Ginger Website Privacy Statement

Ginger.io, Inc. (“Ginger.io,” “our,” “us,” or “we”) respects your privacy. The privacy statement describes our practices and policies regarding the collection, use, storage and disclosure of the personal information collected through our websites and interactions with Ginger.io.

Ginger.io Coaching Services LLC and Ginger.io of California Medical P.C. offer mobile applications and services subject to separate privacy statements. When you use the mobile application, coaching services, or medical services, the privacy statements specific to each of those services, as listed below in Supplements and Additional Notices below, shall apply.

When you visit our website, or provide personal information to us, we will only use the information for the uses and purposes described in this policy. By continuing to use the website, or by providing your personal information to us, you agree to the practices and policies described in this Privacy Statement.

How We Collect and Use Information

We do not require you to register with us to visit our website. We do collect anonymous information, as described below. We may collect your personal information (such as name, email address, or other information) only when you voluntarily give it to us to request information about our services.

Information Collected Automatically/Aggregate Data Collection

We track visits to our website and its webpages and use visitor logs to compile anonymous aggregate statistics, (e.g., information such as your web requests, browser type, browser language, domain names, IP address, referring and exit pages, URLs, platform type, pages viewed and the paths you took on our website). We use this information to analyze trends, administer our website, improve our website design, and otherwise enhance our websites and services.

Use of Cookies/Web Beacons

We may use cookies, both session and persistent cookies, or web beacons on certain webpages and/or html email correspondence to anonymously track visitors, save website preferences or allow us to recognize visits from the same computer and browser. You have the option to disable cookies in your browser and still use our website, although your access to the site may be limited.

Information You Voluntarily Provide

We may use your personal information to contact you regarding an inquiry or to provide you with more information about Ginger.io or other marketing information we believe you may be interested in.

When You Send Us an Email

If you contact us about our website or services, we may retain the content of your email, your email address and our response to you. We may retain your information for a period of time to resolve disputes, troubleshoot problems or for other valid business or legal reasons.

How to Unsubscribe

You have the opportunity to select certain communication methods from us. Anyemail from us will include instructions on how to update your personal information and on how to unsubscribe or change your communication preferences. Please follow these instructions to notify us of any changes to your information and/or marketing preferences. You may also unsubscribe or change your preferences at any time by contacting us at help@ginger.io.

How We Share Information

We do not sell or rent your personal information to any other third party. We only share Personal Information with third parties who are bound by terms at least as restrictive as this Privacy Statement and only in the following ways:

Affiliates – We may share Personal Information with any of our subsidiaries and affiliates for the purpose of providing our services and improving our offerings.

Service Providers – We share Personal Information with third-party service providers who perform a variety of functions to enable us to provide our services. These service providers only have access to the Personal Information necessary to perform their functions, only act on our behalf and under our instructions, and may not use it for purposes other than to perform such functions.

Legal – We may disclose Personal Information to courts, law enforcement agencies and other government bodies if we suspect that an individual's use of our website or services involves illegal activity or is otherwise inconsistent with any applicable terms and conditions. We may also disclose Personal Information where we believe that doing so would be in accordance with or required by any applicable law, regulation or legal process.

Business Transfers – In the event of a reorganization, merger or sale, we may transfer any and all Personal Information we collect to the relevant third party involved in the reorganization, merger or sale, with the consent of data subjects if and as required under applicable privacy laws.

Other Disclosures – We may otherwise disclose Personal Information as permitted or required by law, when we believe in good faith it is necessary for safety purposes, to prevent you or others from harm, protect our legal rights, enforce our Terms of Use or any applicable rules, or to protect the rights of others.

How We Protect Information

We secure information by using reasonable administrative, physical and technical safeguards. We encrypt information transmitted to us using Secure Sockets Layer (SSL/TLS) technology. All information is stored on controlled servers with restricted access. It is important for you to know that, despite using these current technical and industry-recommended practices, it is never possible to fully guarantee against breaches in security.

How You May Access Information

You may contact us to notify us of any changes to your name, email address or marketing preferences. If you have provided us with your personal information and would like access to or be able to review the information, you may submit a request to us by sending an email to help@ginger.io

Children

Our website is directed toward adults and Ginger.io does not knowingly collect information or offer services to children under the age of eighteen (18).

Third-Party Services

When you visit our website, Ginger.io uses the following third-party analytics services to help us analyze, monitor, and improve our website and services:

Google Analytics – http://www.google.com/policies/privacy/

HotJar - https://www.hotjar.com/privacy

Adjust - http://www.adjust.com/privacy-policy

Ginger.io does not provide any personally identifiable information to these third-party services.

Links to other sites

Our website may contain links to external sites or services. Ginger.io does not maintain these sites and is not responsible for the privacy practices of sites or services it does not operate. You should consult the respective privacy policies posted on these sites.

Supplements and Additional Notices

Some Ginger.io services, the mobile application, coaching services, and the medical services provided by our Ginger.io companies have separate notices about how such products and services collect and use your Personal Information.

Please refer to the relevant notices for these Ginger.io services:

Ginger.io of California Medical P.C. Privacy Statement

Ginger.io Coaching Services LLC Privacy Statement

Ginger.io of California Medical P.C. Notice of Privacy Practices

Updates

We may revise this Privacy Statement from time to time. Changes to this Privacy Statement become effective when the revisions are posted on the website. We encourage you to periodically review this Privacy Statement to stay informed about how we collect, use, and share personal information.

How to Contact Us

If you have any questions about this Privacy Statement, please contact us at privacy@ginger.io.

Last Updated: December 1, 2017

Ginger.io of California Medical P.C. Privacy Statement

INTRODUCTION

This Privacy Statement describes the practices and policies of Ginger.io Inc, ("Ginger.io") regarding the collection, use, storage, and disclosure of personally identifiable information ("Personal Information") we collect from our website (www.ginger.io) (the "Website"), mobile application (the "App"), and related services (collectively, the "Services" or "Service")

You may have been invited to use, download or install the Service by your Employer, as part of an ongoing study or research project or your healthcare provider (an "Institutional Client"), or a third party healthcare provider, such as Ginger.io of California Medical P.C. ("G.io Medical"), whose services are provided through the Ginger.io mobile application, or you may have subscribed or downloaded and installed the Service for your personal use.

BY ACCESSING OR USING THE SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY AND OUR TERMS OF USE AND CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS SET OUT IN THIS PRIVACY STATEMENT.

WHAT INFORMATION DO WE COLLECT?

We may collect the following types of Personal Information in connection with our delivery of Services to you:

When you register to receive services from us, whether in your individual capacity or on behalf of an organization, we collect any Personal Information that you submit through our registration form, including your name, email address, mailing address, phone number, payment card information, and any other Personal Information you voluntarily submit through the online registration form (your "Account Data");

When we deliver Services to you, we collect Personal Information and health information that you voluntarily provide to us, our coaches, clinicians including information about your personal goals and health circumstances (your "Care Data");

When you use our Services we automatically collect information about your web browser, mobile device, and how and when you use our mobile application, including the manufacturer and model of the device, unique device identifiers, and IP address ("Mobile Data");

We collect usage information about our Website and Services and use visitor logs to compile anonymous aggregate statistics, (e.g., information such as your web requests, browser type, browser language, domain names, referring and exit pages and URLs, platform type, pages viewed and the paths you took on our Site, and IP Addresses) ("Usage Data");

When you use the Services to respond to our surveys and health questionnaires, we may collect the information you voluntarily provide in your responses as well inferred health status for specific conditions and survey alerts (your "Survey Data").

We may also collect Personal Information that you voluntarily provide to us when you contact us with a question or comment about our Services.

HOW DO WE USE INFORMATION WE COLLECT?

PERSONAL INFORMATION

We will use and store Personal Information for the purpose of delivering the Service to you and, where applicable, to Institutional Clients and healthcare providers, and to analyze and enhance the operation of the Service.

We also use and store Personal Information and, where applicable, information obtained from Institutional Clients and healthcare providers, for proprietary analysis and development of personalized behavioral profiles for you and/or, where applicable, the healthcare provider or Institutional Client.

In particular we use:

Account Data to manage your account, communicate with you in relation to your account, process your transactions, and deliver and monitor the performance of our services;

Care Data to help you, your coach, clinician, or healthcare provider understand your personal objectives and circumstances, help you develop and execute strategies to overcome your challenges and achieve your goals, deliver appropriate care, evaluate the quality and progress of our program, and optimize delivery of services;

Mobile Data to monitor and enhance the performance of the App, analyze trends, usage and activities in connection with the App, and ensure its technological compatibility with users;

Usage Data to analyze trends, administer our services, improve the design of our App and Website, and otherwise enhance the services we provide;

Survey Data and reports to our coaches, clinicians, and applicable Institutional Clients to better understand your health status, provide feedback, and to provide proactive alerts.

To allow for additional research, product development, and insights over time, Ginger.io may anonymize or de-identify your Personal Information and health information in a manner that meets the Health Insurance Portability and Accountability Act of 1996 (HIPAA) de-identification standard, such that such data is no longer reasonably identifiable.

AGGREGATE INFORMATION

We create statistical, aggregated data relating to our users and the Service for analytical purposes. Aggregated data includes data derived from Personal Information and obtained by Ginger.io from other sources in aggregated, anonymous form. Aggregate Information cannot reasonably be used to identify any individual. We use Aggregate Information to understand our customer base, market our Services, and improve and enhance our site and services.

EMAIL AND OTHER COMMUNICATIONS

We may use your personal information to contact you regarding an inquiry or to provide you with more information about Ginger.io or other marketing information we believe you may be interested in. We will send you email alerts or notification messages unless you unsubscribe.

If you wish to opt out of these emails, you may do so by following the "unsubscribe" instructions in the email; provided however, Ginger.io may maintain the right to send you important emails about your account or the Services.

Email and text messaging allows healthcare providers to exchange information efficiently for the benefit of users/patients. We recognize that email and text messaging may not be a completely secure means of communication. Your use of the Service means that you agree and consent to the use of email and/or text messaging as an acceptable form of communication.

USER TESTIMONIALS

We value your feedback on, and appreciate any testimonials about, our Services. If you send us any such feedback or testimonials, they shall be deemed, and shall remain, the property of Ginger.io and shall be subject to any obligation of confidence on our part. However, Ginger.io shall obtain prior written approval of any usage of your identity or contact information, if Ginger.io wishes to reference you in connection with that feedback or testimonial.

WHAT INFORMATION DO WE DISCLOSE TO THIRD PARTIES?

We will not sell or rent your personal information to any other company or organization We will not disclose your Personal Information to any third party except as follows:

To a provider on whose behalf the information was collected for the purpose of providing services to you.

To emergency services and other agencies to protect you, the clinician, the coach, or others from harm

To third parties engaged to provide services on our behalf such as managing our accounts, processing transactions, operating the App, or providing customer service. We enter into agreements which require such providers to protect such information and use the Personal Information they receive only to perform services for us.

To obtain and process payment for our services

To law enforcement, judicial authority, or governmental or regulatory authority, to the extent required by law or if in our reasonable discretion disclosure is necessary to enforce or protect our legal rights, to protect you, or to protect third parties.

In the event of a reorganization, merger, acquisition, asset sale or similar transaction, we may transfer any and all Personal Information we collect to the relevant third party involved in the transaction, with your consent if and as required under applicable privacy laws.

We may otherwise disclose your Personal Information only when we have your prior consent to share the information.

We may otherwise disclose your Personal Information only when we have your prior consent to share the information.

ACCESSING AND UPDATING YOUR INFORMATION

You have the right to review, amend, or correct your email address, Account Data, or other Personal Information held in our database. To do so, please contact us by sending an email to help@ginger.io with a clear description of your request. We will try to comply with your request as soon as reasonably practicable and always under the timeframes set forth by applicable laws.

If you would like your Personal Information permanently removed from our database, please contact us at help@ginger.io. We will then terminate your account, you will no longer be able to use our services, and you will no longer receive emails from Ginger.io. Subject to applicable law and necessary record retention requirements, your identifying Personal Information shall be deleted from our records within 30 days of your request. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or authorized by law.

INFORMATION SECURITY

We use reasonable and appropriate security precautions to protect the security and integrity of your Personal Information in accordance with this Privacy Statement and applicable law. However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur.

We have implemented administrative, physical, and technical safeguards including use of SSL and encryption of your information.

You are responsible for maintaining the security of your login ID and password. If you believe that your login ID or password has been compromised, you should immediately change your password and contact our support services. We are not responsible if someone else accesses your account through registration information they have obtained from you or through a violation by you of the Terms of Use.

LINKS

The Ginger.io Services may contain links to other websites. Ginger.io is not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave our Service and are encouraged to review the privacy statements of each third party website. This Privacy Policy applies solely to information collected by Ginger.io.

USE OF COOKIES / WEB BEACONS

We may use cookies, both session and persistent cookies, or web beacons on certain webpages and/or html email correspondence to anonymously track visitors, save website preferences or allow us to recognize visits from the same computer and browser. You have the option to disable cookies in your browser and still use our services, although it may limit your access to the services.

CHILDREN

Ginger.io does not knowingly collect or maintain personally identifiable information from persons under 18 years of age, and no part of the Service is directed at persons under 18.

CHANGES

We may modify or amend this Privacy Policy from time to time. If we make any material changes, as determined by Ginger.io, in the way in which Personal Information is collected, used or transferred, such changes to this Privacy Policy will be available via a link to the most current terms of the Privacy Policy (which can be found at Ginger.io's website for the Services). Notwithstanding any modifications we may make, any Personal Information we collect from you will be treated subject to applicable laws and regulations. The date last revised appears at the bottom of the Privacy Policy. Changes take effect immediately upon posting.

QUESTIONS

To submit a question or concern, please contact us at help@ginger.io or write to us at the following address: Ginger.io, Inc. c/o Customer Support - Privacy 332 Pine Street Suite 800, San Francisco, CA 940104.

VISITORS FROM OUTSIDE THE UNITED STATES

Ginger.io and its servers are located in the United States and are subject to the applicable state and federal laws of the United States. If you choose to access or use the Service, you consent to the use and disclosure of information in accordance with this Privacy Policy and subject to such laws.

Last Updated: May 1, 2018

Ginger.io of California Medical P.C. Notice of Privacy Practices

This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

Ginger.io of California Medical P.C. ("Ginger.io Medical") and the members of its workforce are committed to protecting the privacy and confidentiality of your personal information and mental health information.

OUR RESPONSIBILITY

Ginger.io Medical is required by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to keep your personal health information ("Protected Health Information") confidential. This Notice describes the ways in which we may use and disclose health information about you and describes your rights and our obligations regarding the use and disclosure of that information.

HOW WE MAY USE AND DISCLOSE YOUR HEALTH INFORMATION

Your Protected Health Information may be used and disclosed for treatment, payment, healthcare operations and other purposes permitted or required by law. Ginger.io Medical may use and disclose your Protected Health Information for the following purposes:

TREATMENT

We may use or disclose your protected health information to provide coaching, tele­health, and therapy services as part our Ginger.io Medical product and service offerings. We may disclose information to doctors, therapists, or other healthcare providers who are involved in taking care of you and your health.

PAYMENT

We may use and disclose health information about you so that the health services you receive may be billed to and payment may be collected from you, an insurance company, or a third party.

HEALTHCARE OPERATIONS

We may use and disclose health information about you for activities necessary to support, operate, and improve Ginger.io Medical products and services. For example, we may use your Protected Health Information to monitor and/or improve the quality of our tele­health services, respond to patient inquiries, and review the competence and qualifications of our therapists and coaches. We may de-­identify your Protected Health Information to remove personal information that identifies you (for example your name and address) in order to develop new products and/or services, or to work with others who can develop such products and/or services, which we can use to better serve you.

BUSINESS ASSOCIATES

We may disclose your Protected Health Information to other companies or individuals, known as "Business Associates," who provide services to us. Business Associates are required to protect the privacy and security of your Protected Health Information and notify us of any improper disclosure of information.

FAMILY AND FRIENDS

We may disclose health information about you to your family members or friends if we obtain your verbal or written agreement or if we can infer from the circumstances, based on our professional judgment that you would not object.

PERSONAL REPRESENTATIVES

We may disclose Protected Health Information about you to an authorized personal representative, such as a lawyer, administrator, executor, or other authorized person responsible for you or your estate.

THREAT TO HEALTH AND SAFETY

We may disclose Protected Health Information to prevent or reduce the risk of a serious and imminent threat to your health or to a third party or the general public.

COMMUNICATIONS ABOUT OUR PRODUCTS AND SERVICES

We may use and disclose your Protected Health Information to contact you about other Ginger.io Medical products and services which we believe may be of interest to you.

LAW ENFORCEMENT

We may disclose your Protected Health Information to the police or other law enforcement officials as required by law or in compliance with a court order, warrant, subpoena, summons, or other legal process for locating a suspect, fugitive, witness, missing person, or victim of a crime.

AS REQUIRED BY LAW

We must disclose your Protected Health Information when required to do so by any applicable federal, state or local law.

JUDICIAL AND ADMINISTRATIVE PROCEEDINGS

Under certain circumstances, we may disclose your Protected Health Information in the course of a judicial or administrative proceeding in response to a court order, subpoena, or other lawful process.

RESEARCH

Under certain circumstances, we may use or disclose your Protected Health Information for research purposes. All research projects at Ginger.io Medical are subject to review by a committee responsible for ensuring the protection of individual research subjects, appropriate patient authorization, and an adequate plan to safeguard Protect Health Information. In preparation for research, we may review limited Protected Health Information to draft research protocols, to identify prospective research participants, or for similar purposes.

HEALTH AND GOVERNMENT AGENCIES

As permitted by HIPAA, we may also disclose your PHI to:

Public Health Authorities

The Food and Drug Administration

Health Oversight Agencies

Military Command Authorities

National Security and Intelligence Organizations

Correctional Institutions

Organ and Tissue Donation Organizations

Coroners, Medical Examiners and Funeral Directors

Workers Compensation Agents

ALL OTHER USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION

We will ask for your written authorization before using or disclosing your Protected Health Information for any purpose not described above. You may revoke your authorization, in writing, at any time, except for disclosures that the company has already acted upon or are required by law. Ginger.io Medical will never sell or give your identifying information to third­party marketers unless you give us written permission for marketing purposes or sale of your identifying information.

Ginger.io Medical will never share psychotherapy notes unless you give us written permission, or as required by law, health and safety, or a government agency.

YOUR RIGHTS REGARDING YOUR HEALTH INFORMATION

You have the following rights with respect to your Protected Health Information. To exercise any of these rights, please contact our Privacy Office using the contact information provided at the end of this Notice.

RIGHT TO ACCESS PROTECTED HEALTH INFORMATION

You, or your authorized or designated personal representative, have the right to inspect or copy the Protected Health Information maintained by us. You must submit a written request to the privacy office to inspect and/or copy your health information records.

RIGHT TO REQUEST CONFIDENTIAL COMMUNICATIONS

You have the right to request that we communicate with you about your Protected Health Information by alternative means or to an alternative address, email, or phone number. Your request must be in writing and must specify the alternative means or location.

RIGHT TO CORRECT OR UPDATE INFORMATION

If you believe the Protected Health Information we maintain about you contains an error, you may request that we correct or update your information. Your request must be in writing and must explain why the information should be corrected or updated. We may deny your request under certain circumstances and provide a written explanation.

RIGHT TO AN ACCOUNTING OF DISCLOSURES

You may request a list, or accounting, of certain disclosures of your Protected Health Information made by us or our business associates for purposes other than treatment, payment, healthcare operations and certain other activities. The request must be in writing and state a time period, which may not be longer than the prior six years.

RIGHT TO REQUEST RESTRICTIONS

You have the right to request restrictions on our use and disclosure of your Protected Health Information. While we will consider all requests for additional restrictions carefully, we are not required to agree to a requested restriction except for Payment or Operations restrictions where payment has been made "out-­of-­pocket" and "paid-­in-­full."

RIGHT TO A COPY OF THIS NOTICE

Upon request, you may obtain a paper or electronic copy of this Notice.

INFORMATION BREACH NOTIFICATION

We are required to notify you following the discovery a breach of your unsecured Protected Health Information, unless there is a demonstration, based on a risk assessment, that there is a "low probability" that the Protected Health Information has been compromised. You will be notified in a timely fashion, no later than 60 days after discovery of the breach.

QUESTIONS AND COMPLAINTS

If you have questions or concerns about our privacy practices or would like a more detailed explanation about your privacy rights, please contact our Privacy Office using the contact information below.

If you believe that we may have violated your privacy rights, you may submit a complaint to our Privacy Office. You also may submit a written complaint to the U.S. Department of Health and Human Services. We will provide you with the address to file your complaint with the U.S. Department of Health and Human Services upon request. Ginger.io Medical will not take retaliatory action against you and you will not be penalized in any way if you choose to file a complaint with us or with the U.S. Department of Health and Human Services.

CHANGES TO THIS NOTICE

We reserve the right to change our privacy practices and the terms of this Notice at any time, provided such changes are permitted by applicable law. We will promptly post any changes to this Notice on our website or otherwise provide them to you.

CONTACT INFORMATION

When communicating with us regarding this Notice, our privacy practices, or your privacy rights, please contact the Privacy Office using the following contact information:

Attn: Privacy Officer

Ginger.io Medical

332 Pine Street Suite 800

San Francisco, CA 94104

privacy@ginger.io

EFFECTIVE DATE: February 27, 2017

Ginger.io Coaching Services LLC Privacy Statement

INTRODUCTION

Ginger.io Coaching Services LLC (“Ginger.io” or “we”) has prepared this Privacy Statement to inform recipients of our coaching services (“user” or “you”) about how we collect, use and disclose their personally identifiable information (“Personal Information”). To receive coaching services from us, you must download the Ginger.io mobile application (the “App”).

BY REGISTERING FOR AND RECEIVING OUR COACHING SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY STATEMENT, AGREE TO BE BOUND BY OUR TERMS OF USE, AND CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS SET OUT IN THIS PRIVACY STATEMENT.

WHAT INFORMATION DO WE COLLECT?

We may collect the following types of Personal Information in connection with our delivery of coaching services to you:

When you register to receive coaching services from us, whether in your individual capacity or on behalf of an organization, we collect any Personal Information that you submit through our registration form, including your name, email address, mailing address, phone number, payment card information, and any other Personal Information you voluntarily submit through the online registration form (your “Account Data”);

When we provide our coaching services to you, we collect any Personal Information that you voluntarily provide to us and our coaches, including information about your personal goals and circumstances (your “Coaching Data”);

When you use the App, we automatically collect information about your mobile device and how and when you use our mobile application, including the manufacturer and model of the device, unique device identifiers, and IP address (“Mobile Data”);

If you use the App to respond to our surveys and questionnaires, we collect the information you voluntarily provide in your responses (your “Survey Data”).

We may also collect Personal Information that you voluntarily provide to us when you contact us with a question or comment about our services.

HOW DO WE USE INFORMATION WE COLLECT?

PERSONAL INFORMATION

We use your Personal Information to provide and optimize the App and our coaching services. In particular, we use:

Account Data to manage your account, communicate with you in relation to your account, process your transactions, and deliver and monitor the performance of our services;

Coaching Data to understand your personal objectives and circumstances, help you develop and execute strategies to overcome your challenges and achieve your goals, evaluate the quality and progress of our coaching program, and optimize our coaching services;

Mobile Data to monitor and enhance the performance of the App, analyze trends, usage and activities in connection with the App, and ensure its technological compatibility with users;

Survey Data to provide insight to your coach about your personal circumstances and to receive feedback on the quality of our services.

We also use the Personal Information you provide us to respond to your comments and questions and personalize our services for you.

We may wish to use your Personal Information to provide you with marketing communications. We will only do so with your consent and as permitted by law.

AGGREGATE INFORMATION

We create statistical, aggregate data (“Aggregate Information”) about our user base for analytical purposes. Aggregate Information includes data derived from Personal Information and obtained by us from other sources in aggregated, anonymous form. Aggregate Information cannot reasonably be used to identify any individual.

LEGAL EXCEPTIONS

Under certain circumstances, Personal Information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders. As such, notwithstanding the above, we may in any event use Personal Information to the extent required or permitted by applicable law to resolve disputes, to enforce our agreements (including the Terms of Use) with you, or as reasonably necessary to protect our legal rights, to protect you against self-harm, or to protect third parties.

WHAT INFORMATION DO WE DISCLOSE TO THIRD PARTIES?

We will not disclose your Personal Information to any third party except as follows:

We may disclose your Personal Information to third parties who provide services on our behalf, such as managing our accounts, processing transactions, operating the App, or providing customer service. We enter into confidentiality agreements with such providers which require them to use the Personal Information they receive only to perform services for us.

Subject to applicable law, we may disclose your Personal Information to any law enforcement, judicial authority, or governmental or regulatory authority, to the extent required by law or if in our reasonable discretion disclosure is necessary to enforce or protect our legal rights, to protect you, or to protect third parties.

In the event of a reorganization, merger, acquisition, asset sale or similar transaction, we may transfer any and all Personal Information we collect to the relevant third party involved in the transaction, with your consent if and as required under applicable privacy laws.

We may otherwise disclose your Personal Information when we have your prior consent to share the information. In such cases, we will have written contracts in place with the third parties requiring them to comply with terms of confidentiality similar to the applicable terms of this Privacy Statement as well as all applicable statutes, regulations and laws pertaining to the protection of such Personal Information.

We may share Aggregate Information with third parties where permitted by applicable law.

INFORMATION SECURITY

We use reasonable and appropriate security precautions to protect the security and integrity of your Personal Information in accordance with this Privacy Statement and applicable law. We secure information using industry standard administrative, physical, and technical safeguards including encryption of information that is stored and transmitted. It is important for you to know that, despite using these current industry-recommended practices, we cannot guarantee against breaches in security.

You are responsible for maintaining the security of your login ID and password. If you believe that your login ID or password has been compromised, you should immediately change your password and contact our support services. We are not responsible if someone else accesses your account through registration information they have obtained from you or through a violation by you of the Terms of Use.

LINKS

The App may contain links to other websites. Ginger.io is not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave our Service and are encouraged to review the privacy statements of each third party website. This Privacy Policy applies solely to information collected by Ginger.io.

CHILDREN

Ginger.io does not knowingly collect or maintain Personal Information from persons under 18 years of age, and no part of our services is directed at persons under 18. If you are below the age of 18, you are not permitted to use our services.

If Ginger.io learns that Personal Information of persons less than 18 years of age has been collected without verifiable parental consent, then Ginger.io will take the appropriate steps to delete this information. To make such a request, please contact us at help@ginger.io.

ACCESS, CORRECTION, AND OTHER RIGHTS

To exercise the statutory rights you may have under applicable law, such as to access, correct, update or delete Personal Information we have under our control, limit our use of your Personal Information, or exercise any right to data portability, please contact us by the means noted below and clearly describe your request.

You have the right to review, amend, or correct your email address, Account Data, or other Personal Information held in our database. To do so, please contact us by sending an email to help@ginger.io with a clear description of your request. We will try to comply with your request as soon as reasonably practicable and always under the timeframes set forth by applicable laws.

If you would like your Account Data or other Personal Information permanently removed from our database, please contact us at help@ginger.io. We will then terminate your account, you will no longer be able to use our services, and you will no longer receive emails from Ginger.io. Subject to applicable law and necessary record retention requirements, your identifying Personal Information shall be deleted from our records within 30 days of your request. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or authorized by law.

CHANGES

We may modify or amend this Privacy Statement from time to time. If we make any material changes in the way in which Personal Information is collected, used or transferred, this Privacy Statement will be revised to reflect such changes and the updated Privacy Statement will be made available to you. Notwithstanding any modifications we may make, any Personal Information we collect from you will be used in accordance with applicable laws and regulations. The date last revised appears at the bottom of the Privacy Statement. Changes take effect immediately upon posting.

QUESTIONS

You may also contact us if you have any questions about this Privacy Statement. Please contact us at help@ginger.io or write to us at the following address: Ginger.io Coaching Services LLC, 332 Pine Street, Suite 800, San Francisco 94104 California USA.

CROSS-BORDER TRANSFERS

In connection with your access and use of our services, your Personal Information may be transferred to and processed in the United States of America, which do not adduce an adequate level of protection from a European data protection perspective. If you are located in the European Economic Area, please note that we will take all necessary measures to ensure that transfers of your Personal Information out of the European Economic Area are adequately protected as required by applicable data protection law.

Last Updated: May 1, 2018