Jaan Health, Inc., (“JHI,” “we,” or “us”) recognizes and respects the importance of protecting the privacy of our customers and our customers’ contacts. Accordingly, we have set forth the following policies and practices to help protect your personal information. By providing JHI with any personal information, you agree to the terms of this Privacy Policy. JHI may change this Privacy Policy from time to time and any such changes will be posted to https://phamily.com/privacy for your review. If you do not agree with this Privacy Policy or amendments hereto, please do not use the JHI Web site or the Phamily® services.

For the purposes of this Privacy Policy the following definitions shall apply:

1. “Customer” or “you” refers to entities or individuals inquiring about or using the JHI Web site or
   the Phamily services, and those individuals designated by a Customer to utilize the Services on
   its behalf. Customers may include Users, Family Members or Physicians participating in the
   Phamily services (as those terms are defined in the Phamily Terms of Use).
2.  “Contacts” or “Contacted Parties” refers to individuals or entities that have received an
   invitation to participate in the Phamily services as requested by a Customer. Contacts or
   Contacted Parties may include Users, Family Members or Physicians participating in the Phamily
   services (as those terms are defined in the Phamily Terms of Use).

Scope of Policy. This Privacy Policy applies to all the services, including the Phamily services, and any early release or evaluation offerings, and Web sites offered by JHI (collectively, the “Services”) and to all personal information that JHI directly collects or receives from you in any form. This Privacy Policy does not apply to information or content that our Customers send to or receive from their Contacts utilizing the Services. While we take commercially reasonable measures to protect all personal information in our control or possession, we cannot guarantee or enforce the privacy policies of our Physician Customers or Contacts. For this reason, we encourage individuals to review the privacy policies of any applicable Physician before disclosing personal information to our through them.

What Is Personal Information? Personal information is any information that identifies you or your
Contacts as individuals. Personal information includes names, addresses, phone numbers, e-mail addresses, and identification numbers; financial information, such as credit card or checking account information; and may include the content of messages sent to and from you and your Contacts.

How is Personal Information Collected and Used? We may collect personal information from you
through our Services, for various purposes, including but not limited to, the following: (a) to facilitate the delivery of Services to you; (b) to provide information that you request; (c) to provide you with a
customized interactive experience; (d) to measure interest in various Services; (d) to inform you about new Services and features; and (e) to help us develop new Services and features that meet your needs. If you choose not to provide requested personal information, we may be unable to process an order, fulfill a services request, or display certain content on the Web site. We do not sell, rent or give personal information to unrelated third parties.

JHI may also utilize a technology called “cookies” to provide you with tailored information when you return to our Web site. Cookies are pieces of information that a Web site transfers to your computer’s hard disk to store information about your preferences on that site. We treat any personal information that may be contained in cookies with the same level of protection as other personal information that you provide to us. However, if you prefer, you may set your browser to refuse cookies. If you refuse cookies, JHI may not be able to deliver full functionality for certain Services requested by you. Third party vendors, including Google, may use cookies to serve ads to you based on your prior visits. You may opt out of Google’s use of cookies by visiting the Google advertising opt-out page.

How Does JHI Safeguard My Personal Information? JHI uses industry standard precautions to safeguard your personal information, and that of your Contacts, from misuse or access without authorization. Personal information is stored on our own systems or on the systems of our affiliates or contractors. Access is restricted to those employees of JHI and its affiliates or contractors who have a need for such access to perform legitimate business functions relating to the Services including, but not limited to, billing, maintenance, internal security or upgrades. Any contractor whom we retain to provide services to us and who will have access to personal information must agree to abide by the terms of this Privacy Policy.

Under What Circumstances will JHI disclose Personal Information? JHI discloses personal information provided to us under very limited circumstances. These may include the following: (a) to the extent we reasonably deem such disclosure to be required by law or to respond to judicial process; (b) to protect the security and integrity of our Services; (c) to protect our rights and property and the rights and property of others; (d) in connection with a merger, consolidation or sale of all or substantially all of the stock or assets of one or more of our businesses; (e) to provide personal information to a Customer pursuant to a Contacted Individual’s request to stop receiving further communications through the Service; or (f) pursuant to a Customer’s specific direction in connection with a Service we are providing on behalf of a Customer.

How does JHI provide access to Personal Information it has collected? Customers seeking access to personal information that they have provided directly to JHI may contact our Privacy Compliance Officer as set forth below. In some instances, we may not be able to grant Customer requests, such as if the personal information: (a) contains references to other persons; (b) is subject to attorney-client or litigation privilege; (c) includes JHI proprietary or confidential information; (d) has been destroyed in accordance with data retention policies; (e) is too costly in our sole determination to retrieve; or (f) cannot be disclosed for other legal reasons.

How Does JHI Protect the Privacy of Children? JHI is concerned about the privacy and safety of children. The Services are not intended to be used by children under the age of 18. When we collect personal information during registration, we do not knowingly invite or permit individuals under the age of 18 to use our Services.

What About Third Party Sites? The Services may contain links to third party Web sites. JHI is not responsible for the privacy practices of these third parties. Customers and Contacted Parties are solely responsible for reviewing the privacy policies of these third parties before disclosing any personal information to or through them.

For all inquiries relating to the JHI Privacy Policy, please contact the Privacy Compliance Officer at
privacy@jaanhealth.com.

July 14, 2023