PRIVACY POLICY

This California Privacy Notice applies to any California residents about whom we collect personal data (“consumers”). The provisions contained within this section are intended to provide notices in compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Any capitalized term used and not otherwise defined below has the meaning assigned to it in our Privacy Policy.

For the purposes of this California Privacy Notice, except where a different definition is noted, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available information, information that has been de-identified or aggregated, or other information subject to certain federal and state regulation. For purposes of this section, “publicly available information” includes: information is made available from federal, state, or local government records information that a business has a reasonable basis to believe is lawfully available to the general public, either through widely distributed media, or by the consumer and information that is made available by a person to whom the consumer has disclosed the information if the consumer has not restricted the information to a specific audience. Personal information does not include publicly available information, information that has been de-identified or aggregated, or other information subject to certain sector-specific privacy laws such HIPAA and the California Medical Information Act (“CMIA”).

This section does not apply to information that Kandu may collect in its capacity as a service provider or business associate for another entity. We encourage you to review the privacy policies and notices of your healthcare provider to learn more information about how it is collected, used, and shared, and what rights you may have regarding that information.

If you are a visually-impaired customer, a customer who has another disability or a customer who seek support in other language, you may access this California Privacy Notice by emailing us at [email protected].

1. Personal Information We Collect
   Over the last twelve (12) months, we have collected the following categories of personal information from consumers:
   • Identifiers, including your first and last name; email address; phone number; physical address; user ID; date of birth; online identifiers as detailed below including IP address or device IDs; and/or other similar identifiers.
   • Payment and financial information, including your health insurance information, credit or debit card number and related payment card information; bank account and routing number; and/or other financial information.
   • Professional or employment-related information, including your employer name, employment history, professional licenses or registrations, or employment identification number.
   • Commercial information, including Services that you have purchased, obtained, or considered; and/or other purchasing or consumer histories, tendencies, and preferences.
   • Information relating to Internet activity or other electronic network activity, which includes Cookies, as discussed further in our Cookie Policy.
   • Audio, electronic, visual, or similar information, which includes voice recordings, photographs, and other user-generated content that you submit to our Sites.
   • Information not listed above and related to characteristics protected under California or federal law, which may include gender or gender identity; race or ethnicity; disabilities; information related to employment and other social determinants of health, and/or medical and health-related information, including stroke cause, stroke status, stroke treatment, and underlying health conditions.
   • Inferences based on the above information.
2. What We Do With Your Personal Information
   Kandu may collect, use, or disclose Personal Information about you for the following purposes:
   • To provide you with requested Services, as they are described when you first register on our Sites and as may be offered over the course of your use of our Sites;
   • To facilitate and support our community features;
   • To provide you with customer service and support, and to facilitate other communications that you request or that are required to render Services to you;
   • To process payments;
   • To provide you with information about new Services and other opportunities that we believe may be of interest to you, whether offered by us or third-party partners, and to personalize, measure, and improve such offers;
   • To perform analytics for new and existing Sites and Services, such as our user accounts and related features;
   • To maintain and improve the quality of our Sites and Services;
   • To grow our business, including to perform research and development, understand our user trends, and understand the effectiveness of our marketing;
   • To protect ourselves, you, and others; prevent fraud and other unlawful or unauthorized activity; and create and maintain a trusted, secure, and reliable online environment; and
   • To comply with our legal obligations; respond to subpoenas, court orders, or legal process; and to establish or exercise our legal rights or defense against legal claims.
3. Sources of Collected Personal Information
   We may collect personal information from the following categories of sources:
   • From you, including via our Sites (including the Kandu Health App), in person, telephone, and/or social media.
   • From your healthcare provider, such as your hospital or other provider.
   • From Kandu’s parent company, Imperative Care, and affiliated entities.
   • Through our service providers, such as non-affiliated companies who help us provide Sites and Services to you
   • From our business partners and others, including those that may promote and/or offer products and services that may be of interest to youWe may supplement the information described above with information we obtain from other sources, including from both online and offline data providers.
4. Who We Share Personal Information With
   We limit our disclosure of the categories of personal information above to our service providers for one or more business purposes. “Business purposes” means the reasonably necessary and proportionate use of personal information for our operational purposes, other purposes described in this Privacy Policy, for the operational purposes of our service providers and contractors, as well as other purposes compatible with the context in which the personal information was collected. We do not and have not sold personal information to third parties for any monetary value. However, our use of certain Cookies (such as on www.kanduhealth.com and the Kandu App) for cross-context behavioral advertising purposes is considered a “sale”/”share” of personal information as defined under California law. As a reminder, we do not collect personal information via Cookies on www.kandustroke.com. We do not sell personal information of minors under 16 years of age.
5. Sensitive personal information. Certain of the personal information that we collect may constitute “sensitive personal information” as defined by California law, including account log-in information, mental or physical health condition or diagnosis, or personal information collected or analyzed concerning health.
6. Your California Privacy Rights
   If you are a California resident, you have the following rights under applicable California law in relation to your personal information, subject to certain exceptions:
   • Right to Know and Access. You have the right to know what personal information we collect, use, disclose, and sell and/or share, as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
   • Right to Delete. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal information that we collect about you.
   • Right to Correct. You have the right to require the correction of inaccurate personal information that is collected by us.
   • Right to Limit Use and Disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide goods or services to you. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
   • Right to Opt-Out of Sale and/or Sharing. You have the right to opt-out of the sale and/or sharing of your personal information by a business.
   • Right to Non-Discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
   • Sharing with third parties for their own direct marketing purposes. We do not disclose this personal information to third parties for their own purposes without your consent. If you wish to request information regarding such practices under California’s “Shine the Light” Law, please Contact Us via email or mail. You must include your full name, email address and postal address in your email or mail request so that we can verify your California residence and respond.How to exercise your rights. You may exercise any of the rights described in this section by following the instructions in Exercising Your Privacy Rights above.
7. Notice of Right to Opt-Out
   As mentioned above, we “sell”/“share” a limited set of personal information with third parties, as those terms are defined by the CCPA, through our use of certain Cookies (such as on www.kanduhealth.com). We do not “sell”/”share” personal information via Cookies on the Kandu Mobile App or on www.kandustroke.com. If you wish to opt-out of the “sale”/“sharing” of the limited personal information that is gathered via Cookies when you visit the Sites, please exercise your preferences to do so on our Sites or by emailing us at [email protected].
   However, our use of certain Cookies (such as on www.kanduhealth.com and the Kandu App) may be considered a “sale”/”share” of personal information as defined under California law. As a reminder, we do not collect personal information via Cookies on the Kandu Mobile App or on www.kandustroke.com.

We will continue to update our business practices as direct regulatory guidance becomes available.