Introduction

Your privacy is important to us. TruLite, Inc. (“we,” “us,” “our,” and “TruLite”) respects the privacy of every person who visits our website (www.trulitehealth.com) and we are committed to protecting privacy through compliance with this TruLite Website Privacy Policy (“Website Privacy Policy”).

This Website Privacy Policy explains how we collect, use, disclose, and otherwise process Personal Information in connection with our website and related interactions you have with us in connection with your use of our website (collectively, our “Website”).

This Website Privacy Policy does not apply to information collected by TruLite through other sources, including but not limited to our service platform(s). For more information about the privacy practices that apply to the use of our service platforms(s), please refer to the specific privacy policy governing those service platform(s). You can also request a copy of these privacy policies by contacting us at info@trulitehealth.com.

This Website Privacy Policy is written in the English language. We do not guarantee the accuracy of any translated versions of this Website Privacy Policy. To the extent any translated versions of this Website Privacy Policy conflict with the English language version, the English language version of this Website Privacy Policy will control.

Consent to Privacy Policy

Please read this Website Privacy Policy carefully to understand our policies and practices regarding your Personal Information and how we will treat it, including the collection, use and disclosure of your Personal Information. By accessing or using our Website, you agree to this Website Privacy Policy. This Website Privacy Policy may change from time to time (see Changes to Our Website Privacy Policy). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

IF YOU DO NOT AGREE WITH ALL OF THE PROVISIONS OF THIS WEBSITE PRIVACY POLICY, THEN YOU MUST NOT USE OR MUST STOP USING OUR WEBSITE IMMEDIATELY.

What is “Personal Information”

Personal Information is generally any information that either directly or indirectly identifies, relates to, or describes a particular individual or household, or is reasonably capable of being associated with or could reasonably be linked to a particular individual or household. What is considered to be Personal Information may depend on where you live and the laws that apply to the data that we may collect about you. Information that does not identify you is not your Personal information for purposes of this Policy. Deidentified is not considered your Personal Information.

Personal Information We Collect About You

We collect several types of information from and about users of our Website, including:

• Identifiers. We may collect identifiers such as your name (real name and alias), postal address, unique personal identifier, online identifier, email address, mailing address, telephone number (including a cell phone number), and Internet Protocol (IP) address.
• Commercial Information. We may collect information about the products or services you have purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Professional or Employment-Related Information. We may collect information about your current job or past job history, including the name of the organization you work for and your title.
• Other Personal Information. We may collect other Personal Information about you such as your signature.
• Device Information. Information about the device and browser you use to access our Website.
• Internet or Other Similar Network Activity. We may collect information about your activity on our Website, such as your browsing history on our Website, search history on our Website, and browser information. We typically collect this information from our use of Automated Technologies to help us design our Website, to identify popular features, for our own Advertising, and for other managerial and business purposes.
• Sensory data. If you call us about our products or services, or ask us to call you, we may record the call with our customer service representative or sales team. We also may collect electronic communications you send us in connection with the Website, such as emails and text messages. Please read the Section on Electronic Communications to learn more about how we may communicate with you.
• Inferences Drawn from Personal Information. We may draw inferences from the information we collect about you to create a profile that reflects your preferences, characteristics, geographic location, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and/or aptitudes.
• Website Review and Comments. Comments, reviews, and suggestions about our Website.
• Other information. Other Information that is about you, but generally does not identify you individually, such as your browsing activity on our Website or on other third-party websites.

How We May Collect Your Personal Information

We may collect Personal Information and other information about you in different ways, including:

• Directly From You. For example, Personal Information that you provide by filling in forms on our Website, completing surveys or reviews about TruLite, or when you email, text message or call us. This includes Personal Information provided at the time of requesting further information about our services. We may also ask you for information when you report a problem with our Website or otherwise contact us.
• Personal Information and Other Information We Collect Automatically as You Navigate Through Our Website. As you navigate through and interact with our Website, we may use Automated Technologies to collect certain information about your equipment (e.g., computer and Internet connection, including IP address, operating system and browser type), browsing actions and patterns, including details of your visit to our Website and the resources that you access and use on the Website. Please read the Section on Automated Technologies for more information about the technologies we use to collect this information.
• Personal Information and Other Information We Obtain From Third Parties. We may also obtain information about you from our service providers, contractors and other third parties in connection with our Website or through other means if they are permitted by the laws that apply to them to share this information with us. For example, if we create user profiles, we may include other publicly available information in that profile.

How We May Use Your Personal Information

We may use Personal Information that we collect about you, or that you provide to us, for one or more of the following purposes:

• To fulfill or meet the reason you provided the Personal Information;
• To operate our business;
• To provide support for, personalize, and develop our Website, products and services to you, including your use of interactive features on our Website and for our own benchmarking and analysis;
• To create, maintain, customize, and secure an account with us;
• To provide you with customer service support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our interactions with you;
• For our own advertising and marketing as described in the Section on Advertising;
• To help maintain the safety, security, and integrity of our Website and services, databases and other technology assets, and business;
• For testing, research, analysis, and product development, including to develop and improve our Website, products and services;
• To respond to law enforcement requests, subpoenas, or other legal processes, or as otherwise required by law, by court order, or to respond to a governmental/regulatory request;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or a similar proceeding, or as part of a financing transaction;
• To comply with our legal obligations or to protect our interests, property or legal rights, or those of our customers or third parties, such as to enforce our Terms of Use or to exercise or defend legal claims;
• To detect and prevent fraud and other prohibited or illegal activity;
• To notify you about changes to our Website or any products or services we offer or provide though the Website;
• In any other way we may describe when you provide the Personal Information; and
• For any other purpose with your consent.

We may use information that does not identify you without restriction, unless we are required by applicable law to restrict how we use that information.

How We May Disclose Personal Information About You

We may disclose Personal Information that we collect, or that you provide to us, as described below for the following business purposes:

• To a parent organization, subsidiary or affiliate;
• To our contractors, service providers, and other third parties that we use to support our business, such as by helping us to operate and manage our Website and to provide products and services that you may purchase from us. They may also include without limitation our professional advisors who may provide us with legal, compliance, accounting, banking, or consulting services. Our contractors and service providers may have access to your Personal Information to provide these services. We implement reasonable protections on their use of Personal Information;
• To companies or other entities in connection with, or during the negotiations of, any merger, divestiture, restructuring, reorganization, dissolution, acquisition, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or a similar proceeding, or as part of a financing transaction;
• To comply with any law, court order, subpoena, request from law enforcement or other legal processes, including but not limited to responding to any government or regulatory request, or when we believe in good faith that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of this Privacy Notice or other applicable terms;
• To enforce or apply our Website Terms of Use and other agreements, including for billing and collection purposes;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of TruLite Health, our customers, or others;
• To advertise our products and services to you as described in the Advertising Section;
• To fulfill the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information; and
• At your direction or with your consent.

We do not knowingly sell your Personal Information to third parties. If we change our practices, we will update this Notice in accordance with Changes to Our Website Privacy Policy.

Automated Technologies

We and our service providers and contractors may use cookies, web beacons, and other technologies (collectively, “Automated Technologies”) to receive and store certain types of information whenever you interact with our Website through your computer or mobile device to improve the quality of our services, including for storing user preferences, tracking user trends, and providing relevant advertising to you.

• What are cookies? A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows the website to recognize your browser. Cookies may store unique identifiers, user preferences, and other information. Cookies can be set by a website owner like TruLite or they can be set by third parties (e.g., Facebook, Google, etc.). Third-party cookies may also be used to enable analytics (e.g., Google Analytics) or advertising functionality (e.g., ad re-targeting on third-party websites) that enables more customized services and advertising by tracking your interaction with a website and collecting information about how you use the website.
• What are web beacons? Web beacons are small electronic files (also referred to as clear gifs, pixel tags, and single-pixel gifs) on webpages that permit a website owner like TruLite to, for example, count users who have visited those pages and collect other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). Pixels may also be used by website owners like TruLite and our service providers and contractors to reach out to you about our products and services after you leave our site.

The information we collect through Automated Technologies may or may not contain Personal Information about you. This information helps us to improve our Website by enabling us to do things like estimate our audience size and usage patterns; store information about your preferences to customize our Website according to your individual interests; speed up your searches; recognize you when you return to our Website; and to support the other activities described in this Website Privacy Policy, such as Advertising.

You can reset your browser to refuse all cookies or to alert you when a cookie is being sent. However, some Website features or services may not function properly without cookies. Please keep in mind that your browser settings may not permit you to control the technologies utilized by third-party companies. There are third-party companies that are unaffiliated with TruLite who can provide you with more information about third-party advertising and your opt out choices, such as the Digital Advertising Alliance WebChoices Tool.

TruLite may use the following Automated Technologies offered by our service providers and contractors to assist us with the following activities:

• Google Analytics. TruLite may use Google Analytics (or other similar web analytics tools). Google Analytics is a web analytics service provided by Google, Inc. to collect certain information relating to your use of the Website. Google Analytics uses cookies to help us analyze user activity. We may also use Google Analytics Advertising Features or other advertising networks to reach out to you again about our services after you leave our Website.
• Facebook, LinkedIn and HubSpot Pixels. TruLite may use pixels from social media sites, like Facebook or LinkedIn, so that we can reach out to you again if you permit these sites to display our advertisements to you. These pixels only send information about your use of our Website. We do not use these pixels to track your activity on other websites.

Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Website Privacy Policy.

Advertising

We may deliver to you content and marketing communications that we think may interest you. We may also use Automated Technologies (as described above) and information about how you browse our Website to show you advertisements (ads) for TruLite. We may also send you TruLite ads in response to your request for information or feedback. We do not collect your browsing information from third-party websites to display third-party ads to you.

You may opt out of receiving marketing emails from us by following the unsubscribe link in each email, or by emailing us at info@trulitehealth.com. You may continue to receive non-marketing emails from us after you opt-out.

Electronic Communications

We may need to contact you about the Website, your activity on our Website and our services. By giving us your contact information, you have agreed that TruLite, as well as our affiliates, business partners, service providers and contractors, may contact you for these purposes. These communications may be done by automated dialing equipment and/or artificial or prerecorded messages. You may receive multiple messages each day.

You must follow the requirements of this Website Privacy Policy and our Website Terms of Use when contacting us via email or text message. Please note that the information you provide to us through the Website may not be secure (not encrypted). Email via the Internet or other electronic means, such as through your device’s text messaging service, may not be secure (not encrypted). There are risks associated with unsecure communications that you should consider. These risks include (without limitation) that an unauthorized person may get access to these communications. By engaging us in unsecure communications, you agree to accept these risks and consent to receive unsecure communications in response from us.

How We Protect Your Personal Information

TruLite takes reasonable steps to keep your Personal Information secure and to protect against the loss, misuse, or alteration of your Personal Information on the Website. Although TruLite has these security measures in place, it cannot guarantee your privacy. The transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are also not responsible for circumvention of any privacy settings or security measures contained on our Website.

Retention of Your Personal Information

We retain your Personal Information only for as long as is necessary to accomplish the purposes we outline in this Website Privacy Policy and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with laws that apply to us), resolve disputes, and enforce our legal agreements and policies.

Consent To Processing of Personal Data in United States and Transfer of Personal Information

We are based in the United States and this Website is intended for use only by residents of the United States. If you are a citizen of the European Economic Area (EEA) or other jurisdiction outside of the U.S., please note that in order to provide our Website, products, and services to you, we may send and store your Personal Information (also commonly referred to as personal data) outside of the EEA, including to the U.S. Accordingly, your Personal Information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personal Information. By using and accessing our Website, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of Personal Information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

Children’s Use of our Website

Our Website is intended for use by adults only. Our Website is not intended for use by children who have not reached the age of majority, which in most states is eighteen (18) years of age. No one under the age of majority may provide any Personal Information to or on our Website. We do not knowingly collect, sell or share Personal Information of children who have not reached the age of majority. If you have not reached the age of majority, do not use or provide any information on this Website. If we learn we have collected or received Personal Information from a child who is under the age of thirteen (13), we will delete that information. If you believe we may have received information through our Website from or about a child who has not reached the age of majority, please contact us at info@trulitehealth.com.

Third-Party Links

The Website may contain links to third-party owned or operated websites (collectively, “Linked Sites”). This Website Privacy Policy and the practices that we follow under this Website Privacy Policy do not apply to Linked Sites. We are not responsible for the content, accuracy, or opinions expressed on any Linked Site or for the privacy practices or security standards used by third parties on such Linked Sites. These Linked Sites have separate privacy and data collection practices, and we have no responsibility or liability relating to them. Accordingly, if you use Linked Sites through our Website, or share information about your experience on our Website with others, these Linked Sites may be able to collect information about you, including information about your activity on our Website. You understand and agree that by clicking on a link to a Linked Site or using a Linked Site as described above, this Website Privacy Policy, as stated on the Website, is no longer in effect because you have either left our Website or used a Linked Site to interact with our Website.

Changes to Our Website Privacy Policy

We may change our Website Privacy Policy at any time and for any reason. If we make changes, we will revise the Effective Date at the top of this Policy. Changes to this Policy will be effective once they are posted unless otherwise indicated. Please check our Website periodically for updates. You agree to any changes to our Website Privacy Policy by your continued use of our Website after the Effective Date.

Terms of Use

Your use of our Website is also subject to TruLite’s Website Terms of Use. Any disputes related to this Website Privacy Policy will be governed by the applicable provisions of the Website Terms of Use, which are incorporated into this Website Privacy Policy by reference.

Contact Information

If you have questions or concerns about our Website Privacy Policy and privacy practices or the use of your information, please contact us at

Attn: Chief Financial Officer

Mailing Address: 222 S. Mill Avenue, Suite 800, Tempe, AZ 85281

Phone #: 602-805-1751

Toll Free: 888-272-7935

Email Address: Legal@TruLiteHealth.com