GlycoSphere LLC Privacy Policy

1. Scope and Updates to This Privacy Policy

This Privacy Policy applies to personal information processed by us, including on our websites, GlycoSphere software, mobile applications, and other online or offline offerings (collectively, the "Services").

An Important Note. This Privacy Policy does not apply to personal information that we process on behalf of our customers through their use of our Services ("Customer Data"). Our customers' respective privacy policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts we have in place with our customers, not this Privacy Policy. Any questions or requests relating to Customer Data should be directed to our customer.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes, we will notify you as required by applicable law. You will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

2. Personal Information We Collect

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect personal information you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations.

A. Personal Information You Provide to Us Directly

• Account Creation. Information you provide when you create an account, such as name, email address, username, and profile picture.
• Healthcare Professionals. If you are a healthcare professional, professional contact information, credential and institutional affiliations, information about our programs and activities you participate in, our interactions with you, published papers, your photograph, information about your use or prescribing of our products and services, and information contained in agreements with us.
• Regulatory Information. Information required to comply with regulatory requirements, including information relating to any adverse events you experienced when using our products.
• Health Data. We collect your health data, which may include:
  • Information about your health-related conditions, symptoms, status, diagnoses, testing, or treatments.
  • Data collected through your use of our Services, including pages visited, actions taken, files downloaded, data transferred directly from your medical devices, and searches performed. If you are enrolled in GlycoSphere's Remote Patient Monitoring (RPM) program, we also receive health readings (including blood pressure and blood glucose values) that are automatically transmitted from your FDA-cleared monitoring device via Tenovi's cellular network directly to GlycoSphere's platform, without requiring any action on your part beyond taking the measurement. These automatic transmissions are a core function of the RPM service, are required to satisfy Medicare billing requirements for CPT code 99454, and are governed by your signed RPM Informed Consent and our HIPAA Privacy Policies.
  • Information that could identify your propensity to seek health care services in the future.
  • Inferences derived from the above data.
• Purchases. Personal information and details associated with your purchases, including payment information. Payments made via our Services are processed by third-party payment processors. We do not directly collect or store payment card information entered through our Services, but we may receive associated information such as your billing details.
• Your Communications with Us. Email address, phone number, or mailing address when you request information about our Services, register for our newsletter or loyalty program, request customer or technical support, or otherwise communicate with us.
• Surveys. Information you provide if you participate in surveys we contact you about.
• Interactive Features. Information you submit through interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Information shared via public sharing features will be considered public unless otherwise required by applicable law.
• Sweepstakes or Contests. Information you provide for any sweepstakes or contests we offer. In some jurisdictions, we are required to publicly share personal information of winners.
• Conferences, Trade Shows, and Other Events. Information collected from individuals when we attend or host events.
• Business Development and Strategic Partnerships. Information from individuals and third parties to assess and pursue potential business opportunities.
• Job Applications. Information you provide if you respond to job postings on our Services (application, CV, cover letter, and other materials).

B. Personal Information Collected Automatically

• Automatic Collection. When you use our Services we may collect your Internet Protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider, as well as information about pages you visit, links you click, content you interact with, and the frequency and duration of your activities.
• Crash Reports. If you provide crash reports, we may collect detailed diagnostic information about your device and the activities that led to the crash.
• Location Information. We may collect precise location information in connection with your use of our Services.
• Cookies and Other Technologies. We and third parties may use cookies, pixel tags, web beacons, and similar technologies ("Technologies") to automatically collect information through your use of our Services. These fall into the following categories: operationally necessary, performance-related, functionality-related, advertising/targeting-related, and analytics. Analytics partners may include Google Analytics and LinkedIn Analytics.
• Social Media Platforms. Our Services may contain social media buttons (X, Facebook, LinkedIn, Instagram, YouTube). Your interactions with these platforms are governed by the privacy policy of the company providing them.

C. Personal Information Collected from Other Sources

We may obtain personal information about you from third-party services and organizations. If you are enrolled in GlycoSphere's RPM program, we receive your device health readings from Tenovi, Inc., our FDA-cleared device data network partner. Tenovi transmits your readings directly from your monitoring device to GlycoSphere via a secure cellular connection. Tenovi acts as a Business Associate under HIPAA and its handling of your data is governed by a Business Associate Agreement with GlycoSphere.

If you are a healthcare professional, we may also collect hospital affiliation, license information, areas of interest, contact information, and other due diligence information from various sources. Our Services may also offer referral tools that allow you to provide contact information about friends or colleagues; please only share contact information of people with whom you have a relationship.

3. How We Use Your Personal Information

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services.

A. Provide Our Services

• Manage your information and account.
• Personalize your experience.
• Provide access to certain areas, functionalities, and features of our Services.
• Answer requests for customer or technical support.
• Communicate with you about your account, activities on our Services, and policy changes.
• Process your financial information and payment methods for products or Services purchased.
• Process applications if you apply for a job posted on our Services.
• Allow you to register for events.

B. Administrative Purposes

• Pursue legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention.
• Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity.
• Measure interest and engagement in our Services.
• Short-term, transient use, such as contextual customization of ads.
• Improve, upgrade, or enhance our Services.
• Develop new products and services.
• Ensure internal quality control and safety.
• Authenticate and verify individual identities, including requests to exercise your rights under this Privacy Policy.
• Debug to identify and repair errors with our Services.
• Audit interactions, transactions, and other compliance activities.
• Share personal information with third parties as needed to provide the Services.
• Enforce our agreements and policies.
• Carry out activities required to comply with legal obligations.

C. Marketing and Advertising

We may use personal information to tailor and provide you with content and advertisements, including email campaigns, text messages, custom audiences advertising, and interest-based or personalized advertising (including cross-device tracking). To opt out, contact us as set forth in "Contact Us" below.

D. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

E. Other Purposes

De-identified and Aggregated Information. We may use personal information to create de-identified and/or aggregated information, such as analyses about the total number of users in a location or how users interact with our Services.

4. How We Disclose Your Personal Information

A. Disclosures to Provide Our Services

• Service Providers. Third-party vendors that provide IT support, hosting, payment processing, customer service, and related services.
• Business Partners. Partners that help us provide products or services, including those with whom we jointly offer products or services.
• Affiliates. Our company affiliates for administrative purposes, IT management, or to provide services to you.
• Advertising Partners. Third-party advertising partners that may set Technologies to collect information about your activities and your device for personalized advertising.
• APIs/SDKs. Third-party application program interfaces and software development kits used as part of our Services.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we believe in good faith doing so is required or appropriate to: comply with law enforcement requests and legal process such as court orders or subpoenas; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with the investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction.

5. Your Privacy Choices and Rights

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

• Email Communications. You can use the "unsubscribe" link in any unwanted promotional email. You will continue to receive transaction-related emails and certain non-promotional communications (e.g., service or policy updates).
• Text Messages. Follow the instructions in the text message you received or contact us to opt out of future text messages.
• Push Notifications. You may opt out of push notifications by changing settings on your mobile device.
• Precise Geolocation Information. With your consent, we may collect precise location information via our mobile application. You may opt out by changing the settings on your mobile device.
• Phone Calls. Follow any opt-out instructions provided on the call or contact us to opt out.
• "Do Not Track." We do not respond to DNT signals, but we honor the Global Privacy Control where required by applicable law.

Cookies and Personalized Advertising. You can control certain cookies through our cookie banner, browser and device controls, and ad industry opt-outs (Network Advertising Initiative, Digital Advertising Alliance, European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada). You may also broadcast the Global Privacy Control (GPC) signal where supported.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Access and Portability — confirm whether we are processing your personal information, obtain a copy of it, and receive an electronic copy in a structured, commonly used, machine-readable format.
• Request Correction of inaccurate or incomplete personal information.
• Request Deletion of your personal information.
• Request Restriction of or Object to processing based on legitimate interest for direct marketing, processing of sensitive personal information for non-essential purposes, or solely automated decision making and profiling.
• Opt out of Sale, Sharing for Cross-Contextual Advertising, or Targeted Advertising. Although we do not "sell" personal information as that term is typically understood, we may share information with analytics and advertising networks; you may opt out as described above.
• Withdraw your Consent for future processing.

To exercise any of these rights, please contact us as set forth in "Contact Us" below.

6. Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues. If we learn of a security breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by email.

7. International Data Transfers

All information processed by us may be transferred, processed, and stored anywhere in the world, including the United States or other countries which may have data protection laws different from the laws where you live. We endeavor to safeguard your information consistent with applicable laws. For more information about the safeguards we use for international transfers, please contact us as set forth below.

8. Retention of Personal Information

We store personal information as long as you use our Services, or as necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, or based on other criteria including the sensitivity and volume of such data.

9. Notice at Collection and Supplemental Notice for California Residents and Residents of Certain U.S. States

This Notice is for residents of U.S. states that have adopted comprehensive privacy legislation, including California, Connecticut, Colorado, Nevada, Oregon, Virginia, Texas, and Utah ("Applicable State Laws"). The categories of personal information we collect and disclose include identifiers, California Customer Records categories (name, signature, address, financial and medical information), protected classification characteristics, commercial information, biometric and physiological information, internet/network activity, geolocation, sensory data, professional or employment-related information, non-public education information, inferences, and sensitive personal information. These categories may be disclosed to service providers, business partners, affiliates, advertising networks, internet service providers, data analytics providers, government entities, operating systems and platforms, and social networks for business purposes; certain online identifiers and inferences may be shared with advertising networks and data analytics providers for targeted advertising.

"Sales" of Personal Information. For purposes of Applicable State Laws, we do not "sell" personal information, nor do we have actual knowledge of any "sale" of personal information of minors under 18. To the extent any sharing is considered a "sale" or "sharing" for targeted advertising, you may limit it by exercising your privacy choices and rights described above, contacting us, or managing your cookie preferences via our banner, browser controls, ad industry opt-outs, and the Global Privacy Control.

Categories of data shared for cross-contextual and targeted advertising may include online identifiers (IP address, marketing IDs, device identifiers), commercial information, internet or other electronic network activity, and inferences about individual preferences and behaviors.

Sources of Personal Information. Directly from you, automatically from your use of our sites and services (including through cookies), from third parties (e.g., providers of government contractor contact information), and through referrals from others.

Purposes for Use. To provide our Services, for administrative purposes, to process requests and transactions, to advertise and market our Services, with your consent, and to comply with law and enforce our rights and the rights of others.

Processing Sensitive Information. We do not process sensitive personal information for purposes such as profiling or inferring characteristics about you.

Additional Rights. Subject to Applicable Law, you may have the right to know and access the personal information we have collected, delete personal information, opt out or restrict processing for specified purposes such as targeted advertising, and correct inaccurate personal information. Non-Discrimination: we will not discriminate against you for exercising any of these rights. Authorized Agent: you may use an authorized agent to exercise privacy rights, subject to verification requirements. Verification: we will take reasonable steps to verify your identity prior to responding to your request and will respond within 45 days (or as otherwise required by law). Appeal: you may appeal our decision using the same method used to submit your original request.

California Shine the Light. California residents may request once per year, free of charge, a list of third parties to whom we disclosed personal information for direct marketing purposes in the prior calendar year, and the categories of information disclosed.

Right for Minors. Where required by law, California residents under 18 may request removal of their posted content from publicly-viewable portions of the Services.

10. Children's Information

The Services are not directed to children under 18, and we do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has uploaded personal information to our Services without your consent, please contact us. If we become aware that a child has provided personal information in violation of applicable law, we will delete it unless we have a legal obligation to keep it.

11. Other Provisions

Third-Party Websites/Applications. Our Services may contain links to other websites and applications not controlled by us. We encourage users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

12. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights, please contact us at:

GlycoSphere LLC
Attn: GlycoSphere Privacy and Security Officer
5068 Fields Pond Close
Marietta, GA 30068
Email: fmuoka2001@gmail.com