PRIVACY POLICY
Effective: May 30, 2019
Reviewed: Nov 30, 2021

This Privacy Policy (“Privacy Policy”) is between you, a user of any portion
of the Platform (sometimes referred to as “you” or “your”) and LifeBac, LLC
and its affiliates (collectively referred to as “LifeBac,” “our,” “we,” or “us”).
This Privacy Policy governs the collection and use of your information via
the LifeBac mobile application “Solution” and the LifeBac website located at
https://lifebac.com (the “Website”) (collectively, the "Platform").  The
Platform provides you access to certain telehealth services and
consultations related to alcohol use (“Services”) provided by the Providers,
as well as access to a peer support community and educational materials
related to alcohol use.  For purposes of this Privacy Policy, “Providers”
means, collectively, the licensed health care professionals that are affiliated
with or contracted by LifeBac to provide the Services through the Platform.
Agreement to Privacy Policy
PLEASE READ THIS PRIVACY POLICY CAREFULLY.  YOUR ACCESS AND
USE OF THE PLATFORM IS SUBJECT TO YOUR AGREEMENT WITH THE
BELOW POLICY, ALONG WITH THE PLATFORM TERMS OF USE.  BY
USING THE PLATFORM, YOU EXPRESSLY AGREE TO THE TERMS OF
THIS PRIVACY POLICY AND CONSENT TO THE COLLECTION AND USE
OF INFORMATION AS DISCUSSED IN THIS PRIVACY POLICY.
IF YOU DO NOT AGREE WITH THE BELOW POLICY, PLEASE DO NOT USE
OR ACCESS THE PLATFORM FOR ANY PURPOSE.  PLEASE PRINT A COPY
OF THIS PRIVACY POLICY FOR YOUR RECORDS.
Modifications to Privacy Policy
We may revise this Privacy Policy at any time and you should review it
frequently, as it may change from time to time.  We will strive to generally
provide users with notice by posting a notice regarding the new policy on
the Platform.  ANY CHANGES WILL BE EFFECTIVE IMMEDIATELY UPON
THE POSTING OF THE REVISED PRIVACY POLICY UNLESS OTHERWISE
STATED.
BY ACCESSING OR USING THE PLATFORM AFTER SUCH CHANGES ARE
POSTED YOU AGREE AND CONSENT TO ALL SUCH CHANGES.  IF YOU
DO NOT AGREE TO ANY CHANGES WE MAKE, YOU SHOULD
IMMEDIATELY STOP ACCESSING AND USING THE PLATFORM.
Applicability of this Privacy Policy
This Privacy Policy applies solely to the Platform and provides you
information on the specific information that LifeBac may collect from you
via the Platform and how we may use it.
Disclosure of Information Practices
If we collect information from or about you via the Platform, we will tell you
what information we are collecting either at the point of collection or via
this Privacy Policy.  The amount and type of information that we receive

depends on how you use the Platform and the information you choose to
submit to us via the Platform.
Information Collection
The Platform has the ability to collect three types of information from and
about you: (i) personally identifiable information; (ii) non-personally
identifiable information; and (iii) identifiable health information, all as
defined below.  We are the sole owners of the information collected on our
Platform.  We only have access to or collect information from you (i)
through your use of the Platform and/or the Services; or (ii) that you
voluntarily give us via your use of the Platform or other direct contact from
you.
Personally Identifiable Information
Our definition of personally identifiable information includes any
information that may be used to specifically identify or contact you, such as
your name, postal and email addresses, phone number or bank, debit or
credit card information.  In certain circumstances, we may request, allow,
or otherwise provide you an opportunity to submit your personally
identifiable information in connection with a feature, program, or some
other aspect of the Platform.  For instance, you may: (i) provide your name,
your address, your phone number, and your email address to register for
the Solution; (ii) provide certain demographic information about yourself
(e.g., age, gender, etc.) when participating in a survey or poll, or registering
or creating a profile through any aspect of our Platform; (iii) provide
payment information when providing payment via our Platform; (iv) post a
general comment, rating or review, and/or recommendation on our
Platform; or (v) when you request additional information about the Platform
by submitting your information to us or otherwise contacting us.  We may
track use of your user name and may also capture the paths taken as you
move from page to page (i.e., your "click stream" activity).  When you log in,
your user name and password will be logged by our system in an audit log.
Certain information may not be personally identifiable when standing alone
(e.g., your age), but may become so when combined with other information
(e.g., your age and name).  Whether or not you provide this information is
your choice; however, in many instances this type of information is required
to participate in the particular activity or service, realize a benefit we may
offer, or gain access to certain areas or content through our Platform.  In
addition, if you elect to send us your contact information, we will use your
contact information to provide you the information you requested and
otherwise communicate with you to respond to your inquiry.
Identifiable Health Information
Our definition of identifiable health information is any information about
your personal health and medical background including your alcohol use
and treatment history.  If you are a patient or the legal representative of a
patient, you must provide certain identifiable health information and
medical history in order to complete your registration on the Platform
and/or to request and receive Services.  We may also collect other

personally identifiable information in connection with your identifiable
health information, such as your name, address, e-mail address, gender,
birth date and phone number, as further described above.
If you are a registered patient user of the Platform, your identifiable health
information (or that of the patient for whom you are the legal
representative) will become accessible to us in order to provide you access
to such information and Services through the Platform.  This information
includes the information you provide to us for us to share with Providers
and information uploaded to the Platform by Providers related to any
Services.  Electronic health records are not permanently stored in the
Platform, but a temporary copy of them is displayed via the Platform when
you are logged in with your user name and password.[a]
As such, please note that when you register for the Platform, the
registration process requires you to choose a user name and password for
your account, which you should keep and maintain as confidential.  If you
disclose your user name and password to anyone else, you understand that
those individuals that have your user name and password will have access
to your identifiable health information and will be able to add to your
identifiable health information as though they were you.  You will be solely
responsible for all activities by users resulting from sharing or not
maintaining the confidentiality of your user name or password.
Non-Personal Information
Our definition of non-personal information is any information that does not
personally identify you.  Non-personal information can include certain
personally identifiable information that has been de-identified; that is,
information that has been rendered anonymous.  We obtain non-personal
information about you from information that you provide us, either
separately or together with your personally identifiable information.  We
also automatically collect certain non-personal information from you when
you browse or otherwise access the Platform.  This information can include,
among other things: your IP address or other unique identifiers that are
automatically assigned to your computer, mobile or other device used to
access the Platform; the type of browser you are using (e.g., Internet
Explorer, Firefox, Safari, etc.); the third party website from which your visit
originated; the operating system you are using (e.g., Vista, Windows XP,
Mac OS, etc.); the domain name of your Internet service provider; the
search terms you use on our Platform; the specific areas within our Platform
that you visit; and the time of day and duration of your visits.  We may
collect such information by tracking, or asking our third party vendor to
track, your click stream activity when such information is not tied to a
specific user name or account through the use of "cookie" technology or by
tracking internet protocol (IP) addresses, as explained below.
LifeBac maintains full rights to any information collected on the Platform,
and may freely collect, use and disclose such information unless prohibited
by this Privacy Policy or applicable law.
Information Collection Methods

A few of the methods and/or avenues that may be used to collect your
information include, without limitation, the following (as well as subsequent
technologies and methods later developed):
Cookies
Like most companies, we may use "cookie" technology on and off of the
Platform.  “Cookies” are small pieces of information that are stored by your
browser on your computer’s hard drive.  They enhance your online
experience by saving your preferences while you are visiting a particular
website.  The cookies do not contain any identifiable health information and
cannot profile your system or collect information from your hard drive.
When you view or access our Platform, we may place a cookie on your
computer, which may be either temporary or permanent.  Temporary
cookies are used to complete transactions with the Platform and for other
purposes such as counting the number of visits to our certain web pages.
These temporary cookies are eliminated when you exit your browser.
A permanent cookie may also be stored on your computer by your browser.
When you log in, this type of cookie tells us whether you've visited us before
or if you are a new visitor.  The permanent cookie doesn't obtain any
identifiable health information about you or provide us with any way to
contact you, and the cookie doesn't extract any information from your
computer.
The "help" portion of the toolbar on most browsers will tell you how to
prevent your browser from accepting certain types of cookies, how to have
the browser notify you when you receive a new cookie, or how to disable
cookies altogether.  Please note that disabling temporary cookies may
prevent you from using and accessing the Platform.  Disabling permanent
cookies may also impact your use and access of the Platform and in
particular will not allow you to see any personalization on the Platform that
you may activate.  In addition, if you visit our Platform again after deleting a
cookie, a new cookie may be activated.
Some of our business partners may use cookies on our Platform.  Since third
parties may use their own cookies, for example when you click on a
hypertext link to their site or service, and since we have no access to or
control over these cookies, you should carefully review the Privacy Policy of
other sites you link to from our Platform.
IP Addresses
An IP address is a number that is assigned to your computer, mobile or
other computing device whenever you are surfing the Internet.  We may
also log and track IP addresses for systems administration purposes, to
report non-personal aggregate information to others, and for reporting
usage trends.  Your IP address is usually associated with the physical place
from which you enter the Internet, the name of the domain and host from
which you access the Internet, the browser software you use and your
operating system, and may also depend on the date and time you access the
Platform.  By collecting your IP address, we may record the page that linked
you to the Platform, the web pages you visit, any external links or content

you click on, and other information about the type of web browser,
computer, platform and settings you are using, and any search terms you
enter on the Platform.  This information also helps us determine how often
different areas of the Platform are visited.
IP addresses are considered non-personal information and may also be
shared as provided in this Privacy Policy. We may combine non-identifiable
information collected automatically (such as through IP addresses) with any
previously submitted personal information that we may have received from
you.
Web Beacons
Web beacons are small graphic images or other web programming code
that may be included in our Platform pages or other areas of the Platform.
Web beacons are tiny graphics with a unique identifier, similar in function
to cookies, and are used to track the online movements of users of our
Platform.  Unlike cookies, which are typically stored on your computer or
mobile device’s hard drive, web beacons are embedded invisibly on web
pages.  Web beacons or similar technologies help us better manage content
on our Platform by informing us what content is effective, counting the
number of users of the Platform and monitoring how users navigate the
Platform or counting how many e-mails, articles or links  were actually
opened or viewed.
Embedded Scripts
An embedded script is programming code that is designed to collect
information about your interactions with the Platform, such as the links you
click on.  The code is temporarily downloaded onto your computer, mobile
or other device from our server or a third party service provider.
Secure Messaging, Email and Other Communications
As a registered user of the Platform, you may also choose to use the secure
messaging feature of the Platform which allows the exchange of
communications between patients and Providers and which may contain
identifiable health information.  Communications sent via this feature are
recorded and maintained by us.  Platform users have the ability to view the
trail of messages received and sent via their Platform account.  We do not
edit the content of the communications between patients and Providers, and
you and the Provider are solely responsible for the content of any
communications.
If you send us an email with questions or comments, we may use your
personally identifiable information to respond to your questions or
comments, and we may save your questions or comments for future
reference.  For security reasons, we do not recommend that you send non-
public personal information, such as passwords, credit card information,
social security numbers or bank account information, to us by email.  In
certain instances, we may provide you with the option to set your
preferences for receiving email communications from us; that is, agree to
some communications, but not others.  We reserve the right to send you
transactional emails such as customer service communications or receipts

and information regarding our products and services including but not
limited to upgrades, offers, promotions and new products. We will not share
this information and will not telemarket 3rd party products using this
information.
If you elect to provide us an email address, you expressly consent that we
can provide these communications to you via email.
As a registered user of the Platform, you may engage in conversations and
post within an online peer support community on the Platform.  You
understand that all registered users of the Platform will have the ability to
view and freely use any such posted content, and other users’ use and
disclosure of information within such postings is not within the scope of this
Privacy Policy.  We will treat posts within the Platform’s support community
as personally identifiable information, but, even though such postings may
relate to your health or alcohol use, such postings will not be considered
identifiable health information.
Information from your Mobile Device
We may also use technologies, such as location based information, to
provide you with tailored information and features as you use our Platform.
When you access the Platform on your mobile device, including, but not
limited to, mobile phones and tablets (“Mobile Device”), we may obtain
information from your Mobile Device about the type of Mobile Device you
are using.  We may use this information to notify you of features and
products that may be available on your Mobile Device.  Certain features
may require our collection of the phone number of your Mobile Device.  We
may link that phone number to the Mobile Device identification information,
but will not use that number for telemarketing. We reserve the right to send
you transactional SMS/text messages such as customer service
communications or receipts and information regarding our products and
services including but not limited to upgrades, offers, promotions and new
products. We will not share this information and will not telemarket 3rd
party products using this information
Geographic Location
We may collect your geographic location based on your IP address and
other location-based data that you provide to us.
In addition, some mobile network providers (“Mobile Provider”) in the U.S.
are required to use programs that track the physical location of Mobile
Devices that use their service.  Depending on your Mobile Provider and
Mobile Device, we may automatically receive this information.  If we begin
to offer services that use this tracking (“pinpointing”) information, we will
obtain your consent (an opt-in) before using the information.  After
obtaining such consent, we may use and store this information to provide
location-based services, including location-targeted advertising.  Most
Mobile Devices provide users with the ability to disable location services.

These controls are usually located in the Mobile Device's settings menu.  If
you have questions about how to disable your Mobile Device's location
services, we recommend you contact your Mobile Provider or your Mobile
Device manufacturer.
Analytics
We may also collect information using a variety of reports from web traffic
and web performance analytics companies to improve our Platform.  This
information allows us to better understand users of the Platform and to
customize the Platform while also tracking our success at reaching new
audiences.

Surveys
Users of the Platform may have the opportunity to participate through the
Platform in various surveys regarding use of the Platform and receipt of the
Services.  Any survey responses that you choose to submit may be
aggregated, de-identified and provided or sold to third parties as set forth
below.  Participation in any such surveys is voluntary and not required for
your use of the Platform.

How Will Your Identifiable Health Information Be Used And Disclosed?
We may use any identifiable health information or other information that
you voluntarily provide us in order to provide you with information,
products or services (including the Services) that you may request from us
or the Providers.

If you are a patient or the legal representative of a patient, any identifiable
health information that you share via the Platform will be made accessible
to the Providers and will become a part of the records maintained by us on
behalf of the Providers, which records will be kept confidential and only
used and disclosed with your consent or as permitted by applicable law.
Any information generated by the Providers in providing the Services will
be provided back to us by the Providers and will also become part of the
records maintained by us.  LifeBac has no control over or responsibility for
the Provider’s use or disclosure of information that you may provide via the
Platform.

We may also use your identifiable health information and personally
identifiable information to send you reminders or other notifications
regarding the including transactional emails such as customer service
communications or receipts, communication from medical providers, and
information regarding our products and services including but not limited to
upgrades, offers, promotions and new products. We will not share this
information and will not telemarket 3rd party products using this
information.  If you elect to provide us a cell phone number, you expressly
consent that we can provide these communications to you via text message.
Data or text charges may apply.
We will share your identifiable health information with the Providers and
our affiliates, suppliers and vendors to the limited extent necessary or
helpful to provide the Platform and the Services.  We require those
suppliers and vendors to comply with all applicable data privacy laws and

regulations regarding protection and use of identifiable health information.
We do not sell, lease or rent your identifiable health information to
unaffiliated third parties.

Aggregate Data
We may aggregate and de-identify identifiable health information to create
anonymous "aggregate data" regarding the users of our Platform.
Aggregate and de-identified data is information that describes the habits,
treatment plans, usage patterns and/or demographics of users as a group
but does not reveal the identity of particular users.  This data will not
identify you, but will be used as statistical information to determine such
things as user demographics and usage patterns of our Platform.  LifeBac
may use aggregate data to understand the needs of our community of users
and determine what kinds of programs and services we can help provide.
Aggregate data may also be provided or sold to third parties, including to
give third party vendors, suppliers, business partners and/or affiliates a
picture of our community and services.
How Will Your Other Information Be Used And Disclosed?
To the extent permitted by applicable law, we may use your information to
communicate to you special offers and featured items from us, from our
affiliates, from third parties, and/or from other suppliers and vendors.  If
you are receiving additional communications and special offers, you may
revoke your authorization to receive such materials from us via the Platform
at any time by contacting us using the contact information below or as
outlined in the applicable communication.  We will implement your
revocation as soon as is commercially reasonable.  We cannot control any
communications and other materials that you may receive directly from
third parties.
We will also use your information to customize your browsing experience
and communicate with you and otherwise respond to your questions and
suggestions regarding use of the Platform as may be permitted by
applicable law.  This includes sharing your information with our suppliers
and vendors and used in the aggregate to create summary statistics that
help us analyze Platform usage trends, assess what information is of most
and least importance, determine technical design specifications, arrange
the Platform in the most user-friendly way, and identify system performance
or problem areas.
We may also use your geographic location to provide you with specific
content and direct you to your closest service providers to the extent
permitted by applicable law.
In addition to the foregoing, we or the third party contractors providing
services on our behalf may use your personally identifiable information or
non-personal information as follows:
When required by law or court order;
To provide you with information or services or process transactions
that you have requested or agreed to receive;

To process your registration with the Platform, including verifying
your information is active and valid;
To improve the Platform, to customize your experience with the
Platform or to serve you specific content that we believe is relevant to
you;
To enable you to participate in a variety of the Platform’s features;
To contact you with regard to your use of the Platform and, in our
discretion, changes to the Platform and related policies;
For inclusion in our data analytics and to improve our success in
marketing, research and promoting the Services;
For purposes disclosed at the time you provide your information or as
otherwise set forth in this Privacy Policy;
To protect or defend our legal rights or property, our Platform or
other users; and
During an emergency to protect the health and safety of our users or
the general public.
Except as described in this Privacy Policy, we will not share any of your
information with any third party outside of other users of the Platform (for
information that you make publicly accessible within a community on the
Platform); outside of our organization, including our affiliates and related
companies, our contractors, vendors, consultants and professional advisors
to the extent necessary for them to perform services on our behalf; and
outside of persons or entities with whom we have marketing, business or
other relationships.  For example, we may use a third party credit card
processing company to bill users for products and services.
Transfer of Data
In the event of a change in control of LifeBac or sale by LifeBac of
substantially all of its assets or other acquisition, sale, merger or
reorganization, any information owned by or in our control may be
transferred and/or sold to such successor.

Security
When you submit information to us through the Platform, you should be
aware that your information is transmitted across the Internet and that no
method of transmission over the Internet is completely or 100% secure.
While we cannot guarantee security, we maintain reasonable physical,
administrative, electronic, technical and procedural safeguards to help
protect your information collected via the Platform, as required by
applicable law.  While we take reasonable precautions to protect your
information, you also need to ensure you take appropriate steps to protect
your information.  Please be advised, however, that while we strive to
protect your personally identifiable information, other information and
privacy, we cannot and do not guarantee or warrant the security of any
information you disclose or transmit to us online, and we are not
responsible for the theft, destruction or inadvertent disclosure of your
personally identifiable information or any other information.

In the event that a breach in our security systems occurs and there is a
possibility that an unauthorized person acquires your personal information,
we will notify you of such a breach if we are required by applicable law to
do so.  However, delays in notification may occur while we take necessary
measures to determine the scope of the breach and restore reasonable
integrity to the system as well as for the legitimate needs of law
enforcement if notification would impede a criminal investigation.  From
time to time, we evaluate new technologies for protecting information and,
when appropriate, we upgrade our information security systems.
In order to help maintain security, you should never share your user name
or password and should always sign out when you are finished using the
Platform.

Access
We will maintain your information and if you are a registered user of the
Platform, allow you to request updates at any time by logging into your
Platform account to access your information.  We will also take steps to
make sure that any updates that you provide are processed in a timely and
complete manner.  You may opt out of any future contacts from us at any
time. You can do the following at any time by contacting us via the email
address given below:
See what data we have about you, if any.
Change/correct any data we have about you.
Have us delete any data we have about you.
Express any concern you have about our use of your data.
Please note that we may not be able to change or delete any identifiable
health information about you, as we maintain your identifiable health
information as required by the applicable agreement between us and the
Providers and in accordance with laws applicable to LifeBac’s business.  If
you need to request any changes to your identifiable health information, you
will need to contact the Provider directly.

Third Party Websites
Our Platform may contain links to other, third party sites that we do not
control or maintain.  If you use the Platform to link to another website,
which is not controlled or maintained by LifeBac, please be aware that we
are not responsible for the content or privacy practices of such other sites.
You may disclose personal and other information at that third party website,
and we cannot and will not be responsible for the protection and privacy of
any information that you provide while visiting such websites.  For example,
you might provide your contact information to obtain an information packet
from an organization.  Please be aware that in contacting that site, or in
providing information on that site, that third party may obtain personal
information about you.  This Privacy Policy does not apply when you leave
the Platform and go to a third party website from the Platform.  We
structure the Service so that no personal or health information goes in the
search string or URL when you move from the Platform to a linked website.

We encourage you to be aware when you leave our Platform and to read the
privacy statements of each and every site that you visit.

Your California Privacy Rights
California Civil Code Section 1798.83 permits users that are residents of
California to request the following information regarding our disclosure of
your personal information to third parties for those third parties’ direct
marketing purposes: (i) a list of certain categories of personally identifiable
information that we have disclosed to certain third parties for their direct
marketing purposes during the immediately preceding calendar year; (ii)
the identity of certain third parties that received personally identifiable
information from us for their direct marketing purposes during that
calendar year; and (iii) examples of the products or services marketed (if we
have that information).  If you are a California resident and would like to
make such a request, please contact us at the address below (at the bottom
of this Privacy Policy).

What if I am accessing the Platform from outside of the United States?
Our Platform is hosted in the United States and is governed by United
States law.  If you are visiting our Platform from outside the United States,
please be aware that your information may be transferred to, stored or
processed in the United States, where our servers are located and our
central database is operated.  The data protection and other laws of the
United States and other countries might not be as comprehensive as those
in your country, but please be assured that we take steps to protect your
privacy.

By using the Platform, you understand and expressly consent that your
information may be transferred to our facilities and to the facilities of those
third parties with whom we share your information as described in this
Privacy Policy.

Important Note Regarding Children
The Website and Platform is not directed toward children under 18 years of
age and LifeBac does not knowingly collect information from children under
18 through the Platform.  We urge all parents or guardians to participate in
their children’s exploration of the Internet, and to teach their children about
protecting their personally identifiable information while online.  If you use
the Platform, you hereby represent and warrant that you are at least 13
years of age.  Any information submitted via the Platform regarding a minor
under the age of 18 must be submitted by the minor's legal representative.
In compliance with the Children’s Online Privacy Protection Act, any
information we receive from users we believe to be under the age of 13 will
be purged from our database.

Sole Statement of Our Privacy Policy
This Privacy Policy is the sole statement of our Privacy Policy with respect
to our Platform, and no summary, modification, restatement or other
version thereof, or other privacy statement or policy, in any form, is valid
unless we post a new or revised policy.

What if I have questions or concerns regarding this Privacy Policy?

If you have any questions about this Privacy Policy or the use of your
information by LifeBac, please contact us at:
LifeBac, LLC
8911 W Charleston Blvd, Las Vegas, Nv, Suite 2-837, 89117.
legal@lifebac.com