please contact us using the information below
under “How to Contact Us,” and we will take reasonable steps to delete the child’s information
from our active databases.

INTERNATIONAL TRANSFERS

We store your Personal information on servers located in the United States. Additionally, we
may use subcontractors that are located in countries other than your own and send them or
provide them with access to information we receive. All our subcontractors will be subject to
nondisclosure and nonuse obligations. Nevertheless, some countries may have levels of
protection of personal and other information which are not as high as in your country of
residence or business.

We may transfer our databases containing your Personal Information if we sell our business
or part of it.

HOW TO CONTACT US

If you have any questions, comments, requests, or concerns related to this Privacy Policy or
the privacy practices for our Application, please contact us at:

ATTN: WatchRx Inc.10 Barker Road, Acton, MA 01720. Email: info@WatchRx.io

CHANGES TO PRIVACY POLICY

From time to time, we may need to change this Privacy Policy. You will be informed of such
change in advance, and you will always have the possibility to stop using the service as
explained above.
This Privacy Policy was last updated in February 2023.