Overview

Last Updated: April 15, 2024

This Privacy Policy covers all Selfii websites, services, and mobile apps (the “Services”). It applies to the Personal Information (defined above) we collect from your use of our services, website, or mobile application and through any other means by which you engage with us.

Selfii enables businesses to purchase technology services and enables individuals to collect, maintain, and share their health information as they choose. Please see Selfii’s Terms of Service for more details.

For individuals in Connecticut, Nevada, and Washington, please refer to the Connecticut, Nevada, and Washington State Consumer Health Data Privacy Policy for additional information about the processing of your personal data, and your rights under applicable U.S. State data privacy laws.

Information Selfii may collect

Account information for Selfii account creation & maintenance

When you sign up for and use the Services, we collect personal and business information from you for account creation and maintenance (“Account Information''). Such Account Information includes, as applicable or permitted under law, items such as your name, address, e-mail address, telephone number, your contact preferences, device identifiers, IP address, prior names, addresses, phone numbers.

Patient-specific information

Your health records and self-reported information

Selfii enables you to receive copies of your health information and medical records (“Health Records”) through the “right of access” granted to you under HIPAA or the laws applicable to where you are located, as well as through online portal accounts that may be made available to you by some health care providers, health plans, or independent app developers.

As part of the Selfii Service, you may choose to provide us with additional health information, medical records, as well as information not directly related to your Health Records, such as: (i) information about how you’re feeling at a specific time or progress pain management; (ii) other information you’ve shared with third parties, including caregivers, medical professionals and researchers; and (iii) data from wearables or home diagnostic equipment; or (iv) information your provide when you engage in blog discussions, message boards, chat rooms, and other forms of social networking and to post reviews and post content, such as messages relating to healthcare experiences, and interact with other users (collectively, “Self-Reported Information”).

Selfii enables you to receive your medical records. To do so we collect information such as name, birth date, gender, medical or health plan record numbers, or information about your doctors, medical providers and health plans. We will let you know at the time of collection when it is optional for you to provide certain information, and when it is necessary to use certain Services.

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices.

Identity verification

Before we can collect your health records on your behalf, we ask that you provide us with additional information to confirm your identity such as a copy of your driver’s license or other official government photo ID, and/or identifiers associated with your cell phone (e.g., country, device ID and Operating System) (collectively, the (“Identification Information'').

In order to verify your identity, we use a third-party identity verification provider that collects a copy of your official government photo ID and images of your face, which are analyzed and compared to your official ID. The third-party identity verification provider uses your official ID and images solely for purposes of identity verification for Selfii. Selfii does not collect, nor does it possess, the biometric information that is collected by this third party. For information on this third-party’s privacy practices, you can visit https://www.clearme.com/privacy-policy.

If you decide you want to enable friends or family members or others to have access to your Selfii account or to be a personal representative, we will collect personal information about those individuals to fulfill your request. Such information may include name, email, telephone, a health care proxy, a power of attorney, or other information used to confirm their identity and authority to represent you.

Billing information

When Selfii accepts payment for Services, we will use a third-party payment processor who, on our behalf, stores and processes your Billing Information, none of which is stored, used, or controlled by Selfii.

Examples:

Credit Card payment information (including billing address and card holder name)
Email
Phone Number

Consult the third party’s privacy policy, which will be made available as part of the checkout process, to learn more about how they handle information.

Other types of information Selfii collects

Product interaction and feedback

We may collect responses to surveys that we invite you to complete, search queries within the Services, and transactions you make regarding the Services. We collect product interaction and feedback that you provide to us through our Service to provide you with the Services, improve and enhance the Services, and conduct research and analytics.

Communications

From time to time, Selfii will send you emails that communicate information about your account or about products, Services, or offers that may be of interest to you. When you open one of these emails or click on links within the email, we may collect and retain information about your interaction with the email to provide you with future communications that may be more interesting to you.

You will have the option of opting out of email communications, except emails that Selfii reasonably deems are required by law or necessary to prevent or mitigate a security or fraud risk, or to continue to provide you with the Services.

Other information

We collect any other information you choose to include in communications with us, for example, when sending a message or submitting information through a webform.

How Selfii uses your information

Selfii may use your information to create and manage your Selfii account, and also for the following purposes:

To keep you posted on available clinical trials, research projects or other opportunities, updated products, Services, software, and upcoming events. You can opt out of these communications in the manner designated in the specific communication, within your account, or otherwise in the manner provided to you.

To understand how our users are using the Services.

To help us create, develop, operate, deliver and improve the Services, including tailoring features and content and development of new products and services.

When necessary, for loss prevention and anti-fraud purposes and account and network security purposes.

To create aggregate data regarding use of the Services (for example, number of individuals using the platform).

To send important notices regarding the Services including changes to our terms, conditions, and policies. It is not possible to opt out of receiving this information as long as you continue to have a Selfii account.

If applicable, locate your Health Records and help the providers and health plans accurately match and send the correct information to us for your Selfii account.

To analyze Health Records via machine learning and artificial intelligence to identify patterns; this allows us to understand the context of information contained in the records and to provide insights to individuals using Services based on aggregated data from their records. We may use this data to create dynamic patient groups who are interested in select opportunities to share data. We will not retain any information from your Health Records used to generate suggestions.

When you ask us to delete your account, your Account Information, Self-Reported Information, and Health Records will be deleted, and further access to your account and the Services will not be possible, in accordance with applicable law.

Selfii does not make decisions based solely on automated processing, including profiling, which have legal consequences for, or significantly affect, our users.

Selfii may access information about your use of our website or Services in order to create aggregate usage data, for both internal use and in some cases public dissemination. Such statistics will not contain any personal information about you or any Selfii users.

Text messages

You may opt-in to receive occasional text messages from Selfii to receive updates on our Services. Message frequency will vary. You agree that by providing your mobile phone number and opting in to receive text messages, you expressly consent to receive automated text messages from us to the mobile phone number you provide. Consent to receiving text messages is not required in order to be a Selfii user. Message and data rates may apply, and you should check the rates of your mobile carrier. Your mobile carrier is not liable for delayed or undelivered messages. You can opt out of receiving text messages by texting STOP in response to any text message. You can also text HELP and we will respond with instructions on how to opt-out of or sign up for text messages from Selfii. As we are located in the United States, international rates may apply depending on your location. We share your mobile phone number with service providers with whom we contract in order to send you automated text messages, but we will not share your mobile phone number with third parties for their own marketing purposes without your express consent. Contact us at legal@selfii.com if you have any questions about our text message program.

We may also use all of the above information to comply with any applicable legal obligations, to enforce any applicable terms of service, and to protect or defend the Services, our rights, the rights of our users, or others. Also, if you stop using our Services, we may continue to store information about your usage but without that information being connected to you or your identity.

When Selfii shares your information

Selfii may share data related to your usage of the Selfii Platform – including Account Information – as follows:

To comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise authorized by law.

To professional advisors, such as auditors, law firms and accounting firms.

To protect against fraudulent, malicious, abusive, unauthorized or unlawful use of or subscription to our products and Services and users from such use.

To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Selfii’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Selfii is among the assets transferred.

In connection with a bankruptcy, merger, acquisition or sale or other business transaction, involving all or a portion of our assets or business, user information will also be transferred as part of or in connection with the transaction.

To enforce any applicable terms of service.

When you request us to share certain information with third parties.

With service providers or third party contractors who need your information in order to perform Services or functions that enable Selfii to function as a company, including:

• Third-party verification companies. If we permit you to create a patient account, we will provide your Account Information (see above) to a third-party to verify your identity.
• Data analytics service providers. We also may from time to time share information about your website use with third party contractors who are assisting us in analyzing or operating the site
• Email marketing service vendors
• Cloud storage providers
• Payment processors
• Security vendors

With your consent , with our research partners, such as academic researchers, clinical research organizations and sponsors that facilitate and/or provide clinical trials, real world evidence studies or similar research engagements.

When you make a decision to share your data outside of Selfii–including Health Records–the data practices under this Privacy Policy will no longer apply to the information held by that outside entity. We recommend that you review and determine you are comfortable with that entity’s privacy policy prior to sharing your data (including Account Information and Health Records) outside of Selfii.

In any circumstance where your consent is sought prior to Selfii sharing personal information about you, you will be able to withdraw that consent at any time, provided we can individually identify you in such data.

Such withdrawal of consent will apply only to new uses or disclosures of personal information about you within a reasonable amount of time after Selfii has received the withdrawal or at such other time as required by applicable law.

Jurisdiction specific provisions

A. residents of US states

This section is applicable to residents of California, Colorado, Connecticut, Utah, Virginia, and other U.S. residents, and provides information as to how you may exercise your rights under the California Consumer Privacy Act of 2018 (“CCPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), and the Virginia Consumer Data Protection Act (“VCDPA”).

For individuals in Connecticut, Nevada, and Washington, please refer to the Connecticut, Nevada, and Washington State Consumer Health Data Privacy Policy for additional information about the processing of your personal data, and your rights under applicable U.S. State data privacy laws.

6.1 Categories of personal information

Selfii collects, and has collected in the 12 months prior to the effective date of this Privacy Policy, the following categories of Personal Information:

Identifiers, such as name, username, postal address, unique personal identifier, online identifier, IP address, your mobile device identifier, email address, account name, driver’s license.

Personal information described in subdivision (e) of Section 1798.80 of the California Civil Code not covered by an existing category (physical characteristics or descriptions).

Characteristics of protected classifications under applicable state or federal law, such as self-reported assigned sex at birth and birthdate. This also includes your Self-Reported Information you choose to disclose with us that is considered a legally protected class under applicable state or federal law.

Commercial information, such as products or services purchased, obtained, or considered or other purchasing or consuming histories or tendencies.

Internet usage information, such as your browsing history, search history, and information regarding your interaction with our sites and advertisements.

Geolocation data, such as location of your device or computer and any metadata associated with digital photographs uploaded, including the location, date, and time the photo was taken.

Sensory data, such as audio, electronic, and visual information (e.g., audio or video recordings you upload, recordings of calls with Selfii customer service or information you voluntarily disclose when doing consumer insights research with us)

Inferences derived from Personal Information, such as to create consumer profiles for the purposes of research, product development and marketing.

Sensitive Personal Information, such as driver’s license, account login information, racial or ethnic origin, and genetic data, depending on how you use the services. We do not use or disclose Sensitive Personal Information to infer characteristics about you, other than those inferences that are an inherent part of the Services, related to your healthcare

Some categories of information are collected only if you use certain of our Services.

6.2 Business purposes

Selfii uses the categories of Personal Information described in Section 6.1 for the following business purposes:

Providing, personalizing, improving, updating, and expanding Selfii’s Services;

Communicating to you about the Services;

Helping to ensure security and integrity of the Services; and

Marketing new products and offers from us or our business partners based on your interests.

6.3 Categories of sources of personal information

Selfii collects, and has collected in the 12 months prior to the effective date of this Privacy Policy, categories of Personal Information described in Section 6.1 from the following categories of sources

You, our user/visitor—this source of Personal Information depends on your use of the Services, including when you submit Self-Reported Information;

Health databases; or

third parties.

6.4 Disclosure of personal information for business purposes

Selfii discloses, and has disclosed in the 12 months prior to the effective date of this Privacy Policy, with the following categories of third parties the correlating categories of Personal Information for a business purpose. Categories of third parties and the categories of personal information we disclose:

Other Selfii users

(if you disclose your Personal Information on Selfii and connect to those users)

Identifiers;

Categories of personal information described in Section 1798.80(e) of the California Civil Code; and

Characteristics of protected classes under applicable state or federal law.

Selfii companies

Identifiers;

Categories of personal information described in Section 1798.80(e) of the California Civil Code;

Characteristics of protected classes under applicable state or federal law;

Commercial information;

Internet usage information;

Geolocation data;

Sensory data; and

Inferences.

Service providers

Identifiers and categories of personal information described in Section 1798.80(e) of the California Civil Code such as email address and unique personal identifiers generated by Selfii;

Characteristics of protected classes under applicable state or federal law (self-reported sex assigned at birth, birthdate) are disclosed to our partner laboratories;

Commercial information;

Internet usage information;

Geolocation data;

Sensory data; and

Inferences.

Research Partners

Identifiers;

Categories of personal information described in Section 1798.80(e) of the California Civil Code;

Characteristics of protected classes under applicable state or federal law;

Commercial information; Internet usage information; Sensory data; and

Inferences.

Law enforcement or other regulatory bodies

We do not voluntarily disclose your Personal Information to law enforcement or regulatory bodies. We require a valid legal process as described in Section 3 before we would provide any data to law enforcement.

6.5 Disclosure and advertising preferences

Selfii shares, and has shared in the 12 months prior to the effective date of this Privacy Policy, with the following categories of third parties the correlating categories of Personal Information for targeted advertising:

Marketing and advertising partners

Identifiers;

Commercial information;

Internet usage information;

Inferences.

We use cookies and similar tracking technologies to disclose information with our service providers and third-party partners for a variety of reasons, including to measure, target, and serve advertisements as further described in this Privacy Policy.

Under the laws in certain US jurisdictions, you have the right to opt out of our sharing of your Personal Information for online targeted advertising purposes. You can learn more about our practices and the controls we provide you, opt out of certain types of such sharing, or change your preferences for targeted advertising by emailing us at support@selfii.com . Selfii does not sell or share your Personal Information for other purposes.

6.6 Exercising your rights

6.6.1 Right to know.

You may have the right to request that we disclose what Personal Information we collect, use, disclose, or share. This includes the right to request the categories of Personal Information we have collected about you, the categories of sources of Personal Information, the business purpose for collecting, disclosing, or sharing Personal Information, the categories of third parties with whom we disclose or share categories of Personal Information, and the specific pieces of Personal Information we have collected about you.

If you are submitting a request to know on your own behalf, please email us at support@selfii.com . We are required to verify your identity before providing you with a copy of your data. We will require you to provide proof of identity and current address (e.g., you may be required to provide a copy of your government-issued ID, which will be used solely to verify your identity and address).

If you are an “Authorized Agent” pursuant to the CCPA/CPRA and are submitting a request to know on behalf of one of our users, see Section 6.6.3.

6.6.2 Right to delete.

You may have the right to request that we delete your Personal Information.

You may submit a request to delete your own information by email. To delete your Personal Information, you must delete your account and, once an account deletion request is completed, this process is irreversible. Your information will be permanently deleted.

To email your request to delete, email us at support@selfii.com . We are required to verify your identity before we delete your data. We will require you to provide proof of identity and current address (e.g., you may be required to provide a copy of your government-issued ID, which will be used solely to verify your identity and address).

If you are an “Authorized Agent” pursuant to the CCPA/CPRA and are submitting a request to know on behalf of one of our users, see Section 6.6.3.

6.6.3 Authorized agents.

In applicable jurisdictions, US residents can use authorized agents to make requests to know and requests for deletion. To use an authorized agent, email us at support@selfii.com . Note that even if you choose to use an authorized agent for a request, your may still need to work directly with us to provide:

Signed permission from the consumer allowing the authorized agent to act on the consumer’s behalf. Verification of the consumer’s identity (to be made directly by the consumer to us). We will require proof of identity and address (e.g., a copy of your government-issued ID, which will be used solely to verify your identity and address).

The report will be delivered to you via your Selfii account.

6.6.4 Right to appeal.

Depending on where you live, if your request to know or delete your data is denied, you may have the right to appeal. You can do so by contacting us at legal@selfii.com .

6.6.5 Right to correct.

You have the right to correct inaccurate Personal Information that we maintain about you. You can do so by visiting Account Settings or contacting us at support@selfii.com .

6.7 Selling.

To opt out of targeted advertising, please see Section 6.5.

6.8 Sensitive personal information.

We process sensitive personal information collected about you only to provide the Services, including to:

Maintain the quality and safety of the Services;

Improve the Services;

Detect security

incidents;

Resist and prosecute malicious, deceptive, fraudulent, or illegal actions directed at Selfii; and

Maintain or service accounts, provide customer service, process or fulfill orders and transactions, verify customer information, process payments, provide analytic services, and provide storage.

We may also process this sensitive personal information as needed to help ensure people’s physical safety and as required by applicable law.

6.9 Non-discrimination.

We will not discriminate against you for exercising any of your rights under applicable US privacy regulations.

6.10 California’s shine the light law.

California Civil Code Section 1798.83, known as the “Shine the Light” law, permits users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, Selfii currently does not share any Personal Information with third parties for their own direct marketing purposes. To make such a request, please send an email to support@selfii.com or write to us at Selfii Corporation, 2601 Blanding Avenue, #C-518, Alameda CA 94501.

6.12 Contact us.

If you have questions about our US-related privacy policies or practices, please contact us at legal@selfii.com .

B. Jurisdictions outside the United States

If you reside in a jurisdiction outside the United States such as the European Economic Area (“EEA”) or the United Kingdom (“UK”), collectively (“Global Jurisdiction”), the disclosures set out below apply to you in addition to the disclosures set out in the general sections of this Privacy Policy above.

For the purpose of applicable data protection laws, we are the data controller. Your information will be processed on the basis of the following legal bases:

Purpose: To keep you posted on available clinical trials, products, Services, software updates, and upcoming events. You can opt out of these communications in the manner designated in the specific communication or within your account.

Categories of data:

• Account Information
• Health Records
• Self-Reported Information

Legal Basis (Article 6): Consent

Legal Basis (Article 9): Explicit consent

Purpose:

For loss prevention and anti-fraud purposes and account and network security purposes.

Categories of data:

• Account Information

Legal Basis (Article 6): Our legitimate interests in maintaining the security and integrity of our systems and networks.

Legal Basis (Article 9): N/A

Purpose: To send important notices regarding Selfii products and Services, including changes to our terms, conditions, and policies.

Categories of data:

• Account Information – name, address, e-mail address, telephone number.

Legal Basis (Article 6): Our legitimate interests in keeping you up to date regarding the Services.

Legal Basis (Article 9): N/A

Purpose: To locate your Health Records and help the providers and health plans accurately match and send the correct information to us for your Selfii account.

Categories of data:

• Account Information – name, address, e-mail address, telephone number, prior names, addresses, phone numbers, birth date, gender, race or ethnicity, medical or health plan record numbers, and information about your doctors, medical providers, and health plans.

Legal Basis (Article 6): Consent

Legal Basis (Article 9): Explicit consent

Purpose: To analyze Health Records to offer you opportunities to share data (for example, with caregivers, with your medical professionals, to find treatment, or to power research).

Categories of data:

• Health Records
• Self-Reported Information

Legal Basis (Article 6): Consent

Legal Basis (Article 9): Explicit consent

Purpose: To allow you to engage in blog discussions, message boards, chat rooms, and other forms of social networking and to post reviews and post content, such as messages relating to healthcare experiences, and interact with other users.

Categories of data:

• Self-Reported Information

Legal Basis (Article 6): Consent

Legal Basis (Article 9): Explicit consent

Your rights.

If you are located in a Global Jurisdiction, you have certain rights, listed below, in relation to personal information about you.

Access: You have the right to access information we hold about you, how we use it, and who we share it with.

Portability: You have the right to receive a copy of the information we hold about you, in a structured, commonly machine-readable form, and to request that we transfer it to a third party, in certain circumstances, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others. and with certain exceptions.

Rectification/Correction: You have the right to correct any personal information about you we hold that is inaccurate.

Erasure: In certain circumstances, you have the right to delete the information we hold about you.

Restriction of processing to storage only: You have the right to require us to stop processing the information we hold about you, other than for storage purposes, in certain circumstances.

Objection: You have the right to object to our processing of personal information about you.

Objection to marketing: You can object to marketing at any time by opting-out using the unsubscribe/ opt-out function displayed in our communications to you.

Withdrawal of consent: You have the right to withdraw your consent at any time.

Submit a complaint: If you believe we have infringed or violated your privacy rights, please contact us at legal@selfii.com so that we can work to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in an EEA Member State of your habitual residence, place of work, or place of alleged infringement.

When we receive an individual rights request from you, please make sure you are ready to verify your identity. Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways: (i) where denial of access is required or authorized by law; (ii) when granting access would have a negative impact on other’s privacy; (iii) to protect our rights and properties; and (iv) where the request is frivolous or burdensome. If you have questions, if you would like to exercise your rights under the applicable law please contact us at legal@selfii.com .

Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests or where we are required by law to retain personal information about you.

To exercise any of these rights, you can contact us at legal@selfii.com . We will respond to requests to exercise these rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances).

Storage and transfer of personal information about you.

The information that we collect from you will be transferred to and stored at/processed in the US. Your information is also processed by staff operating in the US who work for us or one of our third-party service providers or partners. We will take all steps reasonably necessary to ensure that personal information about you is treated securely and in accordance with this Privacy Policy.We will retain personal information about you as follows:

Your Health Records and Self-Reported Information for as long as you keep your account open or as needed to provide you with our Services;

Your Account Information for as long as you keep your account open or as needed to provide you with our Services;

If you contact us, we will keep your data for as long as you keep your account open or as needed to provide you with our Services; and

Your Usage Information for as long as you keep your account open and as long as needed to provide our Services and usage metrics.

We will also retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes and enforce our terms and conditions, other applicable terms of service, and our policies.

C. Other locations around the world

If you live in another part of the world not specifically mentioned here and have a question, please contact us at legal@selfii.com .

Blogs, social networking, and education or promotional content

Selfii regularly publishes blog posts and invites any individual to sign up to receive these posts via email. Email addresses are collected from these individuals and used by Selfii or a contracted service provider solely to send these blog posts and other Selfii marketing or promotional material.

Note that individuals who create an account for the services will receive emails that contain newsletters, links to blog posts and other marketing or promotional content. Any individual – whether or not a Selfii account holder – may opt out of receiving any communications from us by following the unsubscribe link in the communications.

As noted above, the Selfii Service may from time to time allow you to store, display, reproduce, publish, or otherwise use certain Self-Reported Information related to blog discussions, message boards, chat rooms, and other forms of social networking (“Social Self-Reported Information”), and may or may not attribute it to you. These forums are accessible to others and such Social Self-Reported Information you post can be read, collected, shared, or otherwise used by anyone who accesses the forum. If you post Social Self-Reported Information to information sharing forums, including any information about your health, you are doing so by choice and you are providing consent to the disclosure of this information; your Social Self-Reported Information will be considered “public” and will be accessible by anyone, including Selfii.

Please note that we do not control who will have access to the information that you choose to make available to others, and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available on the features permitting creation of Social Self-Reported Information or what others do with information you share with them on such platforms. We are not responsible for the accuracy, use or misuse of any Social Self-Reported Information that you disclose or receive from third parties through the forums or email lists.