Privacy Notice

This Privacy Notice (“Notice”) explains how your personal information, sometimes referred to as personal data, is collected, used, and disclosed by, CodonRX Inc. and its subsidiaries and affiliates (collectively “CodonRX”) in connection with your use of our websites and mobile applications (also known as “apps”), that is our “Services”.

When you use the Services, you consent to our collection, use, retention, disclosure, and protection of information about you, as described in this Notice.

This Notice contains the following sections:

• Information we collect about you
• How we use your information
• How we share your information
• Retention of your information
• Your choices
• Children’s privacy
• International transfer
• State-specific disclosures
• Changes to this Policy
• Contact Us

Information we collect about you
We may collect and store information about you in various ways. For example, we may collect information that you provide to us, information that we collect via social networking sites or Third-Party Applications (as described below), information that we automatically collect through your use of the Services, and information from publicly available sources or non-affiliated third parties.

Information you provide to us
Information about yourself. When you use the Services, you may be invited to provide your information directly to us, which may include personal information. Some examples of the information we may collect when you use the Services include:

• Account registration, including email address, phone number and any additional information necessary for multi-factor authentication to secure your CodonRX account.
• Demographic information that you submit, such as name, gender, date of birth and similar demographic details.
• Health data about existing medical conditions, medications for those conditions and symptoms of those conditions, as related to the consumption of CodonRX products.
• Any other information as may be necessary to operate and secure our Services, and provide them to you.

Information from third-party applications and services
If you opt in to connect the Services with any other applications, devices, services, or third- party accounts that you maintain, such as social media networks (collectively “Third-Party Applications”), we may collect certain information as permitted by your privacy settings in the Third-Party Application.

Advertising data. We may make use of data related to the placement of ads by CodonRX, including data used to measure, report and improve the effectiveness of advertising across our website, third party websites or our mobile app.

Information that is generated automatically
When you utilize our Services, certain information is automatically collected. That information can include:

• Server log data that your browser generates when you visit our website or that your mobile app provides to our servers. We and our third-party service providers may collect your Internet Protocol (IP) address (and associated city and state, province, or country for the IP address), computer operating system, browser type, other system settings, as well as the language your system uses and the country and time zone where your device is located, the date and time you used the Services, error logs, and other similar information.
• Device information collected when using the mobile app may include additional information about the type of device, operating system, settings, unique device identifiers, and crash data.

Cookies & Similar Technologies. Cookies, web beacons, mobile analytics and advertising device IDs, and similar technologies can be used, either by ourselves or by our third-party service providers, to collect information about you, your usage of the Services, and your devices. The data collected may include data about your online activities over time and across different websites, apps, or online services.

Online Analytics. We may use third-party analytics services for our websites, such as those provided by Google Analytics, as well as for mobile application analytics. These service providers use cookies and other technologies described in this Notice to help us analyze how users, like yourself, use our Services. The information collected by these technologies will be disclosed to or collected directly by these service providers.

How we use your information We, and our service providers, use the information collected to provide our Services to you or as otherwise described in this Notice. For example, we may use your information to:

• Operate, manage, maintain, and improve our business, and in particular the Services, including development of new products, features and functionalities, and any required submissions to regulatory authorities or agencies;
• Provide, develop, improve, repair, and maintain our products and services, including the Services;
• Contact you, or otherwise provide you with information about your account and current and future programs and initiatives offered via the Services;
• Respond to your feedback, comments, or questions, or to otherwise send you information about our Services;
• Combine the information collected, including from Third-Party Applications and services, with other information about you or the CodonRX community;
• Perform analysis and/or research, including for publication (in a manner that does not identify you personally) pursuant to Institutional Review Board approval, waiver, or exemption, as necessary;
• Analyze how you use and interact with our Services, as well as how our Services are used across the CodonRX community and our products more generally;
• Protect our Services and the information collected against fraudulent, illegal, or otherwise unauthorized activity, including any investigation into and remediation of such activity;
• De-identify, tokenize, or aggregate your information (or otherwise render the information so you are not reasonably identifiable), or to create or derive datasets, as part of the Services and for other purposes consistent with why the information was collected and CodonRX’s mission;
• Identify and correct technical errors in our products and services, including the Services;
• Personalize, advertise, and market our products and services to you, including the Services;
• Conduct or perform research, analytics, and data analysis;
• Conduct and implement risk and security controls and monitoring, and secure the Services;
• Maintain our facilities and infrastructure;
• Detect and prevent fraud;
 
• Comply with law, legal process, and internal policies;
• Exercise and defend legal claims;
• Otherwise accomplish our business purposes and objectives; and
• For any other purpose described in this Notice or our End User License Agreement.

We may combine information that we collect from you through the Services with information that we obtain from affiliated and non-affiliated third parties, and information derived from any other products or services we provide.

We may aggregate, de-identify, and/or tokenize information collected through the Services and use such data for any purpose; including, without limitation, for our own research and commercial purposes, or to prepare analyses or reports for our blog, public presentations, publication, partners or others regarding the use of our Services and/or data about our user population and subsets thereof. Aggregated, tokenized, and/or de-identified data may also be shared with our research, awareness, and other partners and customers through dashboards and metrics, so that we can run the specific project in which you may have enrolled and also to operate, improve, and provide our Services.

How we share your information
We will not sell, rent, or otherwise disclose your personal information to our customers without your express consent, as detailed below. Specifically, we may disclose your information to:

Service Providers. We may disclose your information with third parties that are our service providers to help us operate or conduct our business and provide the Services. This includes activities such as communication with our users, email management, data hosting, analytics, payment processing, fraud and safety protection, rewards redemptions, and legal and accounting services.

Third-Party Applications or Services. If you access the Services through our partners' or service providers’ websites and applications, in order to provide and administer the Services we may be required to share user identification information, such as a login name or email address associated with your account, with such partners or service providers.

Financial services and payment processing: When you provide payment data, for example to make a purchase, we will disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services.

When Required by Law or as Necessary to Protect Our Members and Services. We may disclose information when doing so is necessary to comply with laws, regulations, or legal process or we believe that is reasonably necessary to protect, enforce, or defend the legal rights, privacy, safety, or property of CodonRX, our employees or other personnel, agents or members.

Corporate transactions: We may disclose your information as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.

Otherwise with Your Consent or at Your Direction. We may also disclose information about you with third parties whenever you consent to or direct such sharing.

Retention of your information
We keep your information only so long as we need it to provide our services to you, fulfill the purposes described in this policy, comply with our legal obligations, resolve disputes, and enforce our agreements. Actual retention periods can vary significantly based on your expectations and consent, the sensitivity of the data, the availability of automated controls, and our legal or contractual obligations.

We may also retain specific limited information related to your account and any data deletion or other access request you may submit as necessary to document our fulfillment of your requests. We will retain this information for a limited period of time as required by policy, law, contractual obligations, and/or as necessary for the establishment, exercise or defense of legal claims and for audit and compliance purposes, and will not use that information for any other purposes.

In some cases, we may need to retain your personal information to meet the specific legal, regulatory, or contractual requirements that apply to certain of our studies, research, or programs.

Your choices
We aim to give you straightforward choices regarding your information. Much of your information can be updated directly in the CodonRX app. This includes:

• Edit information in your profile at any time.
• Choose whether the CodonRX app will be record inputs about underlying medical issues and about the user’s state of health;
• Close your account at any time. When you close your account, we’ll deactivate it and delete your account data. (Please note that there may be legal reasons for us to keep your data, such as if we receive a law enforcement request asking us to preserve data.)

Children’s privacy
Our Services are not intended for children under the age of 18. If we become aware that we have collected “personal information” (for example, as defined by the United States Children’s Online Privacy Protection Act) from children under the age of 13 without valid parental consent, we will take reasonable steps to delete that information as soon as possible and remove the underage users’ access to our application(s). We will also not sell or otherwise knowingly process the information.

International transfer
Your information may be transferred to, and maintained on, computers or servers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide your information to us, we may transfer your information to the United States and process it there (or any other country in which we operate). Your submission of information using the Services represents your agreement to such transfer.

State-specific disclosures
If you are a resident of California, Colorado, Virginia, Utah, or Connecticut, you have certain rights and choices.

Notice at Collection. You have a right to receive notice of our practices before or when we collect your information, including the categories of information and sensitive personal information collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this Notice in the paragraphs above.

Right to Know. You have a right to see the information we have collected about you. You may request your information by contacting us at contact@codonrx.com. You also have a right to request additional information about our collection, use, disclosure, selling or sharing of such information. You can find those details in this Notice in the paragraphs above.

Rights to Request Correction or Deletion. You also have rights to request that we correct inaccurate information about you or delete your information. You can log into your account to update your information, or delete your data at any time by logging into your account or by contacting us at contact@condonrx.com. Please note that there may be legal reasons for us to keep your data, such as if we receive a law enforcement request asking us to preserve data.

Right to Opt-Out/Right to Limit Use and Disclosure of Sensitive Personal Information. You have a right to opt-out from the “sale” or “sharing” of your personal information. We not sell your personal information. However, we do use services that help deliver interest-based marketing and advertising to you outside of the Services.

You also have a right to limit our use of sensitive personal information for purposes other than to provide the Services.

Please contact us at contact@condonrx.com if you do not wish for us or our partners to share information relating to your use of the Services for marketing and advertising purposes.

Right Against Discrimination. CodonRX will not discriminate against you for exercising these rights.

Under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal information to a business with which they have established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. Other Disclosures

Changes to this Policy
We may change this policy from time to time and if we do, we’ll post any changes on this page. If you continue to use the Services after those changes are in effect, you agree to the new policy. If the changes are significant, we may provide more prominent notice or obtain your consent to the changes.

Contact Us
For any questions, complaints, or inquiries regarding this Notice, or our privacy practices, please direct your inquiry to contact@condonrx.com.