PRIVACY STATEMENT

EFFECTIVE DATE: May 20th, 2021

Caryfy, Inc. (“Caryfy”, “we”, “us”, or “our”) values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our websites, www.caryfy.ai , and the landing pages used to access the Caryfy platform (the “Sites”), our mobile applications – Caryfy and Caryfy Pro (the “Apps”), and the services available through our Sites and Apps (collectively, the “Services”). This Policy does not, however, apply to information collected and managed through the use of the Caryfy platform, which our customers, including our personal support service provider customers, and their employees, including caregivers, use to manage information collected in administering the relationships with their clients.

By visiting our Sites or using any of our Services, you agree that your information will be handled as described in this Policy. Your use of our Sites or Services, and any dispute over privacy, is subject to this Policy and our Terms of Use including its applicable limitations on damages and the resolution of disputes. Our Terms of Use are incorporated by reference into this Policy.

INFORMATION WE COLLECT

We collect information about you directly from you; automatically through your use of our Sites, Apps, or Services; and from third parties. We may combine information automatically collected with other information that we have collected about you.

Information We Collect Directly from You. Any Site visitor may browse our Sites without directly providing information to us. However, certain Services may require visitors to our Sites or App users to provide information, such as registering for an account. The information that we collect from you varies based on your particular interaction with our Services. For example, when you sign up for an account on one of our Sites or our App, we will collect your contact information, including your name, email address, and address; password; agency name, size, and website; phone number; and profession. If you make a payment through our Services, we will collect your name, email address, billing address, phone number and other payment information; however, please note that we use third parties to process your credit and debit card information.

If you use our Apps, we will collect the information that you provide, including on behalf of our customers, which may include biometrics, information about your contacts, information included in files stored on your mobile device, such as calendar entries, text, and email content and history. In addition, our Apps will collect any health, medical or therapy information (including health claims and other information used to measure health or wellness) that users choose to provide.

Information We Automatically Collect About You. When you use our Services, we may collect information such as the following through cookies and other technologies: domain name; browser type; operating system type, model, and version; device ID and configuration; pages, screens, or actions you view or take; links you click; Internet Protocol (IP) address; when and the length of time you visit or use our Services; and the referring uniform resource locator (URL), or the webpage that led you to our Sites. When you use our App, we may also collect your geolocation information. You can change your location tracking settings on iOS devices by going to your privacy settings and on Android devices by going to your app settings. If you choose not to share your location information with us you may lose some functionality. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

Customer Information. Personal Support Service Providers and agents may submit, store, review and manage patient information, records, billing information and other protected health information using our platform. Their treatment of your information is subject to the terms of your agreement with them, not this privacy policy. If you would like more information about how your home care providers, adult day care and personal care homes will use and disclose your health information, you should ask for a copy of their Notice of Privacy Practices.

USING YOUR INFORMATION

We use the information that we gather about you, including personal information, for the following purposes:

Providing Our Services. To provide our Services to you, to communicate with you about your use of our Services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.

Employment and Referrals. With respect to the information submitted, collected and disclosed relating to the Sites or connected third-party providers, in order to facilitate job applications, postings, hiring and placement of qualified candidates for open senior care positions and other positions posted by agencies and customers with whom we work.

Communicating with You. To communicate with you about your use of our Services; to respond to your inquiries; to provide you with news and newsletters, special offers, and promotions; to contact you about products or information we think may interest you; and for other marketing, advertising, and promotional purposes, to the extent permitted by law. We also use the information that we learn about you to assist us in advertising our Services on third-party websites and to assist us in evaluating the success of our advertising campaigns on various platforms. We may communicate with you via email or push notification. To opt out of push notifications, you can manage your preferences either through your App setting or device settings, depending on your device type. We do not use protected health information collected and managed by our customers using the Caryfy App for marketing purposes described in this paragraph; as noted above, this information is subject to the privacy policy and Notice of Privacy Practices of each respective customer.

Tailoring Content. To tailor the content and information that we may send or display to you; to offer personalized help and instructions; and to otherwise personalize your experiences while using our Sites or Services.

Customer Loyalty Program. To administer our customer loyalty program. Analyzing Use of Our Services. To better understand how users access and use our Sites and Services, both on an aggregated and individualized basis; to respond to user desires and preferences; to monitor the success of marketing and advertising campaigns; and for other testing, research, and analytical purposes.

Complying with the Law. To comply with applicable legal obligations.

THIRD-PARTY AD NETWORKS

In order to display more relevant advertising, to manage our advertising on third-party sites, mobile apps and online services and to measure and improve our ads and marketing efforts, we may work with third-party ad companies, including ad exchanges, channel partners, measurement services and ad networks, such as:

Google/DoubleClick (more information: privacy policy; choices: ads help page);

Google Analytics Advertising, including its Remarketing, Demographics and Interests Reporting, Campaign Manager Integration, and Display & Video 360 Integration features

AdRoll (more information: privacy policy); and

Facebook Ads and Boosted Posts (more information: About Boosting Posts).

THIRD PARTY PROVIDERS

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy and security policies in respect to the information we are required to provide to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

We do not share protected health information with third parties for advertising purposes and we do not use protected health information to target advertising online.

We may disclose the information that we collect about you, including personal information, in the following ways:

Business Transfers. We may transfer your information to another entity if we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding.

In Response to Legal Process. We may disclose your information in order to comply with the law, a judicial proceeding, subpoena, court order, or other legal process.

To Protect Us and Others. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved.

Aggregate and De-Identified Information. We may also share aggregate or de-identified information about users with third parties for marketing, advertising, research, or other purposes.

SECURITY OF MY PERSONAL INFORMATION

We have implemented safeguards to protect the information we collect, including when applicable safeguards to comply with HIPAA. Please be aware that despite these measures, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

DATA STORAGE

Your data is stored through data storage, databases and the general application on secured cloud platforms offered by Microsoft Azure/ Google Cloud Platform/ Amazon Web services.

YOUR CHOICES

Users of our Sites may access, update, or delete the information you have provided to us by logging into your account and modifying your information or by contacting us at support@caryfy.ai and detailing which information you would like to access, update, or delete and how you would like to modify it. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Sites for a period of time. If you use our Apps, your ability to access, update, or delete the information you have provided is governed by the terms of your agreement with our home care agency customer.

We may send periodic promotional or informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.

DATA RETENTION

We retain the information that we collect through our Apps on behalf of our customers in accordance with our agreements with our customers. We will retain your personal information that we collect through the Sites and Services other than the App for the period necessary to fulfil the different purposes for which the data was collected, and to fulfil other commercial requirements as long as permitted by applicable law, which may include compliance with our records retention policy.

AGE OF CONSENT

By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.

SPECIAL INFORMATION FOR CALIFORNIA CONSUMERS

California residents may request a list of certain third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us at support@caryfy.ai. Please allow up to thirty (30) days for a response.

CONTACT US

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at support@caryfy.ai.

CHANGES TO THIS POLICY

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Sites. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Sites.