SVS-STF-1 Inc., a Utah corporation d/b/a MedCart (“MedCart,” “we,” or “us”), strives to respect the privacy of end users on our Online Platforms and has developed this Privacy Policy & Notice of Collection (this “Privacy Policy”) to demonstrate our commitment to protecting your information in our capacity as a data processor and service provider acting on behalf of our healthcare and institutional clients, and as a data controller in the normal course of our business. Please note that this Privacy Policy governs your online access as an end user to our website, online platforms and features, and any mobile or stand-alone applications we may support in connection with our Services (collectively our “Online Platforms”). Accordingly, this Privacy Policy describes to you what information we collect, how we may use your information, with whom we may share your information, your rights with respect to information we gather and process, and how you can exercise your rights or prevent unauthorized disclosure of your information.

PLEASE READ THIS PRIVACY POLICY, WHICH ALSO SERVES AS A NOTICE OF COLLECTION FOR ALL INFORMATION YOU SUBMIT, CAREFULLY BEFORE ACCESSING OUR ONLINE PLATFORMS OR OUR SERVICES. BY USING OUR ONLINE PLATFORMS, YOU ARE ACCEPTING THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY.

ABOUT OUR ONLINE PLATFORMS.

We publish and maintain our Online Platforms to provide you, as an end user, with remote access to the ‘Medical Cart AR’ augmented reality training software available through the Online Platforms and customized for your organization (our “Services”). When you visit our Online Platforms outside of a relationship with your institution (for example, to simply demo the Services of your own initiative), we are generally the controller of information and data we collect (if such information can identify you), and we will use and process it in accordance with this Privacy Policy. If you are accessing our Services based on a prompt, invite, access code, or notice from your healthcare institution or employer, your institution is generally our client, and we process your personal information or data on their behalf as a service provider and processor. In those scenarios, we only process personal information as instructed in writing by your healthcare institution (under a separate services agreement) and in accordance with this Privacy Policy.

1. INFORMATION WE COLLECT ABOUT YOU.

As you access and interact with our Online Platforms, MedCart or our support service providers may collect (i) personal information or data that can potentially identify you, as described in more detail below, and (ii) other non-personal information or publicly available data that does not identify you, such as submissions to our Services and Online Platforms or backend cloud computing information that cannot be traced to your identity.

With respect to identifying information, we strive to limit our collection activities to information that DOES NOT identify you unless you voluntarily opt in to providing that information through our Online Platforms in order to use the Services. That said, we may collect the following information or data about you when you access our Online Platforms, some of which may qualify as personal information or nonpublic personal information under applicable laws:

• Log-in and Account Information (through Google Firebase). If you access our Online Platforms based on the access code we provide to your healthcare institution, we may collect, store, process, and use certain information such as (i) your unique password, email address, phone number, and IP address; and (ii) a unique device ID generated for your mobile device when you install the app (which is specific to our Services ). In certain scenarios, we may elect to indirectly gather this information through Google Firebase, which serves as a mobile and web app development platform to support functionality of our Services.
• Approximate Country Location (through Google Firebase). In your use of the Online Platforms as an end user, we may also gather information through Tracking Technologies and Google Firebase concerning your approximate country of location if location services are turned on through your device or browser settings.
• Services Usage Information (time challenges). Finally, as you interact with our Online Platforms and Services, you may voluntarily elect to complete certain timed challenges that ask you to input your name and group ID into text fields. This type of submission is entirely optional as you interact with the Online Platforms.

In general, we collect this information directly from you, or automatically from you and your device using Tracking Technologies (defined below), when you access the Online Platforms. As noted in the categories above, we may also periodically obtain both personal and non-personal information about you from affiliates, business partners, add services, and other third parties (such as Google Firebase) when those parties lawfully share the information with us.

YOU ARE NOT REQUIRED TO PROVIDE PERSONAL INFORMATION TO US WHILE USING OUR ONLINE PLATFORMS (FOR EXAMPLE, THROUGH DISABLING OR BLOCKING TRACKING TECHNOLOGIES). However, if you choose not to provide us with certain information, you may not be able to fully access our content and Services.

IN ADDITION, WE GENERALLY DO NOT COLLECT INFORMATION THAT IS CONSIDERED SENSITIVE UNDER DATA PROTECTION LAWS, such as a government issued identification number, racial or ethnic origin information, biometric data, precise geolocation data, or specific details of your treatment to patients or clients.

2. USE OF TRACKING TECHNOLOGIES (COOKIES).

In addition to our direct collection efforts described above, MedCart may use, in our reasonable discretion, various tracking technologies, collection systems, cookies, Google Analytics, and Google Firebase (collectively, “Tracking Technologies”) to collect personal and non-personal information from your device based on your activity on our Online Platforms, doing so according to this Privacy Policy.

As you may already know, Tracking Technologies retain information about your activity on our Online Platforms and other online locations to disclose that information to us or the owner of the applicable webpage. When you access our Online Platforms, we may use Tracking Technologies to follow your usage of our Online Platforms and the content you review. The information we obtain in this manner enables MedCart to customize the Online Platforms and to measure the overall effectiveness of our online presence. We may also allow third parties, advertising companies, and ad networks to display advertisements on our Online Platforms from time to time, some of which may include links to those third-parties’ own sites. These companies may also use Tracking Technologies to collect information about users viewing or interacting with their advertisements. These third-party sites have separate and independent privacy policies, notices of collection, and terms of use. We do not assume responsibility or liability for the content and activities of these linked sites, and we encourage you to directly review the policies and privacy practices on those sites.

You may choose to opt out of certain Tracking Technologies by modifying your browser and device settings. If you do so, however, some of the information or content on our Online Platforms may be inaccessible. WE RECOMMEND YOU REVIEW YOUR DEVICE SETTINGS TO CONFIRM IF TRACKING TECHNOLOGIES, INCLUDING GEOLOCATION TRACKING, HAVE BEEN PROPERLY DISABLED OR CONFIGURED TO YOUR PREFERENCE. For information concerning Google Firebase, please review their separate policies here: https://firebase.google.com/support/privacy/.

3. PURPOSES FOR WHICH WE MAY USE THE INFORMATION WE COLLECT.

We collect, use, and process your personal and non-personal information to pursue our legitimate business interests, perform our ongoing contractual obligations with our institutional clients, and market information concerning MedCart and our Services. In furtherance of those purposes, we may use the information that we collect about you to:

• Operate, maintain, and provide features of the Online Platforms.
• Perform research and analysis about our Services.
• Perform our contractual obligations with third parties, including our financial institution clients.
• Contact users of the Online Platforms to provide support after such users voluntarily contact us.
• Conduct surveys for our own internal or marketing purposes.
• Aggregate information and end user reports to more effectively offer and develop tools and training augmented reality modules on the Online Platforms.
• Comply with legal obligations and prevent illegal activity, fraud, or abuse.
• Enforce or defend the intellectual property and other rights underlying our Online Platforms and Services if we detect misuse of those rights.
• Use the information as otherwise described to you in our Terms of Use or in our separate services agreement relationships with your institution or employer.

4. HOW AND WITH WHOM WE MAY SHARE YOUR INFORMATION.

If you have accessed our Services based on the invite or prompt from your institution or employer (doing so as an end user), we may share your end user reports, access and training logs, or other content from the Online Platforms with your institution or employer.

In maintaining our Online Platforms, we may also use, process, or sell aggregate information that does not identify you, such as survey responses, aggregated reports, and other statistical information, for any purpose permissible under applicable data and consumer privacy laws. We may share your personal information for commercial purposes with others, such as our subsidiaries or affiliates, AI Tools, contractors, service providers (including third party marketing partners), developers, and other third parties we use to support our Online Platforms and Services so long as those parties are bound by contractual or fiduciary obligations to keep your personal information secure and to use it only for the purposes for which we disclose it to them (e.g., in support of our Online Platforms).

We may also share personal information if we believe in good faith that doing so is required by law or is otherwise required to exercise or defend legal rights, take precautions against liability, protect the rights of any individual, protect the integrity and proprietary rights of the Online Platforms, protect the Services or others from fraudulent or unlawful activity, or defend against third party claims.

In general, we may also submit your information to our automated decision making technologies or machine learning tools (each, an “AI Tool”) if doing so is reasonably related to one of the purposes described in Section 3 above. That said, if you wish to opt-out of any AI Tool use of your personal information (assuming we have implemented any such AI Tool) or request further information concerning our application of AI Tools, please contact us at the information below.

5. YOUR RIGHTS CONCERNING YOUR PERSONAL INFORMATION.

U.S. Consumer Rights. Pursuant to applicable U.S. data protection and consumer privacy laws, you may contact us to request the exercise of certain rights concerning your personal information, including the right to: (i) request that we disclose the categories and specific pieces of personal information we have collected and disclosed about you; (ii) confirm and know whether we have processed or sold your personal information; (iii) request information about MedCart’s disclosure of personal information to our affiliates, AI Tools, and service providers (including for their marketing purposes); (iv) opt-out of MedCart sharing your personal information with third parties and our service providers; (v) request that we provide a copy of your personal information to you (data portability); (vi) request that we update your personal information or correct any inaccuracies you have detected through your use of the Online Platforms; (vii) opt-out of any direct or indirect profiling or targeted advertising we may engage in based on your use of the Online Platforms and our Tracking Technologies; or (viii) request that we otherwise delete your personal information. You also have the right to lodge a complaint with a supervisory authority if you believe we have breached the terms of this Privacy Policy with respect to your personal information. Depending on where you are located, some of these rights may not apply or may be subject to limitations. For example, we may limit the number of requests you make or charge reasonable fees as legally permitted. YOU WILL NOT FACE DISCRIMINATION FOR EXERCISING YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION.

Exercising your rights. You or your authorized representative may contact us (at the contact information below) to request the exercise of these rights set out above. Your request must provide sufficient information that allows us to reasonably verify you are the data subject about whom the request is made and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Opt-out instructions. If you wish to opt-out of certain features of the Online Platforms or our Tracking Technologies (including our use of AI Tools in the Services), please contact us at the information set out below and we will provide instructions.

6. AGE RESTRICTIONS (PRIVACY OF CHILDREN).

Our Online Platforms (and the Services) are not generally intended for persons under 16 years of age to access and review. If you are under the age of 16, please do not provide any personal information to MedCart through the Online Platforms or review the Services available on the Online Platforms. We do not knowingly collect personal information from anyone under the age of 16, and if you believe we might have any information from or about a person under 16, please notify us immediately at the information set out below.

7. VISITING OUR ONLINE PLATFORMS FROM OUTSIDE THE UNITED STATES.

Please be aware that if you visit our Online Platforms from any jurisdiction outside of the United States, your information may be transferred, stored, and processed in the United States—which primarily serves as the main location of our data servers. Data protection and other consumer laws in the United States might not align with those in your jurisdiction, even in light of the consumer rights we have disclosed above. By accessing the information on our Online Platforms, you understand that your personal information and data may be transferred to our facilities and to those third parties with whom we share the information, as we’ve previously explained in this Privacy Policy.

8. DATA RETENTION PERIOD & SECURITY MEASURES.

We retain your personal information for a reasonable period to fulfill the purposes for which we collected it (as outlined in this Privacy Policy), including to defend our rights under the Online Platforms and the Services. If we no longer reasonably need personal information for such purposes, we will, at our election and in accordance with applicable data protection laws, delete it from our records, anonymize the personal information, or archive the personal information in a manner consistent with industry standards for protection and retention of personal information, unless applicable law or legal considerations necessitate a longer retention period (as the case may be).

We strive to use technical and organizational measures to protect personal information against loss, misuse, and unauthorized access, use, or alteration. However, we cannot guarantee the complete security of these measures, so please exercise caution when submitting personal information online, including through our Online Platforms.

9. CHANGES TO THIS PRIVACY POLICY.

We may update or change this Privacy Policy from time to time based on modifications in law or internal review of our policies and procedures. When we perform an update, we will amend the “last updated” date above and notify you if such changes materially affect your rights or our obligations under this Privacy Policy. If you continue using our Online Platforms after the Privacy Policy has been updated, you will be considered to have accepted the new terms.

10. HOW TO CONTACT US.

If you have any questions, comments, or complaints about this Privacy Policy or our practices under applicable date protection and privacy laws, or if you have any requests in regard to your personal information, please contact us through the support functions available through the Online Platforms or by emailing us at: support@medcartar.com.