ComplianceReward℠

Program Privacy Policy

Last Updated on April 9, 2020

Welcome to ComplianceReward℠, combining patient adherence, profitability and loyalty using state of the art patient security and blockchain based micro-payments using ethereum's erc20 protocol (the "Service"), made available to you by Ingenious Mobility Ventures, LLC, a Delaware limited liability company ("IMV", "we", "us", and "our"). This Privacy Policy describes our policies on the collection, use, and disclosure of information about you in connection with your use of the Service, which may occur via our website www.compliancereward.com ("Website") or the ComplianceReward℠ mobile application ("Application").

Your privacy is important to us. It is our policy to protect your personal information and to use it only in accordance with this Privacy Policy. This Privacy Policy only governs our use and disclosure of information collected through this Website, Application or any component of the Service. When you use the Website, Application or any component of the Service, you consent to our collection, use, and disclosure of information about you as described in this Privacy Policy. If you do not consent to the collection, use and disclosure of your information as set forth above, you may not access or use the Website, Application or Service. Any capitalized term not defined in this Privacy Policy has the meaning given that term in the ComplianceReward℠ Terms of Service.

Modifications to This Privacy Policy

We may, at our sole discretion, revise this Privacy Policy from time to time. The most current version of the Privacy Policy will be made available to you on the Website and within the Application. If we make material changes to this Privacy Policy, we will notify you on the Website or within the Application or both by posting a conspicuous notice on the Service prior to the effective date of the changes and you will be required to review and opt-in to the revised terms to continue to access the Service. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy. If you do not agree to the revised Privacy Policy, you may terminate your account as set forth in the Terms of Service.

International Users

IMV is based in the United States and the Service is hosted in the United States. If you are accessing the Service from outside the United States, by providing your information to IMV and using the Service, you hereby consent to the transfer of your information to the United States for processing, storage and maintenance in accordance with this Privacy Policy and our Terms of Service. You are also consenting to the application of United States law in all matters concerning the Service.

Information We Collect and Your Choices on How We Use It

You may download the Application and visit the Website without providing us any personally identifiable information, although we will collect non-personally identifiable information regarding your visit as set forth below. In order to access and use the Service, we require you to provide us with certain information to create an Account.

We collect and use the following information

Account Information : If you register to create an Account, we require you to submit your first name, last name, date of birth, email and zip code. We will also collect any other information that you choose to submit in connection with your Account, which may include your gender and address. We will use your Account to communicate with you and you can access information associated with your Account and the communications settings for your Account within the Settings and User Profile pages of the Service or by emailing ComplianceReward@.com. You cannot opt out of receiving communications from IMV that are administrative or legal notices related to your Account, the Website, the Application or the Service.

Practice Information :If you register to create a Practice Account, we require you to submit your practice type e.g. pharmacy, practice name, website, address, email and zip code in addition to professional licenses, and identification as well as key staff and personnel and their contact information. We will use your Account to facilitate service transactions, communicate with you and you can access information associated with your Account and the communications settings for your Account within the Practice Profile pages on the Client DAshBoard of the Service or by emailing ComplianceReward@.com. You cannot opt out of receiving communications from IMV that are administrative or legal notices related to your Account, the Website, the Application or the Service.

User Activity : We may collect, or have collected on our behalf, information about your use of the Service, such as your user activity, the pages you view and the date, time and duration of your activity. We also may collect and store information that your computer or mobile device provides to us in connection with your use of the Service, Website and Application, such as your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, unique device identifier (e.g. Google Advertising ID (GAID), Android ID, ID for Advertisers (IDFA), ID for Vendors (IDFV), MAC address, International Mobile Equipment Identity (IMEI), or other device IDs), location, requested and referring URLs, and other information about your device(s), operating system, and the state or country from which you accessed the services. We use this information for marketing purposes and to understand how you interact with the Service.

Location Information : In order to enhance your user experience and increase the usefulness of the Service, with your consent, we may access your location. IMV will only access your location while you are using the Application and provided you have opted in to activate this feature. You may choose to allow IMV to access your location by granting the Application access to your device's location, when prompted by the Application, or through your device's location services settings. You may also provide us with a zip code in using the Website IMV uses the Google Places API(s) for location searches and as a result is using the Google Maps/Google Earth API(s). Pursuant to the Google Maps/Google Earth APIs Terms of Service, use of this location feature is also subject to the Google privacy policy, which can be found at www.google.com/privacy.html, and is incorporated with this reference.

Technical data and related information : In order to enhance your user and practuceaPexperience and increase the usefulness of the Service, with your consent, we may use such as information about your device, internet connection, system and application software, peripherals and other data related to your interactions with the Products (“Technical Information”). Metadata and other information associated with other files stored on your device, such as camera images and photos (“Metadata”). Information from your web browser about your activities over time and across third-party products, applications or other online services (“Online Tracking Information”).

Personal Information In order to provide our services, we share personal Information with the practices, e.g., licensed pharmacies, in order to fulfill and deliver services or orders placed through the application. ComplianceReward uses certain health information provided to it by the the practices, e.g., licensed pharmacies in compliance with applicable federal and state laws, including but not limited to the Health Information Privacy and Protection Act. The practices use Personal Information submitted by ComplianceReward in accordance with the policies and procedures of each such practices, and such use of Personal Information by the practices may not be under the control of ComplianceReward. ComplianceReward hereby disclaims any and all liability for any type of damages including, but not limited to, indirect, incidental, consequential or special damages, or losses of expenses, for the actions and customer information processing of any of the practices.

We do not sell, rent, loan, or lease any Personal Information. We may disclose Personal Information to the government or private parties in connection with a lawsuit, subpoena, investigation, regulatory examination or similar proceedings. We may also disclose Personal Information where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms, to verify or enforce compliance with the policies governing the ComplianceReward application and applicable laws, or as otherwise required or permitted by law or consistent with legal requirements. Additionally, in the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, or a transfer of any type of our assets to another company, Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by the Terms.

Personal Information may be stored locally on your mobile device and may be transmitted across our servers in the United States. The transmission of information over wireless and wired networks is not inherently secure. We encrypt data transmitted through the ComplianceReward application using SSL technology to help protect the Personal Information. The only ComplianceReward representatives, agents or employees allowed to access Personal Information are those who are authorized by ComplianceReward to do so and/or access such Personal Information in order to ensure that the orders placed through the ComplianceReward application are transmitted to a Licensed Pharmacy, and filled and delivered to you in a timely and efficient manner.

Cookies: Cookies are small data files that consist of unique identifiers and reside on your computer, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of the Service, such as your browser type, search preferences and the date and time of your use. Cookies may be persistent or stored only during an individual session and may serve the following purposes:

• To prevent fraud, protect your data from unauthorized parties, and comply with legal requirements. For example, we use cookies to determine if you are logged in to the Service or not.
• To remember information about how you prefer the Service to behave and look. For example, we use cookies that tell us whether or not you have declined to allow us to use location information.
• To make the Service work in the way you expect it to. For example, we may use a cookie to tell us whether you have already signed up for the Service.
• To help us understand how visitors use the Service. For example, we employ analytics that use cookies to identify which type of device and operating system version you are using to access the Service and how that may affect your user experience.
• To allow notice of information or options that we think could improve your use of the Service. For example, we may use a cookie to allow us to stop showing you the sign-up screen if you have already signed in.
• To gain information about your online activities in order to provide you online ads and other marketing materials as set forth below.

Managing Cookies: It may be possible to disable some (but not all) cookies through your device or browser settings, but doing so may affect your ability to use the Service and your preference settings may not be saved. The method for disabling cookies may vary by device and browser, but can usually be found in preferences or security settings.

Ad Networks: We use third party ad networks (called third-party ad servers or network advertisers, including Google, Tapjoy, UpRival and Conversant) to deliver ads to you on our behalf. These third party ad networks may place their cookies, web beacons or other technology on the Website or the Application or in your browser to collect non-personally identifiable information about you when you visit this Website or use this Application (such as browser type, time and date, browsing or transaction activity, subject of advertisements clicked or scrolled over, or a platform-provided identifier during your visits to this and other websites) to enable those third party ad networks to deliver to you advertisements on third party websites and mobile applications for our products or services or those of third parties that are likely to be of greater interest to you. For example, Google uses the Doubleclick cookie to enable it and its partners to serve ads to you based on your visit to our Website and/or other sites on the Internet.

We encourage you to view the privacy policy of advertisers and ad services to learn more about their cookies and other technologies. To learn more about interest-based advertising, or to opt-out, you can visit www.networkadvertising.org.

If you do not want to receive those kinds of advertisements, look for the "Ad Choices" icon in the advertisements, which will contain a link to the privacy policy of the ad network that will provide you with information on how to opt-out of receiving such targeted advertising.

Website Analytics: Like many websites, our Website uses Google Analytics to collect information about your use of our Website. This information consists of information that your web browser automatically sends to Google, such as the web address of the page that you visit and your IP address. Google may also set cookies or read preexisting cookies. This information is stored on Google´s servers. Google uses this information to provide us with reports about traffic to our website and your visit to our website (such as the domain from which you access the internet, the web address of the website from which you linked to our site, the time and date of your visit to the web pages that you view and click through). We will use this data to improve our website structure and content.

Google may also use this data in accordance with their Privacy Policy, which can be found at www.google.com/policies/privacy.For more detailed information on how Google uses your data through our Site, please visitwww.google.com/policies/privacy/partners.

You may opt-out of our use of Google Analytics by visiting the Google Analytics opt-out page and installing the Google Analytics browser add-on, currently made available by Google at tools.google.com/dlpage/gaoptout.

Google Analytics Advertising Features: We have also enabled the following Google Analytics Advertising Features: Google Display Network Impression Reporting, Remarketing with Google Analytics and Google Analytics Demographics and Interest Reporting. The Google Display Network Impression Reporting uses the Google Analytics cookie to track our ad impressions and your interactions with those impressions, including the effectiveness of those ads, which generates reports for us to help us analyze our advertisements. Remarketing with Google Analytics uses the Google Analytics cookie to serve advertisements to you across the Internet based on your visit to our Web Site. Google Analytics Demographics and Interest Reporting uses a third party cookie to collect information about our website traffic by tracking users across websites and across time, which generates a report for us to better understand our website users.

We also use the Google AdWords service to serve ads on our behalf across the Internet and sometimes on this Website. Google uses cookies (or other similar identifiers) to collect anonymous information about your visits to our Website and your interaction with our products and services to generate targeted advertisements to you on other sites that you visit across the Internet.

If you do not want Google to collect and use this information you may visit the Google Ad Settings page (www.google.com/safetycenter/tools/#manage-your-ads-preferences) or you can also visit the websitewww.networkadvertising.org/choices as referenced above to change your consumer preferences with respect to certain online ads and to obtain further information about third party ad networks and online behavioral advertising. For the Google Analytics Advertising Features, you may also opt-out of our use of Google Analytics as described above. Please remember that changing your settings with certain browsers and ad networks will not carry your privacy choices across browsers and other ad networks.

Application Analytics: We use Tapjoy to provide analytics regarding the Application. Tapjoy has the right to collect, retain, use, and publish in an aggregated manner, any information collected by Tapjoy in connection with our use of the Tapjoy analytics service, which Tapjoy may share with third parties, pursuant to their terms and privacy policy, home.tapjoy.com/info/about-tapjoy/privacy-policy. If you prefer not to receive ads that are tailored to your interests, you can opt out of Tapjoy using your information to provide you interest-based ads at any time by going to the Tapjoy Opt-Out page: home.tapjoy.com/info/third-party-opt-out.

Attribution Analytics: We use Tune to track attribution and advertising analytics on the Application. Tune tracks device identifiers and IP addresses on our behalf, which may also be used for marketing purposes as described elsewhere in this Privacy Policy. You may choose to opt out of our use of the Tune analytics at www.optoutmobile.com.

Facebook and Social Media: The Service may allow you to connect and share information with Facebook. This feature may require us to implement cookies and/or APIs provided by such social media platform to facilitate the communication. We may share information that you provide us or that we may collect about your use of the Application or Website with Facebook, which information becomes subject to Facebook's Data Policy.

In addition, by choosing to use any third party social media platform or choosing to share content or communications with any social media platform, you allow us to share information with the designated social media platform. IMV cannot control any policies or terms of such third party platform. As a result, we cannot be responsible for any use of your information or content by a third party platform, which you use at your own risk.

Online Health Initiative Survey: We may collect survey information from time to time. We may use all of the survey information that we collect for our internal business purposes. We may also aggregate and anonymize any survey information and license and distribute the same. In addition to the purposes set forth above, we use the information we collect to fulfill your requests, provide the Service, improve the performance and quality of the Application and Website, personalize your experience, track usage of the Service, provide feedback on the Service, provide customer support, communicate with you about your Account and use of the Service, back up our systems and allow for disaster recovery, enhance the security of the Service, and comply with our legal obligations.

How We Share Your Information

We may share information about you with third parties as follows:

Aggregate Information: We may share user information in the aggregate with third parties advertisers and content distributors for our own marketing purposes. For example, we may disclose the number of users that use the Service, how they use the Service and basic non-personal demographic data. We will not share to third parties your personal information in a manner that identifies you for any direct marketing purposes by such third parties nor sell information that could be used to identify you as an individual.

Investigations: We may investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure is (a) reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us; (b) helpful to prevent, investigate, or identify possible wrongdoing in connection with the Service; or (c) protect our rights, reputation, property, or that of our users, affiliates, or the public.

Our Suppliers: We contract with a number of service providers and vendors that will have access to your information as necessary to provide the Service, Application or Website. These service providers and vendors consist of our third party marketing and ad agencies, our information technology vendors, and our customer service call center vendors. Information shared may include but is not limited to your personally identifiable information, the analytics tools discussed above and other analytic tools used to report information to us should we experience technical issues with the Application, Website or the Service or for various other purposes related to providing the Application, Website or the Service.

Sale or Transfer of Business or Assets: If we are sold or disposed of as a going concern, whether by merger, reorganization, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, any and all personally identifiable information, including your Account information may be one of the assets sold or merged in connection with that transaction. Information about you may also need to be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support, or funding. In such transactions, personal information will be subject to the promises made in any pre-existing Privacy Policy in effect when the information was obtained.

Do Not Track

We will automatically collect cookies and other non-personally identifying information when you visit the Website or use the Application. Due to this automatic collection, we do not currently honor "do not track" requests. We currently participate in third party ad networks and use third party cookies as discussed above to track your visits across websites.

Data Retention and Account Termination

You can close your account by emailing us at ComplianceReward@.com. We will remove your Account from active status, but we may retain information about you for the purposes authorized under this Privacy Policy unless otherwise prohibited by law.

Links

The Service may contain links to unaffiliated third party websites. We have no responsibility or liability for such third party websites and do not endorse the same. Except as described in this Privacy Policy, we do not share your personal information with them, and are not responsible for their privacy practices. We suggest you read the privacy policies on all third party applications, websites or services that you visit or use.

HIPAA

IMV, to the extent it is a “covered entity” under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) has its own privacy and security obligations with respect to your PHI. We encourage you to contact any registered practice, e.g., pharmacy, regarding their privacy and security practices (for more information regarding your rights under HIPAA, see http://www.hhs.gov/ocr/privacy).

To the extent IMV is a “business associate” of any Practice or Pharmacy under HIPAA, we have agreements in place with them requiring us to only use and disclose your PHI as they are permitted to under HIPAA. This Privacy Policy and the privacy and security practices described in this Privacy Policy are designed to comply with these agreements. As such, among other obligations, we will:

• use reasonable and appropriate safeguards to keep your PHI that we collect private and confidential;
• alert you in accordance with the guidelines set forth under HIPAA if we are made aware of any unauthorized access to your PHI that we have collected; and
• provide you access in a reasonable time and manner to your PHI we have collected and make any reasonably requested amendment thereto.

IMV may de-identify Personal Health Information pursuant to the Health Insurance Portability and Accountability Act (“HIPAA”) and aggregate patient’s de-identified information with other IMV user information, and use such aggregated information for population based research activities and analytics; Treatment, payment, enrollment, or eligibility for benefits are not conditioned upon patient reviewing the privacy policy; when information is used or disclosed, it may be subject to re-disclosure and may no longer be protected by state or federal privacy regulations.

California Privacy Rights

If you reside in California, we are required to provide additional information to you about how we use and disclose your information, and you may have additional rights with regard to how we use and disclose your information. We have included this California-specific information below.

CA Personal Information. We collect certain categories and specific pieces of information about individuals that are considered "Personal Information" under California law ("CA Personal Information"). Specifically, we may collect the following types of categories of CA Personal Information and have listed some representative data elements in each category:

• Identifiers: such as name, address, telephone number, email address, age, date of birth, username and password for our websites, online identifiers, IP address;
• Characteristics of protected classifications under California or Federal Law such as sex, gender, age (40 or older);
• Commercial information: such as products or services purchased, obtained or considered, other purchasing or consuming histories or tendencies, payment information, Balance Rewards and Balance Rewards for healthy choices® participation information;
• Internet or other electronic network activity information: such as computer and connection information, statistics on page views, traffic to and from the websites, ad data and other standard weblog information;
• Geolocation information: such as physical location information through the use of our Services on your mobile phone or device by, for example using satellite, cell phone tower, Wi-Fi signal, beacons, Bluetooth and near field communication protocols;
• Audio, visual, or similar information: such as photographs you share, in-store security video, customer service audio recordings; and
• Inferences drawn from other personal information: such as consumer preferences, characteristics, predispositions, and behavior.

Sources. We may collect certain categories of CA Personal Information from you and third parties. The categories of sources from whom we may collect CA Personal Information include the following:

• On our websites and mobile applications (parent, subsidiary and affiliate brands)
• When you communicate with our Customer Care Center
• Third party websites and mobile applications (e.g., websites that share information with us or our advertising partners regarding your online activities)
• Data Suppliers (e.g., companies that provide demographics and other information regarding consumers)
• Delivery partners/carriers
• Social media companies
• Other service providers
• Survey providers

Purposes. We collect CA Personal Information for the business and commercial purposes. We also share and/or disclose CA Personal Information as follows:

Sharing your CA Personal Information for business purposes: As described above, we may share the following categories of CA Personal Information with third parties who are considered "service providers” as defined under California law since we disclose CA Personal Information to them for our business purposes. We also list representative data elements for each of these categories of CA Personal Information:

• Identifiers: such as name, address, telephone number, email address, age, date of birth, username and password for our websites, online identifiers, IP address;
• Characteristics of protected classifications under California or Federal Law: such as sex, gender, age (40 or older);
• Commercial information: such as products or services purchased, obtained or considered, other purchasing or consuming histories or tendencies, payment information, and Balance Rewards participation information;
• Internet or other electronic network activity information: such as computer and connection information, statistics on page views, traffic to and from the websites, ad data and other standard weblog information;
• Geolocation information: such as physical location information through the use of our Services on your mobile phone or device by, for example using satellite, cell phone tower, Wi-Fi signal, beacons, Bluetooth and near field communication protocols, when you are in or near a Walgreens store;
• Audio, visual, or similar information: such as photographs you share, in-store security video, customer service audio recordings; and Inferences drawn from other personal information: such as consumer preferences, characteristics, predispositions, and behavior. As described above, examples of business purposes include product and service fulfillment, internal operations, prevention of fraud and other harm, and legal compliance.

Sharing CA Personal Information with third parties: As described above, we may share the following categories of CA Personal Information with third parties who are considered "third parties” as defined under California law since we disclose CA Personal Information to them which they may use for secondary purposes. Our disclosure of CA Personal Information to the third parties who use the information for secondary purposes may constitute a "sale” of CA Personal Information as defined under California law. You may stop our potential disclosure of your CA Personal Information to these entities for their use for secondary purposes by opting out of the sale of your CA Personal Information as described in the California Consumer Rights section below. We also list representative data elements for each of these categories of CA Personal Information:

• Identifiers: such as online identifiers, IP address;
• Commercial information: such as products or services purchased, obtained or considered, other purchasing or consuming histories or tendencies;
• Internet or other electronic network activity information: such as computer and connection information, statistics on page views, traffic to and from the websites, ad data and other standard weblog information;
• Geolocation information: such as physical location information through the use of our Services on your mobile phone or device by, for example using satellite, cell phone tower, Wi-Fi signal, beacons, Bluetooth and near field communication protocols; and
• Inferences drawn from other personal information: such as consumer preferences, characteristics, predispositions, and behavior.

California Consumer Rights. Subject to certain exceptions, as a California resident, you have the right to: (i) request access to your CA Personal Information (including information regarding the sharing of your CA Personal Information); (ii) request deletion of your CA Personal Information; and (iii) opt out of the sale of your CA Personal Information.

Exercise your California Consumer Rights by:

Contacting our Customer Care Center: Please submit a written request to the following address: Ingenious Mobility Ventures, LLC, 9001 Airport Freeway, North Richland Hills, TX 76180. Please allow at least thirty days to receive a response to such request.

.Please note that in order to opt out of the sale of CA Personal Information implicated by advertising cookies when browsing our digital properties as a guest, you must click the “Do Not Sell My Personal Information” link and save your preferences.

Additionally, California law requires California residents under the age of 16 to opt in to the sale of CA Personal Information. As a result, certain programs and services may be unavailable to California residents under the age of 16.

Children's Privacy

Only persons 18 years of age or older are permitted to use the ComplianceReward application. The ComplianceReward application is not directed toward children under 13 years of age nor does IMV knowingly collect Personal Information from children under 13 years of age unless Personal Information is provided by the parents or guardians of such children.

Security

Your privacy and the security of your information is very important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it, including two-factor authentication for access to your Account and SSL encryption for data transmission. However, no method of transmission over the Internet or via mobile device, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Contacting Us

If you have any other questions or concerns regarding this Privacy Policy, please contact us as follows:

Via email at: info@ComplianceReward.com

Or by Mail at:

Ingenious Mobility Ventures, LLC

9001 Airport Freeway,

North Richland Hills, TX 76180