EFFECTIVE AS OF JAN. 1, 2023 

Squid iQ Inc. (“Squid iQ”, “we”, “us” and/or “our”) operates the website at https://squid-iq.com/ (the “Site”) to provide information about our company and our platform, mobile applications, tools and other services designed to facilitate the gathering of information related to individuals’ health, fitness and other activities in order to aid such individuals and their healthcare providers and/or medical insurance providers (“Providers”) in making informed decisions about such individuals’ care (such platform, mobile applications, tools and other services, together with the Site, the “Service”). This Privacy Policy describes how Squid iQ collects, uses and discloses information from visitors to and certain users of the Service (“you,” “your”), including personally identifiable data and Health and Activity Data (as defined below) (such data collectively, “Personal Data”). 

Please be sure to read this entire Privacy Policy before using or submitting information through the Service. By using or submitting information through the Service, you are indicating that you agree to be bound by the terms of this Privacy Policy. This Privacy Policy is incorporated into Squid iQ’s Terms of Service (the “Terms of Service”). 

Access to and use of the Service by a Provider who is a Squid iQ customer (a “Customer”) and such Customer’s authorized users is subject to and governed by the agreement between Squid iQ and the applicable Customer executed by authorized representatives of each party (the “Customer Agreement”). Squid iQ may collect, use and disclose information from a Customer and such Customer’s authorized users as set forth in the Customer Agreement. If you would like more information about the Service or becoming a Customer, please contact us at info@squid-iq.com 

Information We Collect 

When you interact with us through the Service, we may collect Personal Data and other information from you, as further described below: 

Personal Data that You Provide through the Service: We collect Personal Data from you when you voluntarily provide such information, such as when you create a profile on the Service, use the Devices in connection with the Service (including, without limitation, the software featured on the Devices and/or platforms made available by the third-party providers of the Devices (collectively, the “Integrated Services”)), contact us with inquiries, enter information into our Site contact form, respond to one of our surveys or use certain features of the Service. If you are a Patient, when you create your profile we may ask you to provide your contact preferences, certain contact information, such as your email address and mobile telephone number, and other Health and Activity Data to us. Wherever Squid iQ collects Personal Data, we make an effort to provide a link to this Privacy Policy. 

By voluntarily providing us with Personal Data, you are consenting to our use of such information in accordance with this Privacy Policy. You represent that the Personal Data you provide to Squid iQ are true, accurate, current and complete, and that you have the authorization to provide such Personal Data to us. You acknowledge and agree that such Personal Data and other information that you provide to us may be transferred from your current location to the offices and servers of Squid iQ and the authorized third parties referred to herein located in the United States and you hereby consent to that transfer and the storage of your Personal Data in the United States. 

Other Information 

IP Addresses; Device ID Information: The requests you make to Squid iQ may contain your IP address (the Internet address of your computer). We may use Patients’ and other visitors’ IP addresses for various purposes, including to analyze and report upon usage of the Service; to diagnose and prevent service or technology problems affecting the Service; and to monitor and prevent fraud and abuse. If you access the Service on a mobile device, we may also collect your device identification number and request access to settings and location information for similar purposes. 

Location Information: We may collect and use your location information to provide certain functionality, content or services with location-based components. Location information includes, but is not limited to, any information we derive in order to identify your geographic position. We may collect location information from the computer or mobile device you use to access the Service, through certain third-party service providers or, if you are a Patient, through the Integrated Services or your Provider(s). 

We may also use your location information in an aggregate way, as described below in the “Aggregated Personal Data” section. 

If you are a Patient, you may be able to control the location information that is provided to us by changing the privacy settings of your mobile device to turn off the functionality to share the device’s location information with the Service. Please note that turning off location-sharing may affect certain features of the Service. If you have any questions about the privacy settings of your mobile device, we recommend that you contact the manufacturer or your mobile service provider for assistance. 

Non-Identifiable Data Related to Operation of the Service: When you interact with Squid iQ through the Service, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store such information ourselves or such information may be included in databases owned and maintained by Squid iQ affiliates, agents or service providers. The Service may use such information and pool it with other information to track, for example, the total number of users of the Service, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process. The Service currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. 

In operating the Service, we may use cookies, web beacons and similar technologies. A cookie is a piece of information that the computer that hosts our Service gives to your browser when you access the Service. Our cookies help provide additional functionality to the Service and help us analyze Service usage more accurately for research and marketing purposes. In all cases in which we use cookies, we will not collect Personal Data except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service’s features. In addition to cookies, we may use web beacons (also known as “clear GIFs”) to measure traffic to or from the Service and related browsing behavior and to improve your experience when using the Service. 

This Privacy Policy covers the use of cookies, web beacons and similar technologies by Squid iQ only. Uses of these technologies by third-party websites linked from the Service, including the Integrated Services and third parties with which we partner, are governed by each such website’s or the applicable Integrated Service’s privacy policy. 

Aggregated Personal Data: In an ongoing effort to better understand and serve our Customers, other users of the Service and communities of patients with chronic health conditions, Squid iQ conducts research on its user demographics and behavior based on the Personal Data we collect from you and the other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Squid iQ may share this research and related information in aggregated, de-identified and/or anonymized format with its affiliates, agents and other entities in the healthcare research and services entities, including without limitation insurance and pharmaceutical companies. For the avoidance of doubt, this aggregate information does not identify you personally. Squid iQ may also disclose aggregated, de-identified and/or anonymized information in order to describe our business and the Service to current and prospective business partners and Customers, and to other third parties for other lawful purposes. 

Our Use of Your Personal Data and Other Information 

Squid iQ uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email to ask a question or report an issue with the Service, we will use the Personal Data you provide to answer your question or resolve your problem. Squid iQ and its subsidiaries and affiliates (the “Squid iQ Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Service to help us improve the content and functionality of the Service, to better understand our users and to improve the Service. Squid iQ and the Squid iQ Related Companies may use this information to contact you in the future to tell you about features of the Service we believe will be of interest to you. If we do so, each marketing communication we send you will contain instructions describing how to “opt-out” of receiving future marketing communications. In addition, if at any time you wish not to receive any future marketing communications from us or you wish to have your name deleted from our mailing lists, please contact us as indicated below. 

Our Disclosure of Your Personal Data and Other Information 

We consider your information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below: 

Business Transfers: Squid iQ might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. 

Related Companies: We may also share your Personal Data with the Squid iQ Related Companies for purposes consistent with this Privacy Policy. 

Agents, Consultants and Related Third Parties: Squid iQ, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information and maintaining databases. When we employ another entity to perform a function of this nature, we only provide the entity with the information that it needs to perform its specific function. 

Legal Requirements: Squid iQ may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Squid iQ, (iii) act in urgent circumstances to protect the personal safety of you, us, other users of the Service or the public, or (iv) protect against legal liability. 

Your Choices 

You can visit the Service without providing any Personal Data. If you choose not to provide any Personal Data, you may not be able to use certain features of the Service. 

Exclusions 

This Privacy Policy applies only to Personal Data and other information collected from you by Squid iQ through the Service. As described above, Squid iQ may collect, use and disclose information provided to Squid iQ by a Customer and such Customer’s authorized users through the Service pursuant to the terms and conditions of the Customer Agreement, and such information will be displayed to such Customer along with your Personal Data via the Service. 

This Privacy Policy shall not apply to any unsolicited information you provide to Squid iQ through the Service or through any other means. This includes, but is not limited to, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Squid iQ shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution. 

Children 

Squid iQ does not knowingly collect Personal Data or other information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data or other information through the Service. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Service without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Squid iQ through the Service, please contact us, and we will endeavor to delete that information from our databases. 

Links to Other Websites 

This Privacy Policy applies only to the Service. The Service may contain links to other websites or services not operated or controlled by Squid iQ, including, without limitation, the Integrated Services (the “Third-Party Sites”). The policies and procedures we described here do not apply to the Third-Party Sites. The links from the Service do not imply that Squid iQ endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies. 

Security 

Squid iQ takes reasonable steps to protect the Personal Data provided via the Service from loss, misuse, and unauthorized access, disclosure, alteration or destruction. However, no Internet, email, or telephone transmission or communication is ever fully secure or error-free. In particular, email sent to or from the Service may not be secure. Therefore, you should take special care in deciding what information you send to us via such methods. Please keep this in mind when disclosing any Personal Data to Squid iQ. 

Other Terms and Conditions 

Your access to and use of the Service is subject to the Terms of Service. 

Changes to Squid iQ’s Privacy Policy 

The Service and our business may change from time to time. As a result, at times it may be necessary for Squid iQ to make changes to this Privacy Policy. Squid iQ reserves the right to update or modify this Privacy Policy at any time and from time to time. You should periodically visit this page to review the current Privacy Policy so you are aware of any revisions to which you are bound. If we make any revisions, we will post them on this page and will indicate at the top of this page the date this Privacy Policy was last revised. We will also notify you of any material changes, through a pop-up notice, email notification, in-Service notice or through other reasonable means. Any such changes will become effective immediately. Your continued use of the Service after the date any such changes become effective constitutes your acceptance of the new Privacy Policy. 

New Uses of Personal Data: From time to time, we may desire to use Personal Data for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Data in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.