Privacy Policy

Introduction

We at CoaguSense (“CoaguSense”, “we”, “us” and/or “our”) value your privacy and prioritize protecting your Personal Information and using it solely to propel our mission to provide our products and services (as described below, collectively the “Services”) that help you make informed decisions about your care.

In this Privacy Policy (the “Privacy Policy” or “Policy”), we provide you with detailed information about our collection, use, maintenance, and disclosure of your Personal Information. This Policy explains what kind of information we collect, when and how we might use that information, how we protect the information, and your rights regarding your Personal Information.

Please read the following carefully to understand our views and practices regarding your Personal Information. To the extent permitted by applicable law, by using our website (“Website”) or purchasing our Products, you acknowledge that you have read and agreed to the terms of this Policy. If you do not agree, please do not access our Website or use our Products or Services, and do not submit any information to us.

When Does This Policy Apply?

This Privacy Policy applies to the following Personal Information that is collected or processed:

• When you engage with online activities or through our other services (such as our Website, online contact forms, customer service, or other marketing efforts).
• When you purchase our Products, whether directly through us or through your medical treatment facility, healthcare provider or distributor (“Provider”) or complete a transaction with us.
• In other instances when you interact with us, such as by visiting our office or events, engage with us at trade shows or conferences, or request training services or assistance with our Products.
• When you interact with us in a professional capacity, such as if you are a Provider, or employee of a Provider or other company we partner with, or through our recruiting efforts.

What Information Do We Collect and Why?

Personal Information is any information that identifies, relates to, or can be linked to an natural person (“Personal Information”). We may collect certain Personal Information from you when you purchase our Products or otherwise engage with our Website or Services. This information may include your name (or company name), email address, mailing address, phone number, IP address, or geolocation data. We may collect this information from you to provide you with our Products or Services, and primarily to monitor and improve any issues users experience with our Products. While we do not request any health or medical information from you directly, you may voluntarily share this information with us, and hence we may collect such information when you use our Products or engage with our Services. Because the Personal Information we collect and transmit may include Protected Health Information or other medical information, our privacy practices are intended to comply with the Health Insurance Portability and Accountability Act (“HIPAA”). While we do not use this data for any purpose or share it with anyone, we will maintain the privacy of your health information as required by HIPAA and the regulations promulgated under the Act.

Where is Your Personal Information Processed and/or Stored, and How is it Protected?

We process and store your Personal Information on servers located in the United States and endeavor to implement adequate physical, technical, and administrative safeguards to protect your information.

Will CoaguSense Share Personal Information with Anyone Else?

Services and Marketing. CoaguSense does not sell your Personal Information. We may share your personal data with certain third parties, including:

• Our affiliated companies and subcontractors for the purpose of providing or improving the Website, Products or Services.
• Third party providers such as telemarketing companies for marketing, research, analytic, and data storage and processing purposes.

Legal Disclosures: We may also disclose Personal Information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to:

• Comply with any applicable law, regulation, legal process or governmental request;
• Enforce our policies, including investigations of potential violations thereof;
• Investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
• Establish or exercise our rights to defend against legal claims; or
• Prevent harm to the rights, property or safety of us, our Website, you, or any third party.

Disputes. In case of any dispute with or concerning you, we may disclose Personal Information relating to you with our legal counsel, professional advisors and service providers, the relevant court or other tribunal and other third parties as needed in order to resolve the dispute, defend ourselves against any claims, or enforce our rights.

Mergers and Acquisition. In the event that we, or a part of our business, are sold to a third party, or if we are merged with another entity, or in the event of bankruptcy or a similar event, we will transfer information about the relevant portions of our business as well as relevant customers and users, to the purchaser or the entity with which we are merged.

External Links. Our Website may contain links to other websites or services. However, we are not responsible for their privacy practices. We encourage you to be aware of when you leave our Website and access a third party website or service (including those of your Provider), and to read the privacy policies of every website and service you visit. This Privacy Policy applies only to CoaguSense’s Website, Products, and Services.

Do We Collect Personal Information from Your Providers?

If you purchase our Products through a Provider, we generally do not collect Personal Information about you from your Provider. However, if you have purchased the Product through a Provider and we discover an issue that could potentially lead to a Product recall, we may request that your Provider share certain

Personal Information about you, including health information, which could be related to the recall.

Will Providers Protect Your Personal Information?

Yes, all Providers are required to use all reasonable measures to protect your Personal Information. For more information on your Provider’s privacy practices, please refer to their Privacy Policy.

How Long Will CoaguSense Retain Your Personal Information?

CoaguSense will retain your data for as long as necessary for the purpose for which it was collected, or for as long as necessary to comply with our legal obligations, resolve disputes or complaints, or enforce our policies. We may rectify, remove, or replenish incomplete or inaccurate information at any time and at our own discretion. If you have any questions or would like to request to know more about the information we have collected about you, please contact us at support@coagusense.com.

Does CoaguSense Utilize Cookies?

Yes, CoaguSense uses cookies to measure your activity on the Website and does not collect any Personal Information in the process. We do not track individuals’ online activities over time and across third party Web sites or online services, nor do we allow third parties to collect Personal Information about you when use the Site. We do not respond to web browser “do not track” signals or similar mechanisms.

How Can You Update, Correct or Delete Your Personal Information?

To submit a request to know what Personal Information we have collected about you, or to update, correct or delete such information, please contact us at support@coagusense.com. In your message, please include a detailed description of the request.

Can You “Opt Out” Of Receiving Communications from CoaguSense?

If you would like to opt out of our mailing marketing efforts, please send us an email at support@coagusense.com. To opt out of promotional emails, please click on the “unsubscribe” button located at the bottom of the applicable email and follow the instructions to unsubscribe.

Does This Privacy Policy Apply to All Information You Provide?

This Privacy Policy does not apply to any unsolicited feedback you provide to CoaguSense through the Service or through any other means. This includes, but is not limited to, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Feedback”). All Feedback shall be deemed to be non-confidential and CoaguSense shall be free to reproduce, use, disclose, and distribute such Feedback to others without limitation or attribution.

What Rights Do EU Users Have Under the GDPR?

EU users have the right, at any time, to know whether their Personal Data has been stored and can consult with us via support@coagusense.com to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to us at the contact information set out above.

If you are a resident of the European Union, please note that the following rights specifically apply regarding your personal information under the Regulation (EU) 2016/679, known as the General Data Protection Regulation (the “GDPR”): (1) Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information; (2) Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format; (3) Request rectification of your personal information that is in our control; (4) Request erasure of your personal information; (5) Object to the processing of personal information by us; (6) Request to restrict processing of your personal information by us; (7) Lodge a complaint with a supervisory authority. However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

We may be permitted by law (including the GDPR and local national laws) to refuse or limit the extent to which we comply with your request. We may also require additional information in order to comply with your request, including information needed to locate the information requested or to verify your identity or the legality of your request. To the extent permitted by applicable law, we may charge an appropriate fee to comply with your request.

Cross Border Transfers. We transfer European users’ Personal Information to the United States, where we and our marketing services company are located, and where our third-party web hosting provider stores our data. Please note that some data recipients may be located outside the EU. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection. We transfer European users’ Personal Information to the United States under the following conditions:

• Contractual obligation, or where transfers are necessary to satisfy our obligation to you under our

Customer Agreement or the applicable agreement with your Provider, including to provide you with or to optimize and enhance our Services and customer support service.

• Consent, or where you have consented to the transfer of your Personal Information to the United States. Where transfers to the United States are based on your consent, you may withdraw your consent at any time. Please understand, however, that our Products and Services may not be available if we are unable to transfer your Personal Information to the United States.

Safeguards. When we transfer Personal Information to the United States, we endeavor to ensure adequate safeguards are implemented. If you are an individual protected by the GDPR, you may contact us at support@coagusense.com to obtain additional information regarding the basis for the transfer of Personal Information relating to you to countries outside the EU. Please note that information or copies of documents we may provide to you in connection with such requests may be limited or redacted in order to protect the rights of third parties or to comply with contractual obligations we may have (such as obligations of confidentiality).

How CoaguSense Makes Changes to This Policy

We occasionally update this Privacy Policy. It is your responsibility to stay up to date with any amended versions. If we modify this Privacy Policy, we may notify you of the changes through either a notice on the Website, an email notification, or other reasonable means. You can store this Policy and/or any amended version(s) digitally, print it, or save it in any other way. Any changes to this Privacy Policy will be effective immediately, and shall apply to all information we maintain, use, and disclose. By continuing to use the Website, Product, or Services following such changes, you consent to those changes.

Anonymous Information

We may use information we collect or receive which cannot be connected to any particular person or which is anonymized or aggregated such that it can no longer be connected to or used to identify any particular person as Personal Information, even if it was originally linked to or stored with Personal Information. Such information cannot be used to identify you or any other person. We may useanonymous information internally for a variety of purposes, including improving the Website, Products and Services, and may share it with third parties or even publish it for any reason.

How Can You Contact CoaguSense?

Please feel free to contact us if you have any questions about this Privacy Policy or the information practices of the Service. You may contact us by email at the following address: support@coagusense.com.