Privacy Policy

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 Curio App platform located on the Apple App Store and Google Play (the “Application”), 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 APPLICATION, 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 APPLICATION IMMEDIATELY.

Data Collection

Personal Information You Provide to Us

We collect the personal information that you choose to provide to us through the Application, including the personal information that you choose to provide to us through the “Contact Us” section of the Application or when you participate in interactive features of the Application. 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.

Usage Data We Automatically Collect

We also automatically collect usage data when you use the Application. “Usage data” is information about your activity on the Application 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. We collect usage data through the use of “cookies” and other data collection tools, including technologies from third-party partners such as Google and Meta. For more information about these data collection tools, please see the section of this Privacy Policy titled “Cookies and Other Data Collection Tools.”

If we combine any usage data with personal information, we will treat the combined data as personal information in accordance with this Privacy Policy. The use of information received from Health Connect will adhere to the Health Connect Permissions policy, including the Limited use requirements.

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 Application, including your registration and account;

• To deliver the services that you have requested;

• To process transactions and fulfil orders;

• To better understand how you interact with the Application;

• To tailor the content and information that we provide to you through the Application;

• 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; and

• For research and analytics purposes.

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;

• 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.

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

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.

Third-Party Websites

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

The Application may also include functionality that allows certain kinds of interactions between the Application and your account on a third-party web site 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 site or application may send personal information about you to the Application. If so, we will then treat it as personal information under this Privacy Policy.

Children’s Privacy

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

Payment Processing

We do not store your payment information when you provide it through the Application. Payment processing is offered through the third-party payment processor, Square. Your payment will be processed directly by Square, who collect, use and process your information, including payment information in accordance with their privacy policies.

You can access their privacy policy via the following link:

https://squareup.com/us/en/legal/general/privacy

Square will share with us certain information related to the completed transaction in order for us to fulfill the respective transaction ordered.

Cookies and Other Data Collection Tools

What is a cookie?

A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website again, the cookie allows that website or online service to recognize your browser. Cookies may store unique identifiers, user preferences and other data.

Why do we use them?

Cookies help us improve the Application by providing us with data about which parts of the Application are most popular, enabling us to analyze technical and navigational data about the Application and helping us to detect and prevent fraud. We also use cookies and other data collection tools to help improve your experience with the Store.

What is a pixel?

Pixels (also known as web beacons) is code embedded in a website, video, email, or advertisement that sends information about your use to a server. There are various types of pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a website, video, email, or advertisement that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser. Pixels are used in combination with cookies to track activity by a particular browser on a particular device. We may incorporate pixels from separate entities that allow us to track our communications, bring you advertising both on and off the Application, and provide you with additional functionality, such as the ability to connect our Application with your social media account.

How do I control cookies?

Web browsers allow some control of most cookies through the browser settings. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although you are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some parts of the Store. To find out more about cookies, including how to manage and delete them, visit www.allaboutcookies.org.

Do Not Track

The Application does not support Do Not Track (DNT). DNT is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your online activities collected. For more information about DNT, please visit www.donottrack.us.

Application Usage Analytics

The only cookies and pixels that we currently use are Google Analytics and Meta Pixel (see below). We operate an ‘implied consent’ policy for this which means that we assume you are comfortable with this usage. If you are not comfortable with this usage, then you should either not use this Application, delete the cookies having visited the Application, or browse the Application using your browser’s anonymous usage setting (called “Incognito” in Chrome, “InPrivate” for Internet Explorer, “Private Browsing” in Firefox and Safari, etc.)

Google Analytics:

We use Google Analytics to collect information about visitor behavior on our Application. Google Analytics stores information about what pages you visit, how long you are on the Application, how you got here and what you click on. This Analytics data is collected via a JavaScript tag in the pages of our Application and is not tied to personally identifiable information. We therefore do not collect or store your personal information (e.g. your name or address) so this information cannot be used to identify who you are.

You can find out more about Google’s position on privacy as regards its analytics service at

http://www.google.com/intl/en_uk/analytics/privacyoverview.html (http://www.google.com/policies/privacy/).

If you would like to opt-out from the use of your information by Google analytics, you may use Google’s analytics opt-out browser add-on designed for this purpose: https://tools.google.com/dlpage/gaoptout/.

Meta Pixel

We also use Meta Pixel to track non-personal information relating to visitors to the Application who navigated to the Application from an ad available on Facebook. This tool allows us to follow your actions after you are redirected to the Application by clicking on a Facebook ad. The collected data remains anonymous and is not tied to personally identifiable information.

Meta is able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with Meta privacy policies, which you can find at http://www.Facebook.com/Privacy/Explanation.

If you would like opt-out from the use of your information by Meta Pixel, please click here:

http://www.facebook.com/ads/website_custom_audiences/.

Additional Information for EU Visitors

With respect to “personal data” as defined by Regulation (EU) 2016/679 that you may provide to us through the Application, we serve as the “controller”.

We provide the Application from servers located in the United States. If you are accessing the Application from the European Union, we will only transfer your personal data to the United States through the use of appropriate safeguards. We process your personal data to pursue our legitimate business interest to operate the Application and as described in the section of this Privacy Policy titled “Using Your Personal Data”. To learn more about with whom we may share your personal data, please refer to the section of this Privacy Policy titled “Sharing Your Personal Information”.

We retain your personal data for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulations. Copies of information that you have updated, modified or deleted will remain in our systems if applicable law requires us to retain it and/or consistent with our data retention policy.

You have the right to access your personal data, rectify inaccuracies in it, request the erasure of it and request that we restrict the processing of it in certain circumstances. If you wish to access your personal data, please contact us at hello@curiodigitaltx.com, and allow reasonable time for your personal data to be collected.

You also have the right to lodge a complaint with a supervisory authority.

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 Application and they will become effective immediately upon being posted to the Application. Your continued use of the Application 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 Application, 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).

Contact

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