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Effective Date: January 01, 2025

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Curio Digital Therapeutics Inc. (“our”, “us” or “we”) is committed to protecting your privacy.

 

This privacy policy (this “Privacy Policy”) describes the types of personal information that we collect from you through our platform (the “App”), how we use your personal information and the circumstances under which we may disclose it to others.

 

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. BY USING THE APP, YOU CONSENT TO OUR TERMS OF USE AND TO THE PRIVACY PRACTICES SET FORTH IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THESE PRIVACY PRACTICES, YOU MUST CEASE USING THE APP IMMEDIATELY.

 

Data Collection

 

Personal Information You Provide to Us

 

We collect the personal information that you choose to provide to us through the App, including the personal information that you choose to provide to us through the “Contact Us” section of the App or when you participate in interactive features of the App. This personal information may include your name, e-mail address, phone number and other data, such as age and gender, that by itself, or in combination with other data, reveals your identity. We collect the personal information and protected health information that you choose to provide to us through the App, including but not limited to:

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  • Name, e-mail address, phone number

  • Date of birth, gender, and other demographic information

  • Medical history and conditions

  • Treatment information Insurance information (if applicable)

  • Any other health-related information you choose to share through the App.

 

Usage Data We Automatically Collect

 

We also automatically collect usage data when you use the App. “Usage data” is information about your activity on the App that, by itself, does not identify you as an individual. For example, the operating system that you are using, the date and time stamp of your visit, the referring URL and your internet service provider. If we combine any usage data with personal information, we will treat the combined data as personal information in accordance with this Privacy Policy.

 

Using Your Personal Information

 

We may use your personal information as described at the point of collection or as follows:

 

  • To operate and improve the App, including your registration and account.

  • To deliver the services that you have requested.

  • To process transactions and fulfill orders.

  • To better understand how you interact with the App.

  • To tailor the content and information that we provide to you through the App.

  • To contact you about events, publications, and services that we provide.

  • To provide you with marketing materials or relevant advertising, promotions, and recommendations.

  • For security purposes.

  • To enforce and protect our rights and the rights of others.

  • For research and analytics purposes.

  • To provide and coordinate your healthcare treatment.

  • For healthcare operations purposes, such as quality assessment and improvement activities.

  • To communicate with other healthcare providers involved in your care with your consent.

  • For payment purposes, including billing and collections (if applicable).

  • To comply with legal and regulatory requirements.

 

Sharing Your Personal Information

 

We may share your personal information as described at the point of collection or as follows:

 

  • With third-party service providers whom we engage to provide services on our behalf under a Business Associate Agreement (BAA) ensuring HIPAA compliance.

  • In connection with a merger, sale, acquisition or other change of ownership or control by or of us or an affiliated entity.

  • In response to a subpoena, regulation, binding order of a data protection agency, legal process.

  • Governmental request or other legal or regulatory process.

  • To enforce and protect our rights and the rights of others; and

  • To support external auditing, compliance, and corporate governance functions.

  • With healthcare providers directly involved in your care

  • With our business associates who perform functions on our behalf, under strict confidentiality agreements

  • As required by law, such as reporting to public health authorities or in response to a court order

  • With your written authorization for any other purpose not described in this Privacy Policy

 

Other than as described above, we do not share your personal information with third parties, including with third parties for their marketing purposes.

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Protecting Your Personal Information

 

We use commercially reasonable security measures, including technical, physical, and administrative practices and procedures, to protect your personal information against unauthorized access, loss, misuse, and alteration. Nevertheless, no system is perfect. Therefore, we cannot guarantee the absolute security of your personal information, and we make no representations or warranties with respect to the sufficiency of those security measures, nor will we be responsible for any direct or indirect damages that you may incur as a result of a security breach or technical malfunction.

 

We implement administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of your electronic PHI. We conduct regular risk assessments and employee training to ensure ongoing HIPAA compliance.

 

Breach Notification

 

In the event of a breach involving your unsecured PHI, we will notify you in compliance with HIPAA’s Breach Notification Rule. You will be informed of:

 

  • The nature of the breach,

  • The types of PHI involved,

  • The steps you should take to protect yourself,

  • The measures we are taking to investigate the breach, mitigate harm, and prevent future breaches.

 

We will notify you by mail or email (depending on your preferences) without unreasonable delay, and in no case later than 60 days following the discovery of the breach. If necessary, we will also provide notification to the Department of Health and Human Services (HHS) and, in certain circumstances, to the media.

 

Third-Party Web Apps

 

We may include links on the App to third-party web Apps that we do not operate or control (“Third-Party Web Apps”). We are not responsible for the collection, use or disclosure of personal information collected through the Third-Party Web Apps, and we expressly disclaim any and all liability related to such collection, use and disclosure. Therefore, before interacting with the Third-Party Web Apps, you should consult the privacy policies of those web Apps to learn more about their privacy practices.

 

The App may also include functionality that allows certain kinds of interactions between the App and your account on a third-party web App or application, such as Facebook or Google. The use of this functionality may involve the third-party operator providing certain information, including personal information, to us. If you choose to use any such functionality, the third-party App or application may send personal information about you to the App. If so, we will then treat it as personal information under this Privacy Policy.

 

Your Rights Regarding Your Protected Health Information 

 

Under HIPAA, you have certain rights regarding your PHI, including:

 

  • The right to access and receive copies of your PHI;

  • The right to request amendments to your PHI;

  • The right to receive an accounting of certain disclosures of your PHI;

  • The right to request restrictions on certain uses and disclosures of your PHI;

  • The right to request confidential communications; and

  • The right to receive notice of a breach of unsecured PHI.

 

To exercise these rights, please contact our Privacy Officer at contact@curiodigitaltx.com.

 

Children’s Privacy

 

We do not knowingly collect or maintain personal information from anyone under the age of thirteen, and no parts of the App are directed towards or designed to attract anyone under that age.

 

App Usage Analytics

 

Curio tracks usage and engagement data on the Mamalift/Mamalift Plus application. We are tracking usage of all trackers and additional metrics such as:

 

  • Time, dates, and information input into the tracker.

  • Time and dates of app opening and closing.

  • Time, date, and information entered into the Daily Learning section of the app.

  • Time, date, and information entered into assessments presented in the app.

  • Time, date, and information entered into journals.

  • Time, date, and information shared with a study coordinator via asynchronous chat messenger.

  • Device name, device type, operating system version.

  • Time zone related to app usage. 

 

If you are not comfortable with this usage, then you should not use this App.

 

Retention of Protected Health Information 

 

We will retain your PHI for as long as necessary to provide you with healthcare services and to comply with our legal obligations. When PHI is no longer needed, it will be securely destroyed or de-identified in accordance with HIPAA’s Security Rule and our internal retention policies.

 

Modifications to this Privacy Policy

 

We reserve the right, in our sole discretion, to modify this Privacy Policy at any time without notice to you. We will post all modifications to this Privacy Policy on the App and they will become effective immediately upon being posted to the App. Your continued use of the App following the posting of modifications to this Privacy Policy constitutes your acceptance of those modifications. Therefore, you should check the Effective Date of this Privacy Policy each time that you visit the App, review the “Notification of Material Modifications” section of this Privacy Policy and review any modifications made since the last time that you visited it. Notwithstanding the foregoing, to the extent required by law, we will seek your consent to any material changes to this Privacy Policy.

 

Notification of Material Modifications

 

This section identifies material modifications to this Privacy Policy since the Effective Date. (None at present).

 

Complaints 

 

If you believe your privacy rights have been violated, you may file a complaint with our Privacy Officer or with the Secretary of the U.S. Department of Health and Human Services. We will not retaliate against you for filing a complaint.

 

Contact

 

We welcome questions and comments about this Privacy Policy. Please send your questions and comments to us at contact@curiodigitaltx.com or by physical mail to 100 Overlook Dr 2nd Floor Princeton, NJ 08540.

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