PRIVACY POLICY

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We at Reframe Health, Inc. (“we,” “us,” “Reframe”) value your privacy and are committed to keeping your personal data confidential and secure. We use certain data solely in the context of providing a convenient platform (the “Platform”) to facilitate a comprehensive assessment of factors impacting your fertility health and to provide you with hands-on coaching, progress tracking, and ongoing support. We also enable you to share data about your fertility health with third parties that you identify, such as your partner or your healthcare provider. The Platform and all relevant content and functionality associated with the Platform are collectively referred to as the “Services.”

Please read this Privacy Policy to learn how Reframe treats personal data (“Personal Data”) that we collect from you. For clarity, you are self-reporting all of your Personal Data, so it is not subject to or covered by the Health Insurance Portability and Accountability Act (“HIPAA”). 

Our Services may contain links to other sites that are not operated by Reframe. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy(ies) of every site you visit. Reframe has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services. This Privacy Policy does not cover the practices of third-party companies that we don’t own or control or people we don’t manage.

Remember that your use of Reframe's Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Use.

By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent to the collection, use and disclosure of your Personal Data as described in this Privacy Policy. If you do not agree, you must immediately cease using the Services. 

Please note that we occasionally update this Privacy Policy and it is your responsibility to stay up to date with any amended versions. If we make any revisions to this Privacy Policy, we will notify you by posting a banner on the Platform. Any changes to this Privacy Policy will be effective immediately upon providing notice via the Platform and will apply to all Personal Data we maintain, use, and disclose. If you continue to use the Platform following such notice, you are agreeing to those changes. 

For additional information related to how we use or disclose your Personal Data, please contact us at hello@frameyourfuture.com.  

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Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect or have collected over the past twelve (12) months and with whom we share it:

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Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

When you provide such information directly to us.

• When you create an account or use our interactive tools and Services.
• When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
• When you send us an email or otherwise contact us.  

When you use the Services and such information is collected automatically.

• Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).
• If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
• If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

Third Parties

Vendors

• We use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support, including: Google, Jotform, and Calendly.

Advertising Partners

• We receive information about you from vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications, including: Google Search.

Social Networks 

• If you provide your social network account credentials to us or otherwise sign into the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

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How We Use Your Personal Data 

Reframe processes your Personal Data for the following legitimate business purposes: 

Providing, Customizing and Improving the Services

• Creating, managing, and communicating with you about your account or your +1 (e.g., partner, spouse, egg donor, sperm donor, surrogate).
• Providing you with the Platform, Services or information you request.
• Fulfilling our obligations to you under the Terms of Use.
• Providing support and assistance for the Services.
• Improving the Services, including testing, research, internal analytics and product development.
• Personalizing the Services, website content and communications based on your preferences.
• Keeping the Platform safe and secure. 
• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process.
• Protecting the rights, property or safety of you, Reframe or another party.
• Enforcing and ensuring your compliance with the Terms of Use or the terms of any other applicable services agreements we have with you.
• Responding to claims that any posting or other content violates third-party rights.

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Marketing 

• Marketing and selling the Services.
• Sending emails and other communications according to your preferences or that display content that we think will interest you.

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We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice and, as required, gaining your consent.

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With Whom We Share Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:

• Hosting, technology and communication providers.
• Security and fraud prevention providers.
• Support and customer service vendors.
• Communications providers.
• Electronic health record providers.
• Care team members, which may include coaches, clinicians, care coordinators, and other staff.

Analytics Partners. These parties provide analytics on web traffic or usage of the Services to track how users interact with, found, or were referred to the Services.

Business Partners. These parties partner with us in offering various services. 

Parties Upon Your Direction or Consent. With your consent and at your direction, we may share your Personal Data with third parties that you identify including: 

• Healthcare providers;
• Your health insurance carrier; 
• Your employer; 
• Other users of Reframe; 
• People you refer to Reframe; and/or
• Social media services.

Please Note: The Services allow you to invite your +1 or your friends to sign up for the Services by adding their email to the questionnaire or sharing a referral code or link. If you choose to share their email with the Services, we will receive and store those contacts' information and use it to send invitations on your behalf when you choose to do so. Your invitation and referral email will include your name.

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Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

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Data De-Identification and Aggregation

We may create aggregated or de-identified data from the Personal Data we collect, including by removing information that makes the data personally identifiable. We may use such aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.  

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Marketing or Advertisement Materials

In accordance with this Privacy Policy, Reframe may use your Personal Data to contact you with newsletters, marketing, or promotion materials and other information that may be of interest to you. You may opt out of receiving any marketing or advertisement materials from Reframe at any time by following the unsubscribe link within the applicable message or by contacting us at hello@frameyourfuture.com. 

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Communications Opt-Out  

We may send communications, including emails, to you regarding your User Account, the Services or the Platform. You can choose to filter any emails from Reframe using your email settings, but many of our communications to you are time-sensitive and may affect your ability to access or use the Services and Platform. We do not provide an option for you to opt out of these communications within your User Account or Reframe. You may opt out of transactional email communications by clicking “unsubscribe” at the bottom of an email from Reframe.

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User Rights

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As a user of the Platform, you may have certain rights relating to your Personal Data. These rights are subject to local data protection and privacy laws and may include the right to:

• Access Personal Data held by Reframe; 
• Erase/delete your Personal Data, to the extent permitted by applicable data protection and privacy laws and to the extent technologically feasible; 
• Receive communications related to the processing of your Personal Data; 
• Restrict the processing of your Personal Data to the extent permitted by law; 
• Object to the further processing of your Personal Data, including the right to object to marketing; 
• Request that your Personal Data be transferred to a third party, if possible; 
• Receive your Personal Data in a structured, commonly used, and machine-readable format; and/or
• Rectify inaccurate personal information and, taking into account the purpose of processing the Personal Data, ensure it is complete. 

Where the processing of your Personal Data by Reframe is based on consent, you have the right to withdraw that consent at any time. If you would like to withdraw your consent or exercise any of the above rights, please contact us at hello@frameyourfuture.com. 

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Tracking Tools and Opt-Out

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The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). 

Some web browsers may transmit do not track (“DNT”) signals to websites with which the user communicates. To date, there is no industry standard for DNT and users cannot know how a given company responds to a DNT signal they receive from browsers. Reframe is committed to remaining apprised of DNT standards. Reframe does not track users via web browsers, support DNT browser settings, or currently participate in any DNT frameworks that would allow Reframe to respond to signals or other mechanisms regarding the collection of your personal information.

We use the following types of Cookies:

• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. Presently, Reframe uses the following Performance/Analytical Cookies: Calendly, Jotform, and Google.

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Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

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You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

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Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in a de-identified or aggregated form where that information would not identify you personally.

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Data or Security Breach Response

Reframe takes the security of your Personal Data seriously. In the event of a data or security breach, Reframe will take the following actions: (i) promptly investigate the security incident, validate the root cause, and, where applicable, remediate any vulnerabilities within the control of Reframe that may have given rise to the security incident; (ii) comply with laws and regulations directly applicable to Reframe in connection with such security incident; (iii) as applicable, cooperate with any affected Reframe user or client in accordance with the terms of any contract between such user or client and Reframe; and (iv) document and record actions taken by Reframe in connection with the security incident and conduct a post-incident review of the circumstances related to the incident and actions/recommendations taken to prevent similar security incidents in the future. Reframe will notify you of any data or security breaches as required by and in accordance with applicable law.

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Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at info@frameyourfuture.com.

If you are a resident of California under the age of 18 and have registered for a User Account with us, you may ask us to remove content or information that you have posted to our Platform. 

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California Resident Rights

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask for and obtain from us an annual list identifying the categories of personal customer information which we shared, if any, with our affiliates and/or third parties in the preceding calendar year for marketing purposes. This list will be provided free of charge. Contact information for such affiliates and/or third parties must be included. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 

You may submit a Valid Request using the following methods:

• Email us at: hello@frameyourfuture.com 

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Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at info@frameyourfuture.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. 

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Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Reframe platform and/or by some other means. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

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Contact Information:

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

• hello@frameyourfuture.com

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