PRIVACY POLICY

Effective Date: January 1, 2020

Updated Date: January 1, 2023

This Privacy Policy (“Privacy Policy”) describes the data protection practices of Fountain Life, LLC. and its subsidiary and affiliate organizations, including Fountain Life – Forever Young, Fountain Life – Lake Nona, Fountain Life – Naples, Fountain Life – Shapiro MD, Fountain Life Frisco, Fountain X – Naples, Fountain OS, Fountain Health(collectively, "Fountain Health", “Fountain Life”, “FountainOS”,”Technomad”, “we ”, “us”, or “our”), including when you visit any Fountain website that links to this Privacy Policy(www.fountainlife.com , www.fountainhealth.com , www.fountainos.com , www.technomad.net, (collectively, the “Websites,” andcollectively with any affiliated mobile application (“App”), the “Sites”).use any affiliated mobile applications (the “Apps”), or otherwise provide data to Fountain. We refer to the Websites, Apps, and other services provided by Fountain together in this Privacy Policy as the “Services.” This PrivacyPolicy is incorporated into our Terms of Use. All capitalized terms used in this Privacy Policy but not defined herein have the meanings assigned to them in the Terms of Use.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.
This Privacy Policy contains the following sections:
The Information We Collect and the Sources of Such Information
Purposes for How We Use Your Information
Online Analytics and Advertising
How We Share and Disclose Your Information
Your Marketing ChoicesThird Party Services and Notice About Health Information
How We Protect Your Information
Retention of Your Information
Revisions to Our Privacy Policy
Contacting Us
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THE INFORMATION WE COLLECT AND THE SOURCES OF SUCH INFORMATION
We obtain information about you through the means discussed below when you use the Services. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use part or all of our Services.

1. Information You Provide to Us
We collect a variety of information that you provide directly to us. For example, we collect information from you through:
Account and product registration and administration of your account
Processing your orders and requests for treatment
Questions, communications, or feedback you submit to us via forms or emailYour participation in research and surveys
Requests for customer support and technical assistance, including through online chat functionalities
Uploads or posts to the Services
Employment applications you submit
The specific types of information we collect will depend upon the Services you use, how you use them, and the information you choose to provide. The types of data we collect directly from you includes:
Name, address, telephone number, date of birth, and email address
Information about your medical conditions, treatment options, physician referrals, prescriptions, and lab results or other related health information, such as your physical and emotional characteristicsLog-in credentials, if you create an account
Billing information, such as shipping address, credit or debit card number, verification number, expiration date, and identity verification information, collected by our payment processors on our behalfInformation about purchases or other transactions with us
Information about your customer service and maintenance interactions with us
Demographic information such as your gender and age
User-generated content you post in public online forums on our Services
Any other information you choose to directly provide to us in connection with your use of the Services.

2. Information We Collect Through Automated MeansWe collect certain information about your use of the Services and the devices you use to access the Services, as described in this Section. As discussed further below, we and our service providers (which are third party companies that work on our behalf), may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.
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‍Our Websites. When you use our Websites, we collect and analyze information such as your IP address, browser types, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs) referring and exit pages and URLs, platform type, the number of clicks, files you download, domain names, landing pages, pages viewed and the order of those pages, theamount of time spent on particular pages, the terms you use in searches on our sites, the date and time you used the Services, error logs, and other similar information.
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‍Our Apps. When you use our Apps, we automatically receive certain information about the mobile phone, tablet, or computer used to access theApps, including a mobile device identifier, IP address, operating system, version, Internet service provider, browser type, domain name and other similar information, whether and when you update the Apps, date and time of use, and how you use the Apps, including time spent in different portions of the Apps.
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‍Location Information. When you use the Services, we and our service providers may automatically collect general location information (e.g., IP address, city/state and or postal code associated with an IP address) from your computer or mobile device. This information allows us to enable access to content that varies based on a user’s general location (e.g., to provide you with accurate sales tax information and to deliver content customized to your location).
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We will ask your permission before collecting your precise GPS location information. In such instances, we will use your precise geo-location information to provide customized services, content, promotional offers and other information that may be of interest to you. If you no longer wish for us and our service providers to collect and use GPS location information, you may disable the location features on your device. Please see your device manufacturer settings.
‍Our Use of Cookies and Similar Online Tools. To collect the information discussed in this Section, we and our service providers use web server logs, cookies, tags, SDKs, tracking pixels, and other similar tracking technologies. We use these technologies to offer you a more tailored experience.

A web server log is a file where website activity is stored.

An SDK is a set of tools and/or code that we embed in our Apps and software to allow third parties to collect information about how users interact with the Services.A cookie is a small text file that is placed on your computer or mobile device when you visit a site, that enables us to: (i) recognize your computer/device; (ii) store your preferences and settings; (iii) understand the parts of the Services you have visited and used; (iv), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and(vi) assist with security and administrative functions.

Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email that are designed to: (1) collect usage information like ad impressions or clicks and email open rates; (2) measure popularity of theServices and associated advertising; and (3) access user cookies.

As we adopt additional technologies, we may also gather information through other methods.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the“Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.

3. Information We Collect From Social Media and Other Content Platforms
When you “like” or “follow” us on Facebook, Instagram, Twitter, or other social media sites, we may collect some information from you including your name, email address, and any comments or content you post relevant to us. We also collect your information if you sign up for one of our promotions or submit information to us through social media sites.

4. Information We Receive From Other Sources
We work closely with third parties (including, for example, third party intermediaries, such as the physicians, medical professionals and pharmacies with whom we partner to provide you with the Services and their health care services, sub-contractors in technical, advertising networks, analytics providers, and search information providers). Such third parties will sometimes provide us with additional information about you.

PURPOSES FOR HOW WE USE YOUR INFORMATION
In connection with providing you with the Services, we may use your information for our business purposes to:
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Carry out, improve, and manage the Services and, as applicable, facilitate the provision of health care services to you by physicians or other health care providers and ensure that the physicians or health care providers have the services and support necessary for health care operations.

Engage in internal research to understand the effectiveness of our Services, improve our Services, and better understand our user base. If we publish or provide the results of this research to others, such research will be presented in a de-identified and aggregate form such that individual users cannot be identified.

Communicate with you about the Services, your use of the Services, or your inquiries related to the Services and send you communications on behalf of physicians or other health care providers utilizing the Services to meet your needs.

Communicate with you by email, postal mail, or phone about surveys, promotions, special events or our products and Services and those of our subsidiaries, affiliates, and parent companies and any of their related businesses and those of our third-party partners.

Provide you with technical support and customer service.

Verify your identity and administer your account, including processing your payments and fulfilling your orders.

Ensure that content from our Services is presented in the most effective manner for you and for your computer or device, allow you to participate in interactive features of our Services (when you choose to do so), and as part of our efforts to keep our Services safe and secure.

Measure or understand the effectiveness of advertising and content we serve to you and others, and to deliver and customize relevant advertising and content to you.Help us better understand your interests and needs, such as by engaging in analysis and research regarding use of the Services.

Comply in good faith with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others.

Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.

‍Combined Information. For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use and share such combined information in accordance with this Privacy Policy.

‍Aggregate/De-Identified Data. We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

ONLINE ANALYTICS AND ADVERTISING

1. Online Analytics
We may use third-party web analytics services (such as those of Google Analytics (including Google Signals, Google User-ID, and other Google Analytics features) and MixPanel) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; try to locate the same unique users across multiple browsers or devices to better tailor services and features; and provide certain features to you. If you have a Google account with personalized advertising enabled, through Google Signals, Google will also be able to gather for us analytics and engagement information from across the various devices you use to access the Services. To prevent Google from using your information for analytics (including cross-device tracking for personalization purposes), you may install the Google Analytics Opt-out Browser Add-on by visiting their website. And to opt out of Google Signals, please open your “Settings” app, locate and tap “Google,” select “Ads,” and turn ON “Opt out of Ads Personalization.” You may also be able to disable cross-device tracking through your Android or Apple device-based settings.If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

2. Online Advertising
The Services may integrate third-party advertising technologies (e.g., ad networks and ad servers such as Facebook, Google Ad Words, Criteo andothers) that use cookies and other technologies to deliver relevant content and advertising for Fountain products on the Services, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, information you enter such as your searches, demographic data, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services.

We sometimes provide our customer information (such as email addresses) to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile applications.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device you use to access the Services by non-affiliated third-party advertising network services. If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs. If you are interested in more information about Criteo’s privacy practices or opting-out of Criteo’s advertising services, you may view their Privacy Policy. To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Please note that if you exercise the opt out choices above, you will still see advertising when you use the Services, but it will not be tailored to you based on your online behavior over time.

3. Mobile AdvertisingWhen using mobile applications from us or others, you may also receive tailored in-application advertisements. We may use third-party service providers to deliver advertisements on mobile applications or for mobile application analytics. Each operating system, iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. We do not control how the applicable platform operator allows you to control receiving personalized in-application advertisements; thus, you should contact the platform provider for further details on opting out of tailored in-application advertisements. You may review the support materials and/or the device settings for the respective operating systems to opt-out of tailored in-app advertisements.

4. Notice Concerning Do Not Track
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so here.

‍HOW WE SHARE AND DISCLOSE YOUR INFORMATION

We may share your information for our business purposes in the following ways:

‍Affiliates and Subsidiaries. We may share information we collect within any Fountain Life member or group (i.e., our subsidiaries and affiliates, including our ultimate holding company and its subsidiaries) to deliver products and services to you, ensure a consistent level of service across our products and services, and enhance our products, services, and your customer experience.

‍Health Care Providers and Services. We share your information with health care providers: (i) to schedule and fulfill appointments and provide health care services as part of the Services, (ii) to whom you send messages through our Services, and (iii) for other treatment, payment or health care operations purposes, including pharmacy services, upon your request.

‍Service Providers. We provide access to or share your information with select third parties who use the information to perform services on our behalf. They provide a variety of services to us, including billing, sales, marketing, advertising, analytics, research, customer service, shipping andfulfillment, data storage, IT and security, fraud prevention, payment processing, and auditing and legal services. These entities may also include health care organizations, pharmacies, and other third parties we use to support our business or in connection with the administration and support ofthe Services.

‍Protection of Fountain and Others. By using the Services, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce our Terms of Use, this Privacy Policy, or other contracts with you, includinginvestigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of Fountain, its agents and affiliates, its users and/or the public. Thisincludes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.

‍Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (includingin contemplation of such transactions) user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.

‍Public Forums. Certain features of our Services make it possible for you to share comments publicly with other users. Any information that you submit through such features is not confidential, and we may use it for any purpose (including in testimonials or other marketing materials). For example, if you submit a product review on one of our sites, we may display your review (along with the name provided, if any) on other Fountainwebsites and on third-party websites. Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Accordingly, please take care when using these features.

‍Consent. We may also disclose your information in other ways you direct us to and when we have your consent.

‍Aggregate/De-Identified Information. We reserve the right to create Aggregate/De-Identified Data from the information we collect through theServices and our sharing of such Aggregate/De-Identified Data is in our discretion.

YOUR MARKETING CHOICES
You may instruct us not to use your contact information to contact you by email, postal mail, or phone regarding products, services, promotions andspecial events that might appeal to your interests by contacting us using the information below. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

THIRD PARTY SERVICES AND NOTICE ABOUT HEALTH INFORMATION
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices, including data privacy and security process and standards of any third parties, including physicians and other health care providers using the Services, the manufacturer of your mobile device and other IT hardware and software, and any other third-party mobile application, website, or service to which our Services may contain a link. These third parties may at times gather information from or about you. We have no control over the privacy practices of these third parties. Thecollection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites or services, and not this PrivacyPolicy. We urge you to read the privacy and security policies of these third-parties.

HOW WE PROTECT YOUR INFORMATION
Fountain takes a variety of technical and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services or via the Internet and that any such transmission is at your own risk.

Where we have given you (or where you have chosen) a password that enables you to access the Services, you are responsible for keeping thispassword confidential. We ask you not to share your password with anyone. The information you share in public areas may be viewed by any user ofthe Services.

PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

‍Categories of personal information we collect. Throughout this Policy, we discuss in detail the specific pieces of personal information we collect from and about our users. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect. Thecategories we collect are: identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information); internet or other network or device activity (such as browsing history or app usage); general and precise geolocation information; inference data about you (e.g., the products and services you might be interested in based on other products and services you use); legally protected classifications (we only collect your gender); insurance (including health insurance) information; medical information; physical characteristics or description; and other information that identifies or can be reasonably associated with you.

‍How we use and share these categories of personal information. We use and share the categories of personal information we collect from andabout you consistent with the various business purposes we discuss throughout this Policy. Please see the “Purposes for How We Use Your Information” and “How We Share and Disclose Your Information” sections of this Policy above for more information.

Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. We do not engage in such activity and have not engaged in such activity in the past twelve months.

Your California Privacy Rights

CCPA Rights Disclosure. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.

Provide access to and/or a copy of certain information we hold about you.

Delete certain information we have about you.

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you. We also will take reasonable steps to verify your identity before responding to a request.

If you are a California resident and you would like to exercise any of your data rights under California law, please email us at care@fountainlife.com. Please include your full name, email address and residential address associated with your use of our Services, along with the rights you would like to exercise, so that we can process your request in an efficient manner. If you would like to receive a copy of your medical record in connection with your request, please indicate that in your email message. By requesting your medical record in this way, you are agreeing to receive your medical record in an unencrypted email message.

Shine the Light Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

PRIVACY INFORMATION FOR NEVADA RESIDENTS

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased services from us, you may submit a request to opt out of any potential future sales under Nevada law by care@fountainlife.com . Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

RETENTION OF YOUR INFORMATIONWe keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

REVISIONS TO OUR PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Privacy Policy accessible through the Services, so you should review it periodically. The date this Privacy Policy was last revised is identified at the top of the document. You are responsible for periodically monitoring and reviewing any updates to the Privacy Policy. If we make a material change to the PrivacyPolicy, we will provide you with appropriate notice in accordance with legal requirements. Your continued use of our Websites or Apps after such amendments (and notice, where applicable) will be deemed your acknowledgment of these changes to this Privacy Policy.

CONTACTING US
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If you have any questions about this Privacy Policy or Fountain’s privacy practices, please contact us

Fountain Life, LLC 9132 Strada Place Suite 200 Naples, FL34108 care@fountainlife.com

‍Effective Date: October 16, 2024

Fountain Life, LLC and our subsidiaries and affiliates, including Fountain Digital, LLC, Fountain Life Management, LLC, Fountain Life New York LLC, Medical Physicians, Inc., Fountain Life Dallas, LLC, Medical Physicians Dallas PA, and Fountain Life Orlando LLC (collectively, "Company" or "We") respect your privacy and commit to protecting it through our compliance with the practices described in this privacy policy (“Privacy Policy”). This Privacy Policy is incorporated into our End User License Agreement and Terms of Use. All capitalized terms used in this Privacy Policy but not otherwise defined herein shall have the meanings assigned to them in the End User License Agreement and/or Terms of Use.

This Privacy Policy describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you (i) visit our websites located at www.fountainlife.com, www.lifeomic.com, and any and all subdomains thereof, or other digital properties, communications, or forms that link or refer to this Privacy Policy (collectively, the "Website"), and/or (ii) purchase, download, install, register with, access, or use the Fountain Life mobile application (the “Application”, and together with the Website, the “Online Platform”). This Privacy Policy applies to the personal data collected through our Online Platform, regardless of the country where you are located.

This Privacy Policy applies to information we collect:

On the Online Platform.
In email, text, and other electronic messages between you and the Website.
Through mobile and desktop applications you download from the Website, which provide dedicated non-browser-based interaction between you and the Website.
From the Application and in email, text, and other electronic communications sent through or in connection with the Application.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

It does not apply to information collected by:

Us offline or through any other means, including on any other website or application operated by any third party, including websites you may access through Application.
Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Online Platform.

The Online Platform may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy notice of every website you visit.

Please read this Privacy Policy carefully to understand our policies and practices for processing and storing your personal data. If you do not agree with our Privacy Policy, do not download, register with, or use the Online Platform. By downloading, using, registering with, or engaging with our Online Platform, you accept and consent to the practices described in this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy) due to changes in the laws, regulations and our business. Your continued engagement with our Online Platform after any such revisions indicates that you accept and consent to them, so please check the Privacy Policy periodically for updates.

A. Data We May Collect About You

We collect and use different types of data from and about users of our Online Platform directly from you when you provide it to us, automatically as you use the Online Platform, and/or from third parties, including:

Personal data that we could reasonably use to directly or indirectly identify you, such as your name, date of birth, gender, age, postal address, email address, telephone number, username or other similar identifier, or any other identifier we may use to contact you online or offline ("personal data").
Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Online Platform feature.
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, or operating system and platform.
Non-personal details about your Online Platform interactions, including the full Uniform Resource Locators (URLs), clickstream information to, through, and from our Online Platform (including date and time), products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page.

B. How We Collect Data About You

We use different methods to collect data from and about you including through:

Direct Interactions and the Information You Provide to Us

The information we collect on or through our Online Platform may include:

Information, including personal data, that you provide by filling in forms or by corresponding with us by phone, email or otherwise.

Information that you provide by filling in forms on the Online Platform. This includes information you provide when you create an account (and the administration thereof), subscribe to our service, search for a product, place an order, participate in discussion boards or other social media functions on our Online Platform, enter a competition, promotion or survey, call our customer service number, and when you report a problem with our Online Platform.
Requests for customer support and technical assistance, including through online chat functionalities.
Processing your orders and requests for treatment.
Health information, including information about your medical conditions, treatment options, physician referrals, prescriptions, lab results, or other related health information.
Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
Employment applications you submit.
Your responses to surveys that we might ask you to complete for research purposes.
Financial information, including billing information such as shipping address, credit or debit card number, verification number, expiration date, and identity verification information (collected by our payment processors on our behalf).
Details of transactions you carry out through the Online Platform and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the Online Platform.
Your search queries on the Online Platform.
Materials, information, and text (collectively, “Prompts”) that you provide for processing on the Application to Fountain Life’s generative artificial intelligence (“AI”) technology, “Zora AI,” in order to generate a response (“Outputs”) based on your Prompts, as well as any feedback you provide (“Feedback”).
Other information you choose to directly provide to us in connection with your use of the Online Platform.

User Contributions. You also may provide information for us to publish or display ("post") on public Online Platform areas or transmit to other Online Platform users or third parties (collectively, "User Contributions"). You submit User Contributions for posting and transmission to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of any Online Platform users with whom you choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

Automated Technologies or Interactions

When you download, access, use, and/or interact with our Online Platform, we may use technology to automatically collect certain information and technical data about your equipment, browsing actions, and patterns, including:

Usage Details. When you access and use the Online Platform, we and our service providers (which are third party companies that work on our behalf) may automatically collect certain details of your access to and use of the Online Platform, including traffic data, number of clicks, time spent on particular pages, files downloaded, location data, logs, and other communication data and the resources that you access and use on or through the Online Platform.
Device Information. We may collect information about your computer, mobile device, and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number.
Stored Information and Files. The Online Platform also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

Location Information. The Online Platform may collect real-time information about the location of your device. This information allows us to enable access to content that varies based on a user’s general location (e.g., to provide you with accurate sales tax information and to deliver content customized to your location). We will ask your permission before collecting your precise GPS location information. In such instances, we will use your precise geo-location information to provide customized services, content, promotional offers and other information that may be of interest to you. If you no longer wish for us and/or our service providers to collect and use GPS location information, you may disable the location features on your device. Please see your device manufacturer settings. Note, however, that opting out of the Application’s collection of location information will disable its location-based features.

We collect this information by using cookies, server logs, and other similar technologies (see Cookies and Automatic Data Collection Technologies). If you do not want us to collect this information do not download the Application or delete it from your device and/or do not use the Online Platform.

Cookies and Automatic Data Collection Technologies

Our Online Platform uses various automatic data collection technologies to distinguish you from other Online Platform users. We also may use these technologies to collect information about your online activities over time and across third-party websites, applications, or other online services (behavioral tracking). This helps us deliver a better and more personalized service when you interact with our Online Platform. It also allows us to improve our Online Platform by enabling us to:

Estimate our audience size and usage patterns.
Store your preferences so we may customize our Online Platform according to your individual interests.
Speed up your searches.
Recognize you when you return to our Online Platform.

The technologies we use for this automatic data collection may include:

Cookies (browser cookies or mobile cookies). A cookie is a small file placed on the hard drive of your computer or on your smart phone. You may refuse to accept browser cookies by activating the appropriate setting on your browser or smartphone. However, if you select this setting, certain parts of our Online Platform may become inaccessible and certain features may not work correctly. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
Web Beacons. Pages of our Online Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies and you must manage their settings separately.
Web Server Logs, Tags, SDKs, and Other Similar Tracking Technologies. We use these technologies to offer you a more tailored experience. As we adopt additional technologies, we may also gather information through other methods.some text
- A web server log is a file where website activity is stored.
- An SDK is a set of tools and/or code that we embed in our Application and software to allow third parties to collect information about how users interact with the Online Platform.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources, or you provide to us.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Online Platform are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Online Platform. They may associate the information collected with your personal data or they may collect information, including personal data, about your online activities over time and across different websites or other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control how these third-party tracking technologies operate or how they may use the collected data. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Third Parties or Publicly Available Sources

We may receive information about you if you visit other websites employing our cookies or from third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, data brokers, or aggregators, such as:

Information we collect from social media and other content platforms. When you “like” or “follow” us on Facebook, Instagram, X, or other social media sites, we may collect some information from you including your name, email address, and any comments or content you post relevant to us. We also collect your information if you sign up for one of our promotions or submit information to us through social media sites.
Information we receive from other sources. We work closely with third parties, including, for example, third party intermediaries, such as the physicians, medical professionals and pharmacies with whom we partner to provide you with services and their health care services, sub-contractors in technical, advertising networks, analytics providers, and search information providers. Such third parties will sometimes provide us with additional information about you.

C. How We Use Your Personal Data

We use your personal data to provide you with products, offer you services, communicate with you, deliver advertising and marketing, and/or to conduct other business operations, such as using data to improve and personalize your experiences. Examples of how we may use the personal data we collect include to:

Present our Online Platform and provide you with the information, products, services, and support that you request from us.
Provide you with the Application and its contents, and any other information, products, or services that you request from us.
Provide services, including carry out, improve, and manage the services and facilitate the provision of healthcare services to you by physicians or other health care providers.
Engage in research and analysis, including engaging in internal research to understand the effectiveness of our services, improve them, and better understand our user base.
Communicate with you about our services, your use of the services, or your inquiries related to the services, and send you communications on behalf of physicians or other healthcare providers utilizing the services.
Market, such as communicating with you by email, postal mail, or phone about surveys, promotions, special events, or our products and services and those of our affiliates and third-party partners.
Facilitate customer support, such as providing you with technical support and customer service.
Facilitate account administration, such as verifying your identity and administering your account, including processing payments and fulfilling orders.
Personalize content, such as ensuring that content from our services is presented in the most effective manner for you and your device.
Ensure security, including as part of our efforts to keep our services safe and secure.
Facilitate legal compliance, such as complying in good faith with any procedures, laws, and regulations that apply to us.
Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or comply with legal requirements.
Fulfill the purposes for which you provided the data or that were described when it was collected.
Notify you about changes to our Online Platform or any products or services we offer or provide through it.
Notify you when Application updates are available, and of changes to any products or services we offer or provide through it.
To provide you with notices about your account and/or subscription, including expiration and renewal notices.
Ensure that we present our Online Platform content in the most effective manner for you and for your computer.
Administer our Online Platform and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
Improve our Online Platform, products or services, marketing, or customer relationships and experiences.
Enable your participation in our Online Platform's interactive, social media, or other similar features.
Protect our Online Platform, employees, or operations.
Measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
Make suggestions and recommendations to you and other users of our Online Platform about goods or services that may interest you or them.
Generate Outputs from Zora AI, including using your Prompts, medical records, such as your test results, clinician notes and medical diagnoses, as Context (as defined herein) to help answer basic questions, provide general and health-related information, and help you better understand your health data. “Context” refers to the surrounding information or circumstances that help clarify the meaning of data or inputs. For instance, in natural language processing, context can include previous sentences, the topic of conversation, or even cultural background that shapes interpretation.
Evaluate and improve Zora AI, including reviewing metadata about chat conversations and anonymized transcripts.
Evaluate responses and obtain insights into topics in which you are interested in learning, including by reviewing your interactions with Zora AI and the content of your conversations with or messages to Zora AI, and such review may be automated or manual (human) by Fountain Life, including its providers.
Provide, maintain, and improve Zora AI, to conduct and support research.
Improve Zora AI and any related technology and support research in areas like AI and machine learning.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

Combined Information. We may combine the information that we collect through the Online Platform and/or services we provide with information that we receive from other sources, both online and offline, and may use and share such combined information in accordance with this Privacy Policy. If we combine or connect non-personal, demographic, or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.

Aggregate/De-Identified Data. We may aggregate and/or de-identify any information collected through the Online Platform and/or services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including for research, scientific, medical, and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

We may also use personal data to contact you about our own and third parties' goods and services that may be of interest to you. If you do not want us to use your data in this way, please adjust your user preferences in your account profile.

We may use personal data to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal data for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. We may use non-personal data for any business purpose.

D. Disclosure of Your Personal Data

We may share your personal data with:

Any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates. We may share information we collect within any Company member or group (e.g., our subsidiaries and affiliates, including our ultimate holding company and its subsidiaries) to deliver products and services to you, ensure a consistent level of service across our products and services, and enhance our products, services, and your customer experience.
Healthcare providers providing services. We share your information with healthcare providers: (i) to schedule and fulfill appointments and provide healthcare services as part of our services, (ii) to whom you send messages through the Online Platform, and (iii) for other treatment, payment or healthcare operations purposes, including pharmacy services, upon your request.
Service Providers. We provide access to or share your information with select third parties who use the information to perform services on our behalf. They provide a variety of services for us, including billing, sales, marketing, advertising, research, customer service, shipping and fulfillment, data storage, IT and security, fraud prevention, payment processing, and auditing and legal services. These entities may also include health care organizations, pharmacies, and other third parties we use to support our business or in connection with the administration and support of the services we render or the Online Platform.
Business partners, suppliers, service providers, sub-contractors, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Online Platform improvement and optimization). We contractually require these third parties to keep that personal data confidential and use it only for the contracted purposes.
Third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep that personal data confidential and use it only for the contracted purposes.
Advertisers and advertising networks that require the data to select and serve relevant ads to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in a specific location). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
Credit reference agencies when required to assess your credit score before entering into a contract with you.
To fulfill the purpose for which you provide it. For example, if you give us an email address to use the "email a friend" feature of our Online Platform, we will transmit the contents of that email and your email address to the recipients.
For any other purposes that we disclose when you provide the data.
With your consent. We may disclose your information in other ways you direct us to and when we have your consent.

If you opt-in and consent to receive SMS messages and authorize the Company to contact you by text message (including by an automatic telephone dialing system) at the mobile number provided by you or on your behalf in connection with your Company account or otherwise, then you shall only receive messages from or on behalf of the Company at the respective number you provide, and no mobile information will be shared by the Company with third parties for marketing or promotional purposes. The above disclosure categories do not include SMS messaging originator opt-in data and consent; this information will not be shared with any third parties. Notwithstanding the foregoing, if you expressly provide your mobile number to a third party via the Online Platform for the purpose of receiving marketing or promotional SMS messages from that third party, then you may receive SMS messages from that third party pursuant to the consent that you provided.

We may also disclose your personal data to third parties:

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal data we hold.
To comply with any court order, law, or legal process, including responding to any government or regulatory request, including responding to claims that any content violates the rights of third parties.
To enforce or apply our End User License Agreement, Terms of Use, this Privacy Policy, and/or terms and conditions of supply and other agreements.
To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.
Public Forums. Certain features of the Online Platform may permit you to share comments publicly with other users. Any information that you submit through such features is not confidential, and we may use it for any purpose (including in testimonials or other marketing materials). For example, if you submit a product review on one of our sites, we may display your review (along with the name provided, if any) on other Company websites and on third-party websites. Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Accordingly, please take care when using these features.
Aggregate/De-Identified Information: We reserve the right to create Aggregate/De-Identified Data from the information we collect through the Online Platform and when rendering services and our sharing of such Aggregate/De-Identified Data is in our discretion.

We may share non-personal data without restriction.

E. Your Personal Data Use Choices

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information:

Promotional Offers from the Company. If you do not want us to use your contact information to promote our own products and services, or third parties' products or services, you can opt-out by sending us an email with your request to care@fountainlife.com. You may also opt-out of further marketing communications by replying to any promotional email we have sent you or following the opt-out links on that message. This opt-out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience, or other transactions. Please note that regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt-out of certain operational emails, such as those reflecting our relationship or transactions with you.
Third-Party Advertising. If you do not want us to share your personal data with unaffiliated or non-agent third parties for promotional purposes, you can always opt-out by logging into the Online Platform and checking or unchecking the relevant boxes to adjust your account profile's user preferences, or by sending us an email stating your request to care@fountainlife.com.
Tracking Technologies and Advertising. 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 this Online Platform may become inaccessible or not function properly. For more information about tracking technologies, please see Cookies and Automatic Data Collection Technologies.
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes, or by sending us an email stating your request to care@fountainlife.com.
Location Information. You can choose whether or not to allow the Application to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the Application may become inaccessible or not function properly.

Our Online Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates, or include plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, please note that these third parties have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.

F. Consent to Personal Data Transfer

The Company is based in the State of Florida in the United States. If you are using the Online Platform, or any part thereof, from outside of the United States, please be aware that your information, including personal data, may be transferred to, stored, or processed in the United States and maintained on computers or servers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective and/or comprehensive as those in your jurisdiction. By providing us with your information you acknowledge that your information, including personal data, will be transferred to the United States and processed and stored on servers in the United States. Your information, including personal data, may also be processed by employees or by other third parties who work for us, or by the representatives and employees or workers of the Company located outside your home country. By submitting your information, including personal data, or engaging with our Online Platform, you consent to this transfer, storing, and/or processing of information, including personal data, to the United States and those third parties with whom we share it.

G. Accessing and Correcting Your Personal Data

You can access, review, and change your personal data by logging into the Online Platform and visiting your account profile page.

You may also send us an email at legal@fountainlife.com to request access to, correct, or delete personal data that you have provided to us. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively impact the information's accuracy.

If you delete your User Contributions from the Online Platform, copies of your User Contributions may remain viewable in cached and archived pages or because other Online Platform users may have copied or stored them. Our Terms of Use govern proper access and use of information provided on the Online Platform, including User Contributions.

H. Data Retention

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

I. Jurisdiction Specific Rights

Privacy Information for California Residents

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

a. Categories of Personal Information We Collect

Throughout this Privacy Policy, we discuss in detail the specific pieces of personal information we collect from and about our users. Under the CCPA, we are also required to provide you with the “categories” of personal information we collect. The categories we collect are: identifiers (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information); internet or other network or device activity (such as browsing history or application usage); general and precise geolocation information; inference data about you (e.g., the products and services you might be interested in based on other products and services you use); legally protected classifications (we only collect your gender); insurance (including health insurance) information; medical information; physical characteristics or description; and other information that identifies or can be reasonably associated with you.

b. How We Use and Share These Categories of Personal Information

We use and share the categories of personal information we collect from and about you consistent with the various business purposes we discuss throughout this Privacy Policy. Please see the “How We Use Your Personal Data” and “Disclosure of Your Personal Data” sections of this Privacy Policy above for more information.

Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties. We do not engage in such activity and have not engaged in such activity in the past twelve months.

c. Your California Privacy Rights

CCPA Rights Disclosure. If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
Provide access to and/or a copy of certain information we hold about you.
Delete certain information we have about you.
The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide services to you. We also will take reasonable steps to verify your identity before responding to a request.

If you are a California resident and you would like to exercise any of your data rights under California law, please email us at legal@fountainlife.com. Please include your full name, email address and residential address associated with your use of our services, along with the rights you would like to exercise, so that we can process your request in an efficient manner. If you would like to receive a copy of your medical records in connection with your request, please indicate that in your email message. By requesting your medical records in manner, you are agreeing to receive your medical records in an unencrypted email message.

d. Shine the Light Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.

Privacy Information for Nevada Residents

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons. We do not engage in such activity; however, if you are a Nevada resident who has purchased services from us, you may submit a request to opt out of any potential future sales under Nevada law by legal@fountainlife.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

J. Data Security

The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure. We store all personal data you provide to us behind firewalls on servers employing security protections. We encrypt any payment transactions using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Online Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to take care when providing information in public areas of the Online Platform like message boards, which any Online Platform visitor can view.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Online Platform. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Online Platform.

K. Children's Online Privacy

We do not direct our Online Platform to minors and we do not knowingly collect personal data from children under 18 or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal data from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at legal@fountainlife.com.

L. Changes to Our Privacy Policy

We may update our Privacy Policy from time to time. If we make material changes to how we treat your information and/or personal data, we will post the new Privacy Policy on this page with a notice that the Privacy Policy has been updated and notify you by email to the primary email address specified in your account as well as provide a notice on the Online Platform the first time you use the Online Platform after we make the change. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this Privacy Policy to check for any changes.

M. Contact Information

Please address questions, comments, and requests regarding this Privacy Policy and our privacy practices to:

Fountain Life Management, LLC

13495 Veterans Way, Suite 330

Orlando, FL 32827

Attn: Jeffrey N. Norton, Chief Legal Officer and Chief Privacy Officer

Email: care@fountainlife.com or legal@fountainlife.com

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Our Chief Privacy Officer is Jeffrey J. Norton.

Our corporate headquarters are located at 13495 Veterans Way, Suite 330, Orlando, FL 32827.

PRIVACY POLICY

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