Zephyr AI Privacy Policy

We at Zephyr AI (Zephyr AI, Inc. and our subsidiaries and affiliates) are committed to protecting your privacy. This privacy policy applies to our applications, software, websites, APIs, products, and services owned and controlled by Zephyr AI.

This Privacy Policy governs our data collection, processing and usage practices. It also describes your choices regarding use, access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use our Services.

Specifically, this Privacy Policy covers:

INFORMATION WE COLLECT ABOUT YOU

When you use our Services, we collect the following types of information.

INFORMATION YOU PROVIDE US ("PERSONAL INFORMATION")

ACCOUNT INFORMATION. Some information is required to create an account on Services, such as your:

• name,

• email address,

• password,

• company,

If you contact us or participate in a survey, contest, or promotion, we collect the information you submit such as your name, email address, contact information, and message.

INFORMATION PROVIDED BY OTHER INDIVIDUALS. While using our Services, individuals may provide information about another individual, or an authorized user (such as an account administrator) creating an account on your behalf may provide information about You. When one individual provides us with information (including personal information) about another individual, we assume that the individual has permission and authority to do so and to consent on behalf of that individual to the collection and use of personal information as described in this Privacy Policy. Please contact us immediately if you become aware of an individual providing us with personal information about another individual without being authorized to do so, and we will act consistently with this Privacy Policy.

INFORMATION WE RECEIVE FROM YOUR USE OF OUR SERVICES

USAGE AND DEVICE INFORMATION. When you use our Services, we receive certain usage data ("Usage and Device Information"). This includes information about your interaction with the Services, for example, when you view or search content, install or open applications or software, create or log into your account, import data into your account, or integrate a third-party service to your account. We may also collect data about the devices and computers you use to access our Services, including IP addresses, browser type, language, operating system, or mobile device information (including device and application identifiers), the referring web page, pages visited, location (depending on the permissions you have granted us), and cookie information.

HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes.

PROVIDE AND MAINTAIN THE SERVICES

We use the information we collect to deliver the Services to you and honor our Terms of Service for each Service or business contract with you. For example,

• to administer, operate, maintain and secure our Services;
• to monitor and analyze trends, usage and activities in connection with our Services;
• for accounting, recordkeeping, backup and administrative purposes;
• to customize and improve the content of our communications, websites and social media accounts;
• to provide customer service and support;
• to communicate with you, including responding to your comments, questions and requests regarding our Services;
• to process and complete transactions, and send you related information, including alerts and notifications about your service, purchase confirmations and invoices; and
• to educate and train our workforce in data protection and customer support.

IMPROVE, PERSONALIZE, AND DEVELOP THE SERVICES

We use the information we collect to improve and personalize the Services and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys and develop new features and Services.

COMMUNICATE WITH YOU

We use your information when needed to send you Service notifications and respond to you when you contact us. We also use your information to promote new features or products that we think you would be interested in. You can control marketing communications and most Service notifications by using your notification preferences in account settings or via the "Unsubscribe" link in an email.

PROMOTE SAFETY AND SECURITY

We use the information we collect to promote the safety and security of the Services, our users and other parties. For example, we may use the information

• to authenticate users;
• to facilitate secure payments;
• to respond to a legal request or claim, conduct audits, and enforce our terms and policies;
• to investigate and protect against fraud, malicious or unauthorized access, and other illegal activities; and
• to demonstrate and verify compliance with our internal policies and procedures, and applicable privacy and data security laws and regulations, such as HIPAA and GDPR.

USE AND DISCLOSURE OF DE-IDENTIFIED INFORMATION

"De-identified" means that we have removed, or rendered unreadable through complex computational algorithms, personally-identifiable information, such as name, address, or birthdate. We may use de-identified information that we have obtained from our Services for various purposes, including for example:

• In accordance with regulatory requirements, we may de-identify, store and use your information for internal quality control, validation and research and development. This is important for Zephyr AI to maintain high quality Services. We may use de-identified information as permitted by law.
• We may use or disclose de-identified information for general research and communications purposes. This may include analysis of this information to communicate observations and learnings, for example in the case of aggregated data. This may also include research collaborations with third parties, such as universities, hospitals or other laboratories, in which we utilize de-identified clinical cases, at the individual level or in the aggregate, in accordance with our study protocols, and we may present or publish such information. This may also include commercial collaborations with private companies for purposes such as to determine the prevalence of particular disorders or variants among the patients we have tested, or to determine whether any of the patients we have tested might be suitable for potential recruitment for research, clinical trials, or clinical care; however, we will not directly contact these patients about these opportunities without their prior written consent.

HOW WE SHARE YOUR INFORMATION

We do not share your personal information except in the limited circumstances described below.

FOR EXTERNAL PROCESSING

We transfer information to our corporate affiliates, service providers and other partners who process it for us, based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures. These partners provide us with services globally, including for customer support, information technology, payments, sales, marketing, data analysis, research and surveys.

FOR LEGAL REASONS OR TO PREVENT HARM

We may preserve or disclose information about you to comply with a law, regulation, legal process or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect or investigate illegal activity, fraud, abuse, violations of our terms or threats to the security of the Services or the physical safety of any person. Please note: Our policy is to notify you of legal process seeking access to your information, such as search warrants, court orders or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period. Exceptions to our notice policy include exigent or counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to a person. We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, in public reports about exercise and activity, to partners under agreement with us or as part of the community benchmarking information we provide to users of our subscription services. If we are involved in a merger, acquisition, or sale of assets, we will continue to take measures to protect the confidentiality of personal information and give affected users notice for the transferring of any personal information to a new entity.