Last updated May 22nd, 2023

At Zei, Inc. ("us", "we", "our" or Zei) we want to assure you that we take the duty of collecting, using and safeguarding your data seriously. We therefore hope that you take a moment to review this policy.

This iOS Privacy Policy of Zei. ("Zei") applies to the Basis Health app, we make available through the Apple ®App Store here referred to as ("Mobile App"). This Privacy Policy is subject to the Zei Terms of Use. By using Basis Mobile App, you agree with the terms of this iOS Privacy Policy.

Our Contact Details

Zei, Inc.

Address: 651 N. Broad St., Suite 206, Middletown, 19709, USA

Email Address: hi@basishealth.io

Website: www.basishealth.io

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1. Information We Receive

The information we receive about you (which we refer to collectively as your "Personal Information") includes Registration Information, Feedback Information, Data Services Information, Use Information, Apple HealthKit Information and Derived Information.

We only collect Personal Information if you have given your consent to collection of Personal Information. You can revoke your consent and opt-out of data collection at any time, see Section 2.

1.1. "Registration Information"

Registration Information is information you are required to provide in order to register with HE in connection with your use of our Mobile App. Any Registration Information is collected by requesting you to input the relevant data.

When registering through our Mobile App and while using the Mobile App, we process the following general account data as inserted by you:

• Name;
• Email address

1.2. "Feedback Information"

Feedback Information is information you submit to us in connection with your use of Zei Products and Services, whether through our Website, through our Data Services, or otherwise, regarding Zei Products and Services, or other matters relating to us and our business, including the metadata relating to that information.

1.3. "Data Services Information"

Data Services Information is information we receive and transmit automatically through our Mobile App, including the following measurement data which is tracked and collected through our supported sensor(s):

• Blood glucose readings;
• Information associated with each glucose reading, including date, time and device identifier;
• Statistical measures calculated from your blood sugar data (e.g. stability score);
• Heart rate readings;
• Information associated with each heart rate reading, including date, time and device identifier;
• Statistical measures calculated from your heart rate data (e.g. heart rate variability).
• Sleep data;
• Calendar data.

1.4. "Use Information"

1.4.1. "General Use Information"

General Use Information is information we receive automatically from the mobile phone you use in connection with the Mobile App, and information we automatically receive from the Mobile App regarding your use, which may include your IP address and other information regarding your device, your internet service, and your activities while using Zei Products and Services, such as how often you open Software Apps, your settings and other activity regarding your use of the components of Zei Products and Services;

1.4.2. "Specific Mobile App Use Information"

Specific Mobile App Use Information is information we automatically receive from the mobile phone you use in connection with the Software Apps produced and offered by Zei. This includes:

• Associated timestamps and frequency of sensor scan actions;
• Associated timestamps and frequency of meal/exercise card creation actions;
• General information and statistics regarding your use and inspection of the Mobile App

1.5. "Apple HealthKit Information"

You may opt to integrate Software Apps with the Apple HealthKit™ database. Software Apps cannot read or write to the HealthKit database without your explicitly granted permission. Apple HealthKit Information that we receive includes:

• General information about your sleep (e.g. total length of sleep)
• General information about your exercise and workouts (e.g. total length of workout)

1.6. "Derived Information"

Derived Information is information that we create by combining and/or analysing some or all of your Personal Information.

1.7. "Google User Information"

When you sign in to the Service, we collect and store encrypted Google authentication tokens. We do not process or send any information to a database or server owned by Basis except for calendar names, level of access to each calendar name, and tasks you input into the Service. All processing of calendar events Basis retrieves occurs locally on your device or on Google’s servers. When you authenticate with the Service using your Google account, we use that account to fetch the calendar events you see in the Service and to create the calendar events and tasks you may schedule within the Service.

Basis' use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements. Refer to the Google API Services User Data Policy here:

https://developers.google.com/terms/api-services-user-data-policy

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1.8. "Other Information"

If any of the Personal Information described above does not reveal your specific identity or relate directly to an individual, we may use such "Other Information" for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use it for all the purposes for which we use and disclose Personal Information.

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2. Your Rights and Responsibilities

• Right to access your data*

You have the right to access your personal data processed by us. You may contact us at support@basishealth.io and we will inform you of what personal data we have collected and processed regarding you.

• Right to revoke consent*

You have the right to refuse or withdraw consent to collection of Personal Information. If you wish to revoke consent, contact us at support@basishealth.io or change your permission settings in your device.

• Right to update, delete and correct your data*

If you would like to correct, update, or delete personal information related to your account you can update and delete your information either in the Mobile App Settings or by contacting us at support@basishealth.io.

For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable. Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed. You must comply with the terms of the Agreement.

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3. Use of Information

• To provide you the service*

We process personal data in the first place to be able to offer the app and service to our Users in accordance with their user contract.

• For communication*

We may process personal data for the purpose of communicating with Users. If you contact us with questions regarding your app data, we will use the provided information to answer your questions and for solving any issues you may have.

See Sections 3.1-3.8 regarding the Use of Information for each Information type.

3.1. Registration Information

We use Registration Information to manage your account and Zei Products and Services applicable to you, and as otherwise described below. We also use your email address to contact you regarding your account. We do not make any Registration Information public. We will use your User Account and Registration Information to link your use of Zei Services and Software Apps with your use of Zei Products, and it may be accessible by our personnel providing Zei Services.

3.2. Feedback Information

Feedback Information may be used by us and provided by us to our customers and third parties, in the form you provide as well as in excerpted, aggregated and anonymized forms, with or without attribution to you as the source. We may also use Feedback Information in our advertising, marketing and other communications with the public and in our business relationships, as well as in our internal communications, in each case with or without attribution to you as the source.

3.3. Data Services Information

We collect Data Services Information and store it on our servers, process it using Data Services, and transmit it to the User and each Designated Recipient, where applicable. We may use Data Services Information in connection with our provision of Data Services and for our operations, administration and product development, maintenance and support. We may remove information that identifies you from Data Services Information, and we may use such de-identified data for our business purposes as we determine, such as research and development, product improvements, business operations and process improvements, marketing purposes, including disclosing such de-identified data to third parties for their use as we determine.

Any third party with whom we share Personal Information will provide the same or equal protection of your Personal Information as stated in our Privacy Policy.

3.4. Use Information

3.4.1. General Use Information

We collect Use Information and store it on our servers, process it using our systems, and analyze it for our business purposes. We do not disclose to third parties any Use Information that can identify you (except as permitted in this Privacy Policy), but we may remove information that identifies you from Use Information, and we may provide such de-identified Use Information to third parties as we determine for their use.

Any third party with whom we share Personal Information will provide the same or equal protection of your Personal Information as stated in our Privacy Policy.

3.4.2. Specific Mobile App Information

We collect Specific Software Apps Use Information information and store and process it through a third party, Segment. This data is stored on Segment’s database and also may subsequently be processed and stored with another third party, Mixpanel. This information is only used to improve the Software Apps and guide future Software Apps developments.

Any third party with whom we share Personal Information will provide the same or equal protection of your Personal Information as stated in our Privacy Policy.

3.5 Apple HealthKit Information

Data or Documents accessed from the HealthKit database will never be shared with third party service providers without your explicit permission. Your HealthKit sourced data or documents will only be used, with your permission, to display a wider range of health data in the Software App, to display blood sugar behavior in relation to other health data or for the purpose of health research, and will never be shared with advertisers or used for marketing purposes.

The information you provide directly from the Apple Health App (i.e., not through Zei) is governed by the Apple Terms and Conditions and Privacy Policy. Zei is in no way responsible for the protection of data and information stored within the Apple HealthKit database.

3.6. Derived Information

We may use Derived Information to determine information, including Solicitations (defined in the next section), to be sent to you, the public or to targeted groups, and for our business purposes in accordance with the applicable provisions of this Privacy Policy.

3.7. Personal Information and Solicitations

As permitted by applicable law, we may use Personal Information (except for Apple HealthKit Information) of you and your Designated Recipients, if applicable, to determine which emails and notices we send to you and your Designated Recipients, if applicable, including emails and notices regarding opportunities relating to our Products and Services (we refer to these emails as "Solicitations"). You may opt out of Solicitations by contacting us by email at support@basishealth.io or by mail at the address listed in the "Contact Us" section below, and you may opt in again through one of those contacts. We will try to comply with your request as soon as reasonably practicable. Please keep in mind that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out. As permitted by applicable law, we may share your email address or other Registration Information with third parties with which we contract for the purpose of providing you with Solicitations we think may be of interest to you. You may opt out of our sharing of your information with third parties for these purposes by contacting us by email at support@basishealth.io.

3.8 Personal Information and Your Zei Experience

‍We may use Personal Information (except for Apple HealthKit Information) to manage our Products and Services, including the Website, to improve our business and provide new website and product and service features, and to otherwise manage our business, but without disclosing your Registration Information except as necessary for such purposes.

3.9. Other Third Parties

In the ordinary course of our business, we will share Personal Information with companies we hire to perform services or functions on our behalf. We will not authorize those third parties to keep, use or disclose your Personal Information except for providing the services we have asked them to provide. We may provide your Personal Information to another company in conjunction with a corporate sale, merger, acquisition or dissolution involving Zei.

Any third party with whom we share Personal Information will provide the same or equal protection of your Personal Information as stated in our Privacy Policy.

3.10. Law Enforcement and Legal Proceedings

‍ We will use and disclose Personal Information as we are required to do by applicable law, including laws outside your country of residence, and may disclose Personal Information when requested by law enforcement authorities or regulatory agencies, including public and government authorities outside your country of residence, or when we determine that such disclosure is appropriate under the circumstances. We may use and disclose Personal Information to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; to protect our operations or those of any of our affiliates; to enforce this Privacy Policy; and to allow us to pursue available remedies or limit the damages that we may sustain.

3.11. De-Identification

‍We may "de-identify" your Personal Information by removing information that could identify you, and we may use such de-identified information for any purpose, except where we are required to do otherwise under applicable law.

3.12. Other Uses

‍We may use your Personal Information for purposes other than those permitted in this Privacy Policy but only after you consent to such use.

3.13. Data retention

We may store your Personal Information only for as long as is necessary for the above mentioned purposes. When storing your Personal Information is no longer necessary, we will delete your data. Once we have deleted your Personal Information, you will not be able to exercise the right to access, the right to delete or the right to change your Personal Information.

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4. More on Privacy

4.1 Children's Online Privacy Protection

• *‍**Zei does not permit any person under 18 to use the Mobile App or to directly purchase Zei Products.

4.2 Adults With Guardians, Conservators or Other Legal Supervision

• ***Zei does not permit any person to subscribe directly to or use Zei Services, or Mobile App or to directly purchase Zei Products if that person lacks the legal competence to enter into a contract and be bound to the terms of the Agreement. A legal guardian, conservator or other person with the legal right to do so may subscribe for a User who lacks the legal competence to enter into a contract and be bound to the terms of the Agreement, but no such User is permitted to use Zei Services or Software Apps without the express agreement of a legal guardian, conservator or other person with the legal right to provide such agreement to the terms of the Agreement, which require, among other things, that such legal guardian or other person is responsible for designating Designated Recipients, connecting the User Device to Zei Services and Software Apps, interacting in all ways with Zei Services and Software Apps, and ensuring that all communications with us come from the such legal guardian or other person and not from the User who lacks legal competence.

4.3. Phishing

We do not and will not, at any time, request Registration Information in a non-secure or unsolicited email or telephone communication. Identity theft and the practice currently known as "phishing" are of great concern to us. Safeguarding information to help protect you from identity theft is a priority for us. For more information about phishing, visit the Federal Trade Commission website.

4.4. Security

Zei uses commercially reasonable standards of technology and operational security to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you feel that your interaction with us is no longer secure, please immediately notify us in accordance with the "Contact Us" section, below.

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5. Terminating Your Account

You may terminate your mobile app data by deleting the application and contacting us at support@basishealth.io.

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6. Changes

We may change this Privacy Policy by posting a new version of this Privacy Policy. When we update this Privacy Policy, we will update the date at the top of this page to indicate when this Policy was last updated. Any changes will become effective when we post the updated Policy on our Website. Your use of our Products and Services following these changes means that you accept the updated Policy. If you do not agree with any change, you may terminate your account as provided above and may choose not to submit any further Personal Information.

If you have any questions about this iOS Privacy Policy or wish to "opt-out" of Solicitations, please: (1) send us an email at hi@basishealth.io.

Because email communications are not always secure, please do not include credit card information or sensitive information in your emails to us.