PRIVACY POLICY

Effective Date: 1st day of October, 2020
PLEASE READ THE FOLLOWING CAREFULLY

DEBDIGITALS FZ-LLC PRIVACY POLICY

PRIVACY POLICY

We do not collect information from visitors of our site.

When do we collect information?

We collect information from you when you or enter information on our site.

How do we use your information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

How do we protect visitor information?

We do not use vulnerability scanning and/or scanning to PCI standards.

We use regular Malware Scanning.

We do not use an SSL certificate.

– We only provide articles and information, we never ask for personal or private information like email addresses, or credit card numbers. Do we use ‘cookies’?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

• Understand and save user’s preferences for future visits.

• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.

If you disable cookies off, some features will be disabled It won’t affect the users experience that make your site experience more efficient and some of our services will not function properly. However, you can still place orders.

Third Party Disclosure We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses. Third party links Occasionally, at our discretion, we may include or offer third party products or services on our website.

These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

Google Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users.

https://support.google.com/adwordspolicy/answer/1316548?hl=en

We use Google AdSense Advertising on our website. Google, as a third party vendor, uses cookies to serve ads on our site.

Google’s use of the DART cookie enables it to serve ads to our users based on their visit to our site and other sites on the Internet.

Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.

We have implemented the following:

• Remarketing with Google AdSense

• Demographics and Interests Reporting

• DoubleClick Platform Integration We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions, and other ad service functions as they relate to our website.

Opting out:

Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.

California Online Privacy Protection Act CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy.

The law’s reach stretches well beyond California to require a person or company in the United States (and conceivably the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.

– See more at: http://consumercal.org/california-online- privacy-protection- act- caloppa/#sthash.0FdRbT51.dpuf According to CalOPPA we agree to the following:

Users can visit our site anonymously Once this privacy policy is created, we will add a link to it on our home page, or as a minimum on the first significant page after entering our website.

Our Privacy Policy link includes the word ‘Privacy’, and can be easily be found on the page specified above. Users will be notified of any privacy policy changes:

• On our Privacy Policy Page Users are able to change their personal information:

• By emailing us How does our site handle do not track signals?

We honor do not track signals and do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

Does our site allow third party behavioral tracking?

It’s also important to note that we allow third party behavioral tracking.

COPPA (Children Online Privacy Protection Act) When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control.

The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under 13.

Fair Information Practices The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe.

Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information. In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur: We will notify the users via in site notification

• Within 7 business days We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law.

This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

CAN SPAM Act The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. We collect your email address in order to:

• Send information, respond to inquiries, and/or other requests or questions.

• Process orders and to send information and updates pertaining to orders

• We may also send you additional information related to your product and/or service. To be in accordance with CANSPAM we agree to the following:

• NOT use false, or misleading subjects or email addresses

• Identify the message as an advertisement in some reasonable way

• Include the physical address of our business or site headquarters • Monitor third party email marketing services for compliance, if one is used.

• Honor opt-out/unsubscribe requests quickly

• Allow users to unsubscribe by using the link at the bottom of each email.

DEBDIGITALS FZ-LLC

FDRK0827 

Compass Building, 

Al Shohada Road, AL Hamra Industrial Zone-FZ, 

Ras Al Khaimah, United Arab Emirates

EMAIL: info@debdigitals.com

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

Table of Contents

What information do we collect?
How do we use your information?
Will your information be shared with anyone?
Who will your information be shared with?
Do we use cookies and other tracking technologies? How long do we keep your information?
How do we keep your information safe?
Do we collect information from minors?
What are your privacy rights?
Controls for Do-not-track features
Do California residents have specific privacy rights? Do we make updates to this policy?
How can you contact us about this policy?

1. WHAT INFORMATION DO WE COLLECT?

(a) Personal information you disclose to us We collect personal information that you provide to us such as name, address, and contact information.

We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services, when participating in activities on our website or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and our website, the choices you make and the products and features you use. The personal information we collect can include the following:

For the mobile app: Legal name, phone number, email, location, address, saved medical history and medical records.

For the Web app: clinic legal name, phone number, email, location, address, EIN document, Articles of Organization, saved medical history and medical records.

Sensitive Personal Information; Sensitive Personal Information” refers to Personal Information regarding more sensitive areas, such as Your government ID and certain other medical or health information, financial information, gender, marriage status, race/ethnicity, or veteran or disability status.

This information is used only for the purpose for which it is submitted unless we disclose other uses in this Privacy Policy or at the time of collection.

(b) Information automatically collected Some information – such as IP address and/or browser and device characteristics – is collected automatically

when you visit our website.

We automatically collect certain information when you visit, use or navigate our website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our website and other technical information. This information is primarily needed to maintain the security and operation our website, and for our internal analytics and reporting purposes.

2. HOW DO WE USE YOUR INFORMATION? We process your information for purposes based on legitimate business interests, the fulfillment of our

contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To send you informational communications. We may use the personal information you send to us for the purposes of sending you informational emails or newsletters. You can opt-out of our informational communications at any time.

Request feedback. We may use your information to request feedback and to contact you about your use of our website.

For other business purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our website, articles, and your experience.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information

in a specific purpose.

Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on our website, which will enable them to collect data about how you interact with our website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

4. WHO WILL YOUR INFORMATION BE SHARED WITH?

We only share information with the following third parties.

We only share and disclose your information with the following third parties. We have described each party so that you may easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent, please contact us.

Google Analytics and other Google services

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the data collected to track and examine the use of our website, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network.

Mailchimp

Mailchimp is a marketing automation platform and an email marketing service. Mailchimp may use the data they collect for internal data analytics projects or to meet legal requirements.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We and our partners use cookies to collect information about your use of the website. “Cookies” are small data files assigned to your browser when you visit Ayademica which enable recognition of your browser and collect and store information about your use of the site, as described above. In addition to cookies, we and our partners use other tracking technologies that collect information about your use of the Services, including mobile identifiers and “web beacons” which are small graphic files (sometimes called “clear GIFs” or “web pixels”) embedded in a web page or email typically used to monitor activity and send relevant information back to a home server (which can belong to the host site, a network advertiser or some other third party).

Our service partners may use cookies and other tracking technologies to collect information about your use of the site, including content you have viewed. These third parties may use this information to deliver advertising on other third party websites based on your browsing activity on Ayademica.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our website.

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 the Privacy Policy.

6. HOW LONG DO WE KEEP YOUR INFORMATION? We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE? We aim to protect your personal information through a system of organizational and TECHNICAL SECURITY MEASURES.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our website is at your own risk. You should only access the services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the website. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age18, please contact us at contact us at customerservice@ayademica.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?6

In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or request deletion of your data at any time. In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include;

Right to access. You may obtain from us the confirmation as to whether or not personal data concerning you is being processed and get an access to such personal data. You are entitled to view, amend, or delete the personal information that we hold. Email your request to our data protection office atcustomerservice@ayademica.com and we will work with you to remove any of your personal data we may have.

Right to rectify your inaccurate Personal Information and to have incomplete personal data completed, including by means of providing a supplementary statement

Right to erase your Personal Information. Please note that a request to erase your Personal Information will also terminate your account on the Site. We will automatically and without undue delay erase your Personal Information when it is no longer necessary in relation to the purposes for which it was collected or otherwise processed;

Right to restrict processing of your Personal Information; Right to data portability. You may obtain from us the personal data concerning you and which you have

provided to us and transmit it to another Personal Information Controller; Right to object to processing of Your Personal Information, Right to withdraw your consent to the usage of your Personal Information at any time

Right to lodge a complaint. We take privacy concerns seriously. If you believe that we have not complied with this Privacy Policy with respect to your Personal Information, you may contact our respective Data Protection Office. We will investigate your complaint promptly and will reply you within 30 (thirty) calendar days.

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? Yes, if you area resident of California, you are granted specific rights regarding access to your personal information.

California Consumer Privacy Act (CCPA) grants California residents the following rights with regard to their personal data (taken from CCPA Fact Sheet):

The right to know what personal information is collected, used, shared or sold, both as to the categories and specific pieces of personal information.

The right to delete personal information held by businesses and by extension, a business’s service provider.

The right to opt-out of sale of personal information. Consumers are able to direct a business that sells personal information to stop selling that information.

Children under the age of 16 must provide opt-in consent, with a parent or guardian consenting for children under 13.

The right to non-discrimination in terms of price or service when a consumer exercises a privacy right under CCPA.

If you are a resident of California, and have submitted data with the Sites or have used the Sites, you have the right to request removal of unwanted data that you publicly post on the Sites. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites, but please be aware that the data may not be completely or comprehensively removed from our systems.

11. DO WE MAKE UPDATES TO THIS POLICY?

Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS POLICY? If you have questions or comments about this policy, you may email us at customerservice@ayademica.com.