Privacy Policy

INTRODUCTION

Serva Health is committed to respecting and protecting your privacy.

This privacy policy sets out how we look after your personal data, how we will use your personal data, and tells you
about your privacy rights and how the law protects you.

This privacy policy sets out our approach to protecting personal data on a worldwide basis and we recognize that
different jurisdictions and legal systems will apply:

• In the United States, the Federal Trade Commission has jurisdiction over our compliance regarding
  personal data. If you do not agree to the terms of this privacy policy, you should not access or use Serva
  Health.
• In the rest of the world, different legal rules apply and, in particular, we will be using and protecting
  personal data in a way which is in accordance with the rules operating in the European Economic Area
  (“EEA”) which has adopted the General Data Protection Regulation (“GDPR”). In the EEA, the relevant
  national supervisory authority will have jurisdiction over our compliance in any specific EEA country. If you
  do not agree to the terms of this privacy policy, please do not access or use Serva Health.

TABLE OF CONTENTS

1. PURPOSE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW YOUR PERSONAL DATA IS COLLECTED
4. HOW WE USE AND DISCLOSE YOUR PERSONAL DATA
5. INTERNATIONAL TRANSFERS
6. DATA SECURITY
7. DATA RETENTION
8. YOUR DATA PRIVACY RIGHTS UNDER GDPR
9. YOUR CALIFORNIA PRIVACY RIGHTS
10. DEFINITIONS

1. PURPOSE

This privacy policy describes how Serva Health collects, uses, processes and protects your personal data and
informs the choices available to you regarding how you can choose and manage your personal data.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we
may provide on specific occasions when we are collecting or processing personal data about you so that you are
fully aware of how and why we are using your data. This privacy policy supplements the other notices and is not
intended to override them.

1.1 CONTROLLER

This privacy policy is issued on behalf of Serva Health so when “we”, “us” or “our” is mentioned in this privacy
policy, we are responsible for processing your data.

We have appointed a data protection officer who is responsible for dealing with questions in relation to this
privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal
rights, please contact the data protection officer using the details set out below.

1.2 CONTACT DETAILS

Our contact details for privacy rights requests and information about our privacy practices are:
Full name of legal entity: Serva Health, LLC
Name or title of data protection officer: Kenneth S. King
Email address: privacy@servahealth.com
Telephone number: 856–644–4498
Postal address: 1000 Bishops Gate Blvd., Suite 201, Mount Laurel, NJ 08054, USA
URL: http://www.servahealth.com/PrivacyRightsRequestForm.php

1.3 COMPLAINTS

You have the right to make a complaint at any time to the relevant national supervisory authority in the country
where you reside. To find more about this right and to locate the appropriate Data Privacy Authority, go to the
European Commission website (https://ec.europa.eu/info/policies/justice–and–fundamental–rights_en) if in the UK,
go to the Information Commissioner’s Office (“ICO”) website (www.ico.org.uk). If you are in the United States, you
may contact the US Federal Trade Commission regarding your concerns. For more information, please see
https://www.ftc.gov/faq/consumer–protection/submit–consumer–complaint–ftc.
We would, however, appreciate the chance to deal with your concerns before you approach one of the national
supervisory authorities, so please contact us in the first instance.

1.4 COMPLAINTS (EU-US and Swiss-US Data Privacy Framework Principles)

In compliance with the EU–U.S. DPF and the UK Extension to the EU–U.S. DPF and the Swiss–U.S. DPF, Serva HEalth
commits to resolve DPF Principles–related complaints about our collection and use of your personal
information. Pursuant to the Data Privacy Framework Principles, EU and Swiss individuals have the right to obtain
our confirmation of whether we maintain personal information relating to you in the United States. EU and UK
individuals and Swiss individuals with inquiries or complaints regarding our handling of personal data received in
reliance on the EU–U.S. DPF and the UK Extension to the EU–U.S. DPF, and the Swiss–U.S. DPF should first contact
Serva Health at: privacy@servahealth.com.

Serva Health has further committed to refer unresolved privacy complaints under the DPF Principles to an
independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National
Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily
addressed, please visit https://bbbprograms.org/programs/all–programs/dpf–
consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of
charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke
binding arbitration for some residual claims not resolved by other redress mechanisms. See
https://www.dataprivacyframework.gov/s/article/G–Arbitration–Procedures–dpf?tabset–35584=2

Serva Health complies with the EU–U.S. Data Privacy Framework (EU–U.S. DPF) and the UK Extension to the EU–U.S.
DPF, and the Swiss–U.S. Data Privacy Framework (Swiss–U.S. DPF) as set forth by the U.S. Department of
Commerce. Serva Health has certified to the U.S. Department of Commerce that it adheres to the EU–U.S. Data
Privacy Framework Principles (EU–U.S. DPF Principles) with regard to the processing of personal data received from
the European Union and the United Kingdom in reliance on the EU–U.S. DPF and the UK Extension to the EU–U.S.
DPF. Serva Health has certified to the U.S. Department of Commerce that it adheres to the Swiss–U.S. Data Privacy
Framework Principles (Swiss–U.S. DPF Principles) with regard to the processing of personal data received from
Switzerland in reliance on the Swiss–U.S. DPF. If there is any conflict between the terms in this privacy policy and
the EU–U.S. DPF Principles and/or the Swiss–U.S. DPF Principles, the Principles shall govern. To learn more about
the Data Privacy Framework (DPF) program, and to view our certification, please
visit https://www.dataprivacyframework.gov/

1.5 CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES IN YOUR PERSONAL DATA

We reserve the right to amend this privacy policy and will notify you by updating this notice, so please check it
from time to time, especially if you have ongoing dealings with us. It is important that the personal data we hold
about you is accurate and current. Please keep us informed if your personal data changes during your relationship
with us.

1.6 THIRD-PARTY LINKS

This website may include links to third–party websites, plug–ins and applications. Clicking on those links or enabling
those connections may allow third parties to collect or share data about you. We do not control these third–party
websites and are not responsible for their privacy statements. When you leave our website, we encourage you to
read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information related to an identified or identifiable natural
person. It does not, however, include data where the identity has been removed (anonymized data).

We may collect, use, store and transfer different categories of personal data about you which we have grouped
together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, date of birth, and
  gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes banking details of clients, suppliers, and agents for the making of payments by us and
  to us in relation to the services we provide.
• Transaction Data includes details of products and services you have received or purchased from us and/or
  affiliates.
• Technical Data includes internet protocol (“IP”) address, your login data, browser type and version, time
  zone setting and location, browser plug–in types and versions, operating system and platform, and other
  technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests,
  preferences, feedback, and survey/questionnaire responses.
• Usage Data includes information about how you use our website, products, and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and/or
  affiliates.
• Health Data includes information in relation to any aspect of your health and/or consequences of taking part
  in any clinical trials organized by our clients.

We may also collect, use and share Aggregated Data such as general statistical or demographic data for any
purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as
this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to
calculate the percentage of users accessing a specific website feature. However, if we combine or connect
Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined
data as personal data which will be used in accordance with this privacy policy.

Apart from Health Data and industry–wide or governmental survey(s)/questionnaire(s) where we are obliged to take part, we do not normally collect any Special Categories of Personal Data about you (this includes details
about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, and
trade union membership.)

2.1 IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to
provide that data when requested, we may not be able to perform the contract we have or are trying to enter into
with you (for example, to provide you with our services). In this case, we may have to cancel a product or service
you have with us but we will notify you if this is the case at the time.

3. HOW YOUR PERSONAL DATA IS COLLECTED

We use different methods to collect the categories of data described above from and about you including through:

• Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by
  mail, phone, and email, or otherwise. This includes personal data you provide when you:
  • apply online or otherwise for our services or products;
  • contract to receive our services; or
  • request marketing material to be sent to you.
• Automated technologies or interactions. As you interact with our website, we may automatically collect
  Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using
  cookies, log files, and other similar technologies. We may also receive Technical Data about you if you visit
  other websites employing our cookies. This aggregate data gives a “macro–view” of the visitor traffic pattern
  and insight to what sections of the website users visits most. We use this information to determine what
  kind of technology is available on the visitors’ computers so it can better serve them by utilizing more
  advanced technologies (e.g., Macromedia Flash). None of this information is linked to any Personal
  Information.
  • We passively collect and log the following information from visitors to our site such as:
    • Browser type
    • IP Address
    • Domain Name
    • Access Time
    • Operating System
• Third parties or publicly available sources. We may receive personal data about you from various third
  parties and public sources as set out below:
  • We may receive Technical Data from the following parties:
    • (a) analytics providers such as Google;
    • (b) advertising networks;
    • (c)search information providers;
    • (d)portals.
  • Contact and Transaction Data from providers of technical, payment and delivery services.
  • Identity and Contact Data from data brokers or aggregators.

4. HOW WE USE AND DISCLOSE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in
the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you, or to
  perform other legal obligations.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and
  fundamental rights do not override those interests (this applies in the EEA).
• Where we need to comply with a legal or regulatory obligation.

In the EEA, in relation to sending direct marketing communications to you via email or text message, we will only
do so where (i) we have your express consent or (ii) you are an existing client. You have the right to withdraw
consent to marketing at any time by contacting us.

4.1 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in table format, a description of the ways we plan to use your personal data, and which of
the legal basis we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose
for which we are using your data. Please contact us if you need details about the specific legal ground we are
relying on to process your personal data where more than one ground has been set out in the table below.

4.2 DISCLOSING INFORMATION TO THIRD-PARTIES

We generally do not share your personal data with any company outside Serva Health except for our trusted
clients and service providers where needed for clinical investigations and trials.

We may have to share your personal data with the parties set out below for the purposes set out in the table in
section 4.1 above.

• Third party sub–contractors who provide services for us and/or help to provide services to you. In the event
  that we use sub–contractors who have access to your personal data, we ensure that there are strict
  contractual terms in place to ensure that they only process personal data to the extent that we instruct them
  to do so in writing and there are suitably worded confidentiality and data protection clauses in all such
  contracts.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
  Alternatively, we may seek to acquire other businesses or merge with them. If a change of control arises in
  relation to our business, then the new owners may use your personal data in the same way as set out in this
  privacy policy.
• We may disclosed personal information to law enforcement, government authorities or otherwise in
  response to legal subpoenas or process as required by applicable law or in circumstances involving the
  possibility of physical or financial harm, fraud, or crime.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
We do not allow our third–party service providers to use your personal data for their own purposes and only
permit them to process your personal data for specified purposes and in accordance with our instructions.

We do not sell your personal data to any third party. Our use and disclosure of Personal Identifiable Health
Information (“PIHI”) is limited to the minimum amount of personal data needed to accomplish the intended
purpose of the specific clinical investigation or clinical trial and is used in relation to pre–screening activities for
such clinical research projects. This includes using study questionnaires that only ask health and medical related
questions that are directly associated with the relevant clinical research project as specified in approved protocols.

PIHI will generally not be used by us or disclosed by us to any third parties unless we have clear consent from you
to do so.

Exceptionally, PIHI may be disclosed by us where we are required to do so by a relevant law or regulation. In
particular, this includes, but is not limited to, situations where we are required to disclose such PIHI in relation to
requests by public authorities to meet national security or law enforcement requirements. This will include use
and/or disclosure in order to:

• prevent or control disease, injury or disability;
• report disease, injury or disability;
• assist public health surveillance, investigations or interventions;
• report child abuse or neglect or domestic violence;
• avert a serious threat to individual(s) or public health or safety;
• to coroners and/or medical examiners or for tissue donation;
• in response to legal proceedings and relevant court orders or subpoenas;
• for specialized government functions and worker’s compensation;
• by workforce members who are whistle-blowers or victims of a criminal act;
• when we believe in good faith that disclosure is necessary to protect our rights or to protect your safety, the safety of others or investigate fraud.

4.3 OPTING OUT

You can ask us or third parties to stop sending you information/reminder messages at any time by contacting us.

Where you opt out of receiving these information/reminder messages, this will not apply to personal data
provided to us as a result of a product/service purchase, warranty registration, product/service experience or
other transactions.

4.4 COOKIES

We only use cookies to record user–specific information on what pages users’ access or visit, record past activity,
and session management and personalization. Use of cookies allows a better user experience when visitors return
to the website.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access
cookies. If you disable or refuse cookies, please note that some parts of the website may become inaccessible or
not function properly.

4.4.1 Cookie Control.

Serva Health’s interactive cookie statement clearly states how the user’s behavior is tracked
and offers easy–to–use controls for granting and revoking consent. The user has the control to prevent cookies
from being placed on their computer until consent via an affirmative act.

4.5 CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that
we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal
basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the
above rules, where this is required or permitted by law.

4.6 USE OF HEALTH DATA IN THE UNITED STATES

The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and subsequent regulations published
by the Department of Health and Human Services (“DHHS”) impose restrictions on other organizations (Covered
Entities) which may be covered under HIPAA with respect to your relationship with Serva Health. Serva Health
may, in providing subject recruiting call center services for one of these organizations, be required to comply with
certain aspects of HIPAA in their conduct of human subject research activities.

5. INTERNATIONAL TRANSFERS

Some personal data may be held on servers in the US. This will involve transferring your data outside the European
Economic Area (“EEA”). In addition, we use third parties who have IT servers located in the United States which
hold your personal data. You consent to the transfer of your personal information to the United States.

Whenever we transfer and/or process your personal data outside of the EEA, we ensure a similar degree of
protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• where we use certain service providers, we may use specific contracts approved by the European
  Commission which give personal data the same protection it has in Europe.
• where we use providers based in the US, we may transfer data to them if they are part of the Data Privacy
  Framework Principles which requires them to provide similar protection to that afforded in the EEA to
  personal data shared between the Europe and the US.

5.1 Data Privacy Framework Principles

Serva Health complies with the EU–U.S. Data Privacy program Framework (EU–U.S. DPF) and the Swiss–U.S. Data
Privacy program Framework (Swiss–U.S. DPF) as set forth by the U.S. Department of Commerce. Serva
Health has certified to the U.S. Department of Commerce that it adheres to the EU–U.S. Data Privacy Framework
program Principles (EU–U.S. DPF Principles) with regard to the processing of personal data received from the
European Union in reliance on the EU–U.S. DPF. Serva Health has certified to the U.S. Department of Commerce
that it adheres to the Swiss–U.S. Data Privacy Framework program Principles (Swiss–U.S. DPF Principles) with
regard to the processing of personal data received from Switzerland in reliance on the Swiss–U.S. DPF. If there
is any conflict between the terms in this privacy policy and the EU–U.S. DPF Principles and/or the Swiss–U.S. DPF
Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to
view our certification, please visit https://www.dataprivacyframework.gov/.

With respect to personal data received or transferred pursuant to the Data Privacy Framework Principles, Serva
Health is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the Data Privacy Framework Principles, EU and Swiss individuals have the right to obtain our
confirmation of whether we maintain personal information relating to you in the United States. Upon request, we
will provide you with access to the personal information that we hold about you. You may also may correct,
amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to
correct, amend, or delete inaccurate data transferred to the United States under Data Privacy Framework
Principles, should direct their query to privacy@servahealth.com. If requested to remove data, we will respond
within a reasonable timeframe.

We will provide an individual opt–out or opt–in choice before we share your data with third parties other than our
agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.
To request to limit the use and disclosure of your personal information, please submit a written request to privacy@servahealth.com.

In compliance with the Data Privacy Framework Principles, Serva Health commits to resolve complaints about your
privacy and our collection or use of your personal information transferred to the United States pursuant to Data
Privacy Framework Principles. European Union and Swiss individuals with Data Privacy Framework inquiries or
complaints should first contact us by email at privacy@servahealth.com.

Serva Health has further committed to refer unresolved privacy complaints under the Data Privacy Framework
Principles to an independent dispute resolution mechanism, the BBB EU Data Privacy Framework Principles,
operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your
complaint, or if your complaint is not satisfactorily addressed, please visit
https://bbbprograms.org/programs/all–programs/dpf–consumers/ProcessForConsumers for more
information and to file a complaint. This service is provided free of charge to you.

If your Data Privacy Framework complaint cannot be resolved through the above channels, under certain
conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.
See Data Privacy Framework Principles Annex 1 at https://www.dataprivacyframework.gov/s/

6. DATA SECURITY

We and our third party hosting partners have put in place appropriate security measures to prevent your personal
data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we
limit access to your personal data to those employees, agents, contractors and other third parties who have a
business need to know. They will only process your personal data on our instructions and they are subject to a
duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any
applicable regulator of a breach where we are legally required to do so.

7. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including
for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity
of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the
purposes for which we process your personal data and whether we can achieve those purposes through other
means, and the applicable legal requirements.

In some circumstances in the EEA you can ask us to delete your data: see the section below entitled “Your Data
Privacy Rights in the EEA” for further information.

8. YOUR DATA PRIVACY RIGHTS UNDER GDPR

Under certain circumstances in the EEA, you have the following rights under data protection laws in relation to
your personal data:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to
receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or
inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you
provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there
is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your
personal data where you have successfully exercised your right to object to processing (see below), where we may
have processed your information unlawfully or where we are required to erase your personal data to comply with
local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal
reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party)
and there is something about your particular situation which makes you want to object to processing on this
ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we
are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we
have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of
your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use
of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no
longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of
your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you
have chosen, your personal data in a structured, commonly used, machine–readable format. Note that this right
only applies to automated information which you initially provided consent for us to use or where we used the
information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will
not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your
consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at
the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

In the EEA, you have the right to make a complaint at any time to the relevant national supervisory authority. For
example, in the UK this would be the Information Commissioner’s Office (“ICO”), the UK supervisory authority for
data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns
before you approach one of the national supervisory authorities so please contact us in the first instance.

8.1 NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data or to exercise any of the other rights.

8.2 WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to
access your personal data (or to exercise any of your other rights). This is a security measure to ensure that
personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for
further information in relation to your request to speed up our response.

8.3 TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within 30 business days. Occasionally it may take us longer than 30
business days if your request is particularly complex or you have made a number of requests. In this case, we will
notify you and keep you updated.

9. YOUR CALIFORNIA PRIVACY RIGHTS

If you are a resident of California, you have the following rights with respect to your Personal Information

• The right to know what Personal Information we have collected, used, disclosed and sold about you. To submit a request to know, please contact us. You also may designate an authorized agent to make a request for access on your behalf.
• The right to request that we delete any Personal Information we have collected about you. To submit a request for deletion, please contact us. You also may designate an authorized agent to make a request for deletion on your behalf.

When you exercise these rights and submit a proper request to us, we will verify your identity by asking you for
identifying information such as your email address, telephone number, and/or information about your account
with us. We also may use a third party verification provider to verify your identity. Please note that we are only
required to honor such requests twice in a 12–month period.

Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.

For the 12-month period prior to the date of this Privacy Policy, Serva Health has not sold any Personal Information collected about you; nor does it have any plans to do so in the future.

10. DEFINITIONS

EEA

Legitimate Interest means, in the EEA, the interest of our business in conducting and managing our business to
enable us to give you the best service/product and the best and most secure experience. We make sure we
consider and balance any potential impact on you (both positive and negative) and your rights before we process
your personal data for our legitimate interests. We do not use your personal data for activities where our interests
are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by
law). You can obtain further information about how we assess our legitimate interests against any potential impact
on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to
which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for
compliance with a legal or regulatory obligation that we are subject to.

GDPR is the European Union General Data Protection Regulation.

UNITED STATES

Covered Entity means an institution, organization or other entity that is subject to the rules of the Health
Insurance Portability and Accountability Act of 1996 (“HIPAA”). Covered Entities include: (i) a health plan, (ii) a
healthcare clearinghouse and, (iii) a healthcare provider who transmits any personal identifiable health
information in electronic form in connection with a transaction covered by HIPAA.

Personal Identifiable Health Information (“PIHI”) means any information including demographic information collected from an individual that:

(i)relates to (a) the past, present or future physical or mental health or condition of an individual; (b) the
provision of healthcare to an individual; or (c) the past, present or future payment for the provision of
healthcare to the individual; and

(ii)identifies the individual or there is a reasonable basis to believe it can be used to identify the individual;
and

(iii)PIHI does not include education records or medical records covered by the Family Education Rights and
Privacy Act or employment records held by Serva Health in its role as an employer.

CALIFORNIA

Personal Information means any information that identifies, relates to, describes, is reasonably capable of being
associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

THIRD PARTIES

• Service providers acting as processors and who provide services to us.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and
  insurers who provide consultancy, banking, legal, insurance and accounting services to us.
• Regulators and other state authorities acting as processors or joint controllers in any jurisdiction in which we
  are operating and who require reporting of processing activities in certain circumstances.

4. REFERENCES:

4.1. HIPAA (Health Insurance Portability Act of 1996)
4.2. 21 CFR Part 56
4.3. 45 CFR Part 46
4.4. Family Education Rights and Privacy Act
4.5. GDPR (General Data Protection Regulation (EU) 2016/679)

Revision History