PRIVACY NOTICE

Last updated 10-22-2024

Power Life Sciences, Inc. ("Power," "we," "our," and/or "us") values the privacy of individuals who use our website, and related online or offline services (collectively, our "Services" or "Platform"). This privacy notice (the "Privacy Notice") explains how we collect, use, and share (collectively, “process”) personal information. Your use of our Services is also subject to our Terms of Service (https://www.withpower.com/terms-of-service).

We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and/or we may also send other communications as required by applicable law.

Disclosure Regarding the Supplemental Consumer Health Data Privacy Notice. For information on our processing of “consumer health data” subject to the Washington My Health My Data Act or Nevada Consumer Health Data Privacy Law, please see Annex A – Supplemental Consumer Health Data Privacy Notice.

1. Personal Information We Collect
2. How We Use Personal Information
3. How We Disclose the Personal Information We Collect
4. Your Privacy Rights and Choices
5. Third Parties
6. Security
7. Children
8. International Transfers of Personal Information
9. Accessing/Updating Your Personal Information
10. Contact Us

Annex A – Supplemental Consumer Health Data Privacy Notice

PERSONAL INFORMATION WE COLLECT

We collect personal information you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

1. Personal Information You Provide to Us

• Account Creation. When you create an account, we collect the information you provide to us, such as such as your name, email address, phone number, date of birth, and address. We will also collect health information that you provide to us.

• Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).

• Communications. When you communicate with us or our service providers, such as through email, our AI-supported chat tool, or customer support, we collect the information you provide to us.

• Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.

• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public.”

• Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.

• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.

• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

• Careers. If you apply for a job with us, we will collect the personal information you provide to us, such as your contact information and resume information.

1. Information Collected Automatically

• Location Information. When you use our Services, we infer your general location information, for example, by using your internet protocol (IP) address.

• Device Information. We may collect information about the device and software you use to access our Services, such as your Internet Protocol (IP) address, user settings, cookie identifiers, other unique identifiers, web browser type, operating system version, internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geolocation information), phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.

• Usage Information. We may collect information about your use of and interactions with our Services, such as the pages or other content you view, the searches you conduct, and the dates and times of your visits, and other information about how you use the Services.

• Information from Cookies and Similar Technologies. We and third-party partners may collect personal information using cookies, pixel tags, or similar technologies (“Technologies”).

• Cookies. Cookies are small text files stored in device browsers. We may use both session cookies and persistent cookies.

• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

  See “Your Privacy Rights and Choices” below to understand your choices regarding these Technologies.

1. Information We Collect from Third Parties

We may receive additional information about you, such as demographic data, from third parties such as data or marketing partners and combine it with information we have about you. Also, if you access the Services using a Third-Party Service (defined below), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, users of the Services may upload or otherwise provide personal information about others.

HOW WE USE PERSONAL INFORMATION

We may use personal information for business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

1. To provide our Services, including:

• Managing your information;

• Responding to requests for support;

• Communicating with you;

• Personalizing your experience on our Services such as by providing tailored content and recommendations;

• Delivering personalized recommendations through the use of artificial intelligence and machine learning capabilities;

• Sharing personal information with third parties as needed to provide the Services;

• Processing job applications;

• Allowing you to register for events;

• Allowing you to apply to clinical trials; and

• Allowing you to manage your clinical research profile

  Some of our Services are enabled by machine-learning tools fundamental to our ability to provide real-time engagement. These machine-learning tools process natural language communications to support user experience and deliverables.

1. For administrative purposes, such as:

• To understand and analyze how you use our Services and develop new products, services, features, and functionality;

• For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;

• To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use to publish reports;

• To send you text messages and push notifications;

• To facilitate transactions and payments;

• To find and prevent fraud, and respond to trust, safety, and/or security issues that may arise;

• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency;

• To create an anonymous profile for you on our Local Patients Registry, if you opt-in to this service; and

• For other purposes for which we provide specific notice at the time the information is collected.

HOW WE DISCLOSE THE PERSONAL INFORMATION WE COLLECT

We may disclose any of the personal information we collect to the categories of third parties described below.

1. Vendors and Service Providers. We may share any personal information we receive with vendors and service providers retained in connection with the provision of our Services. This may include, but is not limited to, service providers that provide us with hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features. Some of the service providers we use may include:

• Google Analytics. For more information about how Google uses your personal information, please visit Google Analytics’ Privacy Notice. To learn more about how to opt-out of Google Analytics’ use of your personal information, please click here.

• LinkedIn Analytics. For more information about how LinkedIn uses your personal information, please visit LinkedIn Analytics’ Privacy Policy. To learn more about how to opt-out of LinkedIn’s use of your information, please click here.

• Hotjar (Session Replay Analytics). We use Hotjar’s session replay analytics services. This allows us to record and replay an individual’s interaction with the Services. For more information about how Hotjar uses your personal information, please visit the “Personal Data collected from a visitor of a Hotjar Enabled Site” section of Hotjar’s Privacy Policy. To learn more about how to opt-out of Hotjar’s use of your information, please click here.

1. Other Users With Whom You Share Information or Interact. The Services may allow Power users to share personal information or interact with other users of the Services.

2. Third-Party Services With Whom You Share Your Personal Information or Interact. The Services may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service.”)

   Any personal information shared with a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for these Third-Party Service’s processing of personal information.

3. Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

   Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.

4. Affiliates. We may share personal information we receive with our affiliates for any of the purposes described in this Privacy Notice.

5. Trial Connections. When you connect with a trial, we will share the information you provide with the party/parties running the trial and their designated representatives.

   When you opt-in to the Local Patients Registry, we will share an anonymized version of your profile with researchers who believe you might be a fit for their trial.

   Note to Trial Sponsors. When you post information about your clinical trial on our Services, that information will be publicly viewable, including the names of any principal investigators and/or recruiting contacts.

6. Advertising Partners. We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising,” “personalized advertising,” or “targeted advertising.” Some of the advertising Technologies we may use include:

• Meta Connect. For more information about Facebook’s use of your personal information, please visit Meta’s Data Policy. To learn more about how to opt-out of Facebook’s use of your information, please click here while logged in to your Facebook account.

1. Disclosures to Protect Us or Others. We may access, preserve, and disclose your personal information if we, in good faith, believe doing so is required or appropriate to: ( a ) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; ( b ) protect your, our, or others' rights, property, or safety; ( c ) enforce our policies or contracts; collect amounts owed to us; or ( d ) assist with an investigation or prosecution of suspected or actual illegal activity. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

2. Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The processing of your personal information following any of these events will be governed by the provisions of this Privacy Notice in effect at the time the applicable information was collected.

3. Consent. We may also disclose your information with your permission.

YOUR PRIVACY RIGHTS AND CHOICES

1. Your Privacy Rights. In accordance with applicable law, you may have the right to:

• Information. You may have the right to be informed about what personal information is collected and by whom, how it is processed, with whom it is shared, and how to exercise applicable rights in a clear and easily accessible format;

• Access. You may have the right to confirm with Power whether it is processing your personal information and to access such information; additionally, you may have the right to obtain details regarding the processing activities performed on your personal information;

• Rectification. You may have the right to correct inaccurate personal information processed by Power;

• Erasure. You may have the right to have your personal information erased; this is not an absolute right and may only apply when certain legal conditions are met;

• Object. You may have the right to object to the processing of your personal information, in certain circumstances as allowed by applicable law, including when your data is used for profiling and direct marketing practices;

• Restriction. If you challenge the lawfulness or accuracy of the processing, you may have the right to restrict the processing of your personal information until you receive the relevant information that may either lead to lifting the restriction or stop the processing;

• Data Portability/Obtain a Copy. You may have the right, in limited circumstances, to receive an electronic copy of your personal information and/or have it transferred to another individual or legal entity as per your request; and

• Withdraw Your Consent. When the processing of your personal information is based on your consent, you have the right to withdraw your consent at any time. Please note your withdrawal will only affect future processing of personal information previously collected.

  If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

  Only you, or someone legally authorized to act on your behalf in certain jurisdictions, may make a request to exercise the rights listed above regarding your personal information. If your personal information is subject to a law that allows an authorized agent to act on your behalf in exercising your privacy rights and you wish to designate an authorized agent, please provide written authorization signed by you and your designated agent using the information found in “Contact Us” below and ask us for additional instructions.

To protect your privacy, we will take steps to verify your identity before fulfilling requests submitted under applicable privacy laws. These steps may involve asking you to confirm the email address we have associated with you.

Some laws may allow you to appeal our decision if we decline to process your request. If applicable laws grant you an appeal right, and you would like to appeal our decision with respect to your request, you may do so by informing us of this and providing us with information supporting your appeal.

1. Email Communications. You can unsubscribe from our promotional emails via the unsubscribe functionality provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive transaction-related messages from us. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Notice).

2. Text Messages. If you receive an unwanted text message from us, you may opt out of receiving future text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us as set forth in “Contact Us” below.

3. “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

4. Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly.

   The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, and the Digital Advertising Alliance.

   Please note you must separately opt out for each browser and on each device.

5. Data Deletion. You can request that your data and account be deleted by emailing us at hello@withpower.com.

THIRD PARTIES

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Notice does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

SECURITY

We make reasonable efforts to protect your information by using safeguards designed to improve the security of the information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

CHILDREN

We do not knowingly collect, maintain, or use personal information from children under 13 years of age (or other age as required by local law), and no part of our Service is directed to children. If you learn that a child has provided us with personal, please alert us at hello@withpower.com.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Our Services are hosted in the United States (“U.S.”) and intended for visitors located within the U.S. only. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.

ACCESSING/UPDATING YOUR PERSONAL INFORMATION

You can update your account and profile information or close your account through your profile settings.

CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, you can reach us as follows:

• Email us at: hello@withpower.com or

• Write to us at: 3517 Divisadero Street, San Francisco CA 94123

ANNEX A

SUPPLEMENTAL CONSUMER HEALTH DATA PRIVACY NOTICE

Effective Date: 10-22-2024

This Notice describes how Power Life Sciences, Inc. (“Power,” “we,” “us,” or “our”) processes Consumer Health Data, including our website available at www.WithPower.com. Our Privacy Notice describes how we handle your personal information generally. This Consumer Health Data Privacy Notice (“Notice”) supplements our Privacy Notice and applies to the collection of “Consumer Health Data” as defined in relevant comprehensive consumer health data privacy laws, including Washington’s My Health My Data Act (“WA MHMDA”) and Nevada’s Consumer Health Data Privacy Law.

Power’s Consumer Health Data Authorization supplements our Privacy Notice and this Consumer Health Data Privacy Notice. It is available for your review in our cookie banner.

In the event of a conflict between any other policy, statement, or notice and this Notice, this Notice will prevail as to Consumer Health Data collected under the WA MHMDA, Nevada’s Consumer Health Data Privacy Law, and similar comprehensive consumer health data privacy laws.

For purposes of this Notice, “Consumer Health Data” means personal information that (1) is linked or is reasonably linkable to a consumer and (2) that identifies past, present, or future physical or mental health status. Consumer Health Data includes information about medical conditions, as well as non-medical information such as biometric data, information about use of non-prescription health-related products, and attempts to access reproductive or gender-affirming care. This Notice does not apply to any personal information that does not fall under this definition.

Click on any of the links below to visit the specific area of this Consumer Health Data Privacy Notice or continue scrolling to read this Notice in its entirety.

Categories and Uses of Consumer Health Data that We Collect
Sources of Consumer Health Data
How We May Share Consumer Health Data
Your Consumer Health Data Privacy Rights
Changes to Our Consumer Health Data Privacy Notice
Nevada Supplemental Consumer Health Data Privacy Notice

Categories and Uses of Consumer Health Data We Collect

We only collect your Consumer Health Data as needed to provide you with the products or services you request or with your explicit consent.

We may collect the following categories of Consumer Health Data:

• Individual health condition, treatment, disease, or diagnosis information;
• Social, psychological, behavioral, and medical intervention information;
• Health-related surgery or procedure information;
• Use or purchase of prescribed medication information;
• Bodily function, vital sign, symptoms, or measurement of health information;
• Diagnosis or diagnostic testing, treatment, or medication information;
• Biometric data;
• Information about your access to healthcare, including precise location information that could reasonably indicate an attempt to acquire or receive health services or supplies; or
• Information processed to associate or identify an individual with the data listed above that is derived or extrapolated from non-health information.

We may process the categories of Consumer Health Data described above to the extent necessary to provide requested products or services, or with your consent, including to:

• Determine and verify program, product, and service eligibility and coverage;
• Enroll you in our programs and provide our products and services to you;
• Administer, manage, analyze, and improve our programs, products, and services;
• Procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations;
• Analyze and better understand your needs, preferences, and interests, as well as those of other consumers;
• Conduct internal business analysis and market research;
• Monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements;
• Comply with legal and regulatory obligations; or
• For our everyday business purposes.

Sources of Consumer Health Data

We collect Consumer Health Data from the following sources:

• Directly from you, if you:

  • request health-related products and services;
  • register to use our health or wellness-related apps;
  • join our email lists; or
  • volunteer the information in connection with surveys or promotions.

• Indirectly from you (gathered directly by social media, other websites, or apps) if you:

  • interact with us by using our apps, accessing our systems, or entering our facilities;
  • enable certain mobile app functions, such as location tracking;
  • enable data syncing between our website and your enrolled health-related app;
  • make your health data publicly available on social media or other websites; or
  • like, follow, or comment about health-related products on our social media sites.

• From our vendors, suppliers, consultants, professional advisers, and other third parties, when:

  • Business contact information, financial information, and other data is necessary for the purpose of managing and operating our business.

• From third parties who provide program enrollment, benefit verification, or product fulfillment services.

• Health Insurance Companies or other payors, when information is necessary:

  • For the purpose of providing our products and services;
  • To determine program eligibility; or
  • To comply with legal and regulatory obligations.

• Your authorized legal representative, family members, or caregivers.

How We May Share Consumer Health Data

We only share or disclose your Consumer Health Data as needed to provide you with the products or services that you request, or with your explicit consent. We may share or disclose any or all the above categories of Consumer Health Data to the following entities, who shall use the data only as permitted for the purposes set forth above, and within the bounds of our contracts with them:

These general categories of third parties:

• The clinical research sites and staff you choose to connect with
• Business Collaborators
• Product co-promotion partners
• Product co-development partners
• Marketing and Advertising Agencies
• Social Media Companies and Platforms
• Service Providers (including those hosting or analyzing data on our behalf, those assisting with fraud prevention, those assisting in program administration, those assisting in incident management and reporting, those administering our call center and websites, and those who assist with our information technology and security programs)
• Emergency Personnel,
• Authorized/legal representatives, family members, and caregivers,
• Third parties (including those with whom Company has joint marketing and similar arrangements, those who provide marketing and data analytics services, those who provide program enrollment or product fulfillment, payment, and authorization, other third parties as necessary to complete transactions and provide products/services, or where required by law),
• Company lawyers, auditors, and consultants, or
• Legal and regulatory bodies.

In addition, we may share or disclose Consumer Health Data as permitted or required by law, such as (i) to an acquiring organization if we are involved in a sale or a transfer of our business, (ii) as needed to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, (iii) in situations that may involve violations of our terms of use or other rules, (iv) to protect our rights and the rights and safety of others, (v) as needed to support external auditing, compliance and corporate governance functions, (vi) as needed to preserve the integrity or security of our systems, or (vii) to investigate, report, or prosecute those responsible for any action that is illegal under applicable state or Federal law.

Your Consumer Health Data Privacy Rights

Subject to certain legal limitations and exceptions, you have the following rights with respect to any Consumer Health Data we may collect about you:

• The right to confirm whether we are collecting, sharing, or selling your Consumer Health Data and to access such data, including to receive a list of affiliates or specific third parties with whom we have shared or sold your information, along with contact information such as an active email address for each third party;
• The right to review and request corrections to your Consumer Health Data;
• The right to withdraw consent from our collection or sharing of your Consumer Health Data; and
• The right to request that we delete your Consumer Health Data.

You may submit a request pursuant to any of these rights by contacting us at hello@withpower.com.

We will not discriminate against you for exercising any of your rights. We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. Please allow 45 days for a response. We may, after receiving your request, require additional information from you to authenticate your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.

If we deny your request, you have the right to appeal that denial by contacting us hello@withpower.com. We will process and respond to your appeal within the time permitted by applicable law. If you are a Washington resident and your appeal is unsuccessful, you may file a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

Changes to Our Consumer Health Data Privacy Notice

We may update this Consumer Health Data Privacy Notice from time to time. When we do update it, for your convenience, we will make the updated statement available on this page. Our intention is to use Consumer Health Data in accordance with the Consumer Health Data Privacy Notice in place at the time the Consumer Health Data was collected.

Nevada Supplemental Consumer Health Data Privacy Notice

This Supplement applies to Nevada consumers for purposes of providing additional disclosures required by Nevada's Consumer Health Data Privacy Law. We collect, use, process, and share Consumer Health Data for the purposes and manners described above in our Consumer Health Data Privacy Notice.

Third Party Collection of Consumer Health Data on Company Websites. We limit third party collection of Consumer Health Data over time and across different Websites or online Services when Nevada consumers use our Websites or online Services. We do this by disabling certain cookies or by ensuring that entities whose cookies, web beacons, pixels, and other online trackers we use on our websites and online services are our service providers or processors under applicable U.S. state privacy or consumer health data privacy laws. Nonetheless, please note that other third parties may still be able to process Consumer Health Data from you over time and across different websites depending on your browser, browser settings and add-ons, and associated permissions you have set on your device. This collection of Consumer Health Data by those third parties is unrelated to the Company processing of Consumer Health Data from you, and we encourage you to review your browser settings and review those third parties’ privacy notices for more information about their Consumer Health Data practices.

Review and Revision of Consumer Health Data. If you would like to review and/or revise your Consumer Health Data, you may submit a request to us via any of the methods listed in this Notice.