Medely Privacy Policy

Last Updated: November 14th 2015

Medely, Inc. (“Medely”) has created this privacy policy in order explain our privacy practices. The following discloses our information-gathering and\-dissemination practices for our Medely website (the “Site”), services and the Medely mobile application (collectively, the “Service”).

By using the Service, you do hereby warrant and represent that you have read, understand and agree to all terms and conditions stated herein, including ourTerms of Use, available at a href="https://medely.zendesk.com/hc/en-us/articles/215072787-Terms-Conditions-" http://www.medely.com/termswhich isincorporated herein by reference, which govern the use of the services offered by Medely, and that you are giving Medely permission to use and store suchinformation consistent with this privacy policy and our Terms of Service.

A user of the Service is hereinafter referred to as a “User,” or collectively, the “Users.”

Links and Information

This website contains links to other websites. Please review our Terms of Service, available at: https://medely.com/professional_terms and https://medely.com/facility_terms for more information.

Information Received by Medely

Personal Information. Medely collects personal information only if you voluntarily choose to share such information with Medely. You may browse the Sitewithout disclosing any personal information. However, in order for you to take advantage of particular opportunities provided through the Service, we mayrequire that you furnish personal information. When you register your account, sign up for newsletters, complete forms for optional programs, surveys,contests and other entries, and through communications transmitted through Medely, applications and your use of the Medely mobile application, we collectinformation including your name, address, phone number and email address. You also may choose to send Medely personally identifying information in an emailmessage containing information or inquiries about the Service.

Anonymous or Aggregated Data. Medely collects and stores certain data about the use of the Service on an aggregate and/or anonymous basis. Medely does notlink this information to anything personally identifiable to you.

Cookies and Other Technologies. When you visit websites on the Internet, your browser may automatically transmit information to the websites you visitthroughout every visit. Like many websites, we may use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’shard disk for record-keeping purposes. We may utilize persistent cookies that only Medely can read and use to save your login information for future loginsto the Service, to assist in processing items in your shopping basket, to hold session information, and to track user preferences. We may utilize sessionID cookies to enable certain features of the Service, to better understand how you interact with the Site and to monitor aggregate usage by our users andweb traffic routing on the Service, to track the number of entries in Medely promotions, sweepstakes and contests and to identify visited areas of the Siteand Service. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Site and Service and then close yourbrowser. Third party advertisers on the Site may also place or read cookies on your browser and we may use Flash cookies (or local shared objects) to storeyour preferences or display content based upon what you view on our site to personalize your visit. You can instruct your browser, by changing its options,to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you will not beable to use all portions or all functionalities of the Service. We and our service providers may also use "pixel tags," "web beacons," "clear GIFs," orsimilar means in connection with the Service and HTML-formatted email messages to, among other things, track the actions of Users and email recipients, todetermine the success of marketing campaigns and to compile aggregate statistics about Site usage and response rates. We may also engage one or more thirdparty service providers to serve online advertisements on our behalf. They may use a “pixel tag” to collect anonymous information about your visits to thisSite and to other websites, and they may use that information to target advertisements for goods and services. This information is collected anonymously,in a manner that does not personally identify you.

IP Address. When you visit and interact with the Site, Medely and/or third parties with whom Medely has contracted to provide services to Medely maycollect your Internet Protocol Address

(“IP Address”), which is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. This number isidentified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that youvisited. We use IP Addresses to monitor the regions from which Users navigate the Site and for fraud prevention purposes.

The Company also collects and uses personal data regarding its employees (“Employee Data”), which may include: name, address, job title and other jobinformation, location, compensation information, identification number, employment history, and a copy of employment agreements.

We may also require you to provide us with your financial information, including billing name, address , Bank account information and credit card number(“Financial Information”).

Only authorized Medely staff have access to your Personal Information in its entirety. Other staff may have access to portions of this information if itpertains to their job duties.

Medely's Use of Personal Information

Medely uses Personal Information for the following general purposes:

• to provide our products and the Service,

• for billing, identification and authentication, and fraud prevention,

• to analyze Site usage and improve our products and the Service,

• to contact you and deliver administrative notices and communications relevant to your use our products and services,

• for internal market research, troubleshooting problems, and detecting and protecting against error, fraud or other criminal activity,

• for distribution to third-party contractors that provide services to Medely and partners of Medely who are bound by privacy restrictions at least asrestrictive as those set forth in this Policy,

• to enforce our Terms of Service, and

• as otherwise set forth in the Policy.

Although we ensure that our third party agents (“Agents”) receiving your information are bound by privacy restrictions at least as restrictive as those setforth in this policy, Medely is not responsible for any issues that may arise regarding the Privacy Policies of any of its affiliates or advertiser. Byusing this website, you do hereby agree to hold Medely harmless from any claims and/or damages that may arise from the actions of any of its affiliatesand/or advertisers.

Two things drive Medely's decisions regarding the use of information collected from Users: 1) improving user experience by offering personalized services,content and advertising, and 2) market research.

Ads are a standard part of user experience on the Internet, and Medely believes that targeted advertising enhances this experience. Medely may use Cookiesand other Technologies and Personal Information to place ads where they believe interested parties will see them.

In addition to banner ads, Medely may advertise products, companies and events that we think might interest you through the email address you provide.

Medely may analyze Personal Information and Web Navigational Data based on your interests and may use the analysis from this information in a way thatdoesn’t reveal a User’s personal information (“Market Research”) in order to:

• Market the Service

• Improve the likelihood of a sale to a group of Users

• Increase the likelihood that a group's experience with the Service is relevant to its interests as a whole

Medely uses data at the individual level to sell products and services to Users who express an interest in these products and services, through a poll forexample, or to Users who can be presumed to have an interest based on results from our Market Research.

Medely may use your cell phone number to call or text you in order to provide the Service. If you would like more information about our policy, or to optout, please review our Terms of Service, available at http://www.medely.com/termsor email [email protected]\.

Employee Data is only used for the for the purposes of facilitating the performance of certain administrative tasks and functions relating to generalemployment and for processing and investigating reports under the Company’s codes and policies ( “Employee Data Purposes”).

We use Financial Information solely as authorized by you in accordance with the Service.

Choice/Opt-Out

You may opt-out of receiving communications from us and our partners, remove your information from our database, and choose to not receive futurecommunications unrelated to the Service.

During registration you choose whether to receive correspondence from either Medely or its partners and whether you want to participate in a variety ofMedely programs. This information remains on your Profile where you can, at any point, easily edit it to indicate that you have changed your mind. Afterlogging on, click on your profile on the top right of any page, then select “Notifications.” You may then click on "email alerts," and make yourselections. If you purchase anything through Medely, we may occasionally contact you with information about special events, sales, activities, promotions,contests, submission opportunities and programs. You always have the option to ask Medely not to contact you with this information again.

If you receive unsolicited email from a Medely domain, please contact us at [email protected]

Medely's information retention policy

To preserve the integrity of our databases, we may retain information submitted by Users for an indefinite length of time. If required by law, we willdelete Personal Information by erasing it from our database. We will also respond to User requests to delete or correct account or Personal Information,which you can do by contacting Medely at [email protected]or by selecting the “Notifications” optionunder your account icon in the top right corner of your home page or on your device.

Videos and Images of Medely’s

For each User seeking to provide services via the Service (each, a “Professional”) who has provided Medely with any videotape, film, record, photograph,voice, or all related instrumental, musical, or other sound effects, you consent to our use of these materials in accordance with the Terms of Use,available at http://www.medely.com/terms.

Medely’s security of collected information

Your Medely account is password-protected so that only you and authorized Medely staff have access to your account information. In order to maintain thisprotection, do not give your password to anyone. If someone who represents to you they are Medely staff and asks for any personal account information,including password, check their URL. If it doesn't say they are [email protected], they aren’t. Also, if you share a computer, you should sign out of yourMedely account and close the browser window before someone else logs on. This will help protect your information entered on public terminals fromdisclosure to third parties.

Medely makes every effort to ensure that your information is secure on its system by backing up data in separate back up drives and uses public key accessencryption and firewalls on both our main and backup servers. We also employ and customer record managers to protect against loss, misuse and alteration ofthe information under our control. Extremely sensitive information, like credit card numbers, is always transmitted in encrypted form. Only certainauthorized Medely staff can access Personal Information, and then only if it is relevant to their job duties. Medely has staff dedicated to maintainingthis Privacy Policy and other privacy initiatives, periodically reviewing security and making sure that every Medely employee is aware of our securitypractices. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, Medely cannot guarantee the security ofany information you transmit to us, and you do so at your own risk. While Medely will use commercially reasonable efforts to ensure the security of allcredit card and all other personal information, we expressly disclaim any liability for any unauthorized access to or use of our secure servers and/or anyand all personal and/or financial information stored therein, and you agree to hold Medely harmless for any damages that may result therefrom. If you haveany further questions on this issue, please refer to the Terms of Use, available at a href="https://medely.zendesk.com/hc/en-us/articles/215072787-Terms-Conditions-" http://www.medely.com/termsMedely expressly disclaims anyliability that may arise should any other individuals obtain the information you submit to this website.

With whom does Medely share information?

When you submit information to Medely, it is collected, processed and maintained solely by us or by third party agents who are bound by privacyrestrictions at least as restrictive as those set forth in this policy. We may allow our business partners to collect information about Users that is notextremely sensitive Information. If you would like to opt out from the onward transfer of your information to our non-agent partners, you may send us anemail at [email protected]Include the word "privacy" in the subject line of the email and all yourregistration information in the body of the email.

Some Medely content is "sponsored by" or "presented by" other companies. Medely shares market research data (how the sponsorship performed, names ofcontest winners, etc.) collected on this website or via email surveys with these partners. This information is aggregate and not linked to specific users.

Partners may sponsor promotions, contests and sweepstakes that require you to reveal details such as your name, address or phone number. Always check theirprivacy policy before revealing information about yourself. If you don't want these sponsors to have your personal information, you can choose to notparticipate.

Medely reserves the right to disclose Personal Information from both private and public areas of this website at our discretion, if required by law or ifwe are given reason to believe, in our sole discretion, that someone is causing injury to or interference with the rights of Users, the general public, orMedely, to comply with a judicial proceeding, court order or legal process.

We will not transfer to a non-Agent third party any Personal Information that is sensitive in nature, such as information specifying your medical or healthcondition, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership without your prior affirmative consent.

Finally, Medely reserves the right to transfer, sell and/or distribute all information collected through the Service to an affiliate, subsidiary, or thirdparty in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our business, assets orstock. We will use our best efforts to ensure that the new entity follows this Privacy Policy with respect to your Personal Information, as and to theextent required by applicable law.

How can Users edit their information?

Medely believes strongly in giving you the ability to access and edit your personal information. To update your personal info, click My Account at the topof any page. There you can view, update and correct your account information. You may edit your account information at any time -- all you need is yourusername and password.

So that we can protect the integrity of sensitive data, there are certain pieces of information, such as your age, that you cannot alter yourself. Forexample, since children under 18 are not allowed to register as Users, we need to take reasonable measures to preserve the accuracy of our Users' ages.Please contact us at [email protected]to find out how to change information you cannot access throughyour account.

Our databases automatically update any Personal Information you edit in your profile, or that you request we edit. Information transmitted through boards,chats, polls or through any other means remains in our databases and becomes the property of Medely upon submission.

Notification of changes

Medely's security and privacy policy are periodically reviewed and enhanced as necessary. This policy might change as Medely updates and expands theService. Medely will endeavor to notify you of these changes by email, but will not be liable for any failure to do so. Medely also encourages you toreview this privacy policy periodically. If you do not understand any of the terms or conditions of any of Medely's policies, you may inquire regarding thesame via email at a href="mailto:[email protected]?subject=" [email protected]

Users from outside the United States

Medely and its Service are based in the U.S., and the Company’s offices are headquartered in the U.S. Please be aware that information you provide toMedely that it obtains as a result of your use of the Service may be processed and transferred to the U.S. and be subject to U.S. law. The privacy and dataprotection laws in the U.S. may not be equivalent to such laws in your country of residence. By using the Website, participating in any of the Service, orby providing Medely with your information, you consent to this collection, transfer, storage, and processing of information to and in the U.S. Medely willtake all steps reasonably necessary to ensure that you data is treated securely in accordance with this Privacy Policy.

US-EU and US-Swiss Safe Harbor Framework

Medely complies with the US-EU Safe Harbor Framework and the US-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding thecollection, use, and retention of personal information from European Union member countries and Switzerland. Medely has certified that it adheres to theSafe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harborprogram, and to view Medely’s certification, please visit a href="http://www.export.gov/safeharbor/" http://www.export.gov/safeharbor/

In compliance with the Safe Harbor Principles, Medely commits to resolve complaints about your privacy and our collection or use of your personalinformation. European Union citizens with inquiries or complaints regarding this privacy policy should contact Medely at: [email protected]or Medely Privacy, 202 Bicknell Avenue, Santa Monica, CA 90049.

Medely will review all audit requests submitted in writing or through email for the purpose of determining whether or not its procedures and protocolsbeing used are consistent with the Safe Harbor Framework. It is Medely’s policy to routinely monitor and check its compliance procedures and protocols.Should Medely determine inconsistency with any such procedures or protocol, Medely will take necessary steps to address and correct the inconsistency. IfMedely is unable to resolve the conflict with the individual or customer/client filing the complaint, Medely, Inc. will comply with the EU Data ProtectionAuthorities (DPAs) to investigate unresolved complaints. Medely will self certify with the Department of Commerce for the purpose of renewing its SafeHarbor Privacy Policy on an annual basis and confirming its continued commitment to the protection and privacy of personal data.

How can I reach Medely staff?

If you have technical problems, questions or other issues related to your use of Medely, please click the link Contact Us on the home at the bottom of anypage of this website. You can also contact us at [email protected]

Medely's staff will respond to all requests sent through mail or email from Users and parents interested in knowing more about what personal information isstored on the Medely database, or if they want their personal information nullified, or have additional questions regarding privacy.

Contacting Us

If you have any questions about this privacy statement, the practices of this site, or your dealings with this website, you may contact us at [email protected]