Privacy Policy

Welcome to SKIIN! This Privacy Policy ("Policy") describes how Myant Inc. ("Myant", "SKIIN", "us", "our", or "we") collects, uses, and discloses information that we obtain about you and your use of the myanthealth.com website (the "Site") and the SKIIN Mobile software ("the App"), collectively "the Service," including information that we collect from the Myant SKIIN Cardiac Monitoring devices (the "SKIIN Device") that you connect to a mobile device running the App.

By using or downloading the Service, you agree that your personal information, including any information about your health that you provide directly to us or that we collect through your use of the Service, may be transferred to, stored, and handled as described in this Policy.

Myant Inc. is committed to complying with the Applicable Privacy Laws as described in the next paragraph and maintaining the confidentiality of an individual's protected health information ("PHI") and personal information ("PI", or "PII") through appropriate, authorized access, uses, and disclosures. In this Policy, PI or PII means any personally identifying information about an individual, which directly or indirectly allows that individual to be identified, and any mention of "PI" or "Personal Information" shall include PHI.

As per: (i) the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA); (ii) Quebec's Act Respecting the Protection of Personal Information in the Private Sector as amended by Law 25 (the "ARPPIPS"); and (iii) Ontario's Personal Health Information Protection Act (HIPPA), collectively the "Applicable Privacy Laws", Myant Inc. must reasonably safeguard PHI and PI from any intentional or unintentional use or disclosure, and only collect, use and disclose that PI and PHI that is necessary for the purposes under the circumstances.

We collect the following information from you and about you, but only with your informed consent, as described further below in this Policy.

We use your information, including your personal information, for the following purposes:

• To provide our Service to you, to communicate with you about your use of our Service, to respond to your inquiries, and for other customer service purposes.
• To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Service.
• For marketing and promotional purposes, to the extent permitted by law and, where required, with your consent. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. You can opt-out of receiving marketing at any time as described below.
• To better understand how users access and use our service, both on an aggregated and individualized basis, to improve our Service and respond to user desires and preferences, and for other analytical purposes.
• To administer surveys and questionnaires.
• To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
• Where we believe necessary to investigate, prevent or act regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms and Conditions or this Privacy Policy.

We may share your information, including personal information, as follows:

• With Your Consent: With your prior consent, we may share information from the Service with other third-party partners, including your personal information and data collected from your devices.
• Your Healthcare Providers or Family: With your consent, we may share your information, including information collected from your connected devices, with your healthcare providers and/or family members that you designate to receive your information.
• Clinical Trial Studies: If you have been enrolled into a formal and registered clinical trial, and have provided consent to a clinical research team to use Myant products as part of the clinical trial to collect your health data, you also consent to Myant sharing information collected by the service with physicians and staff of the clinical trial program(s) you are enrolled in.
• Other Health-Focused Mobile Apps: With your consent we may share your profile information and data collected from your connected devices with other health-focused mobile applications installed on your mobile device to help you track your health and wellness information.
• Anonymized Information: We may share anonymized information—so that it can never be used to identify an individual—with third parties for marketing, advertising, research, or similar purposes.
• Health Researchers: With your consent Myant Inc. may share data collected through the service with healthcare researchers and other research organizations, strictly limited to anonymized profile information and anonymized data collected from your connected devices.
• Affiliates: With your consent we may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.
• Service Providers: With your consent we may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.
• Business Transfers: If we are acquired by or merged with another company, if substantially all our assets are transferred to another company, or as part of a bankruptcy proceeding or reorganization, we will give affected users notice before transferring any personal information to a new entity.
• In Response to Legal Process: We may disclose the information we collect from you to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
• To Protect Us and Others: We may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or act regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions or this Policy, or as evidence in litigation in which SKIIN is involved.
• Third Party Analytics: We use automated devices and applications, such as Google Analytics and Mixpanel, to evaluate usage of our Service.

Myant Inc. will obtain consent before any collection, use or disclosure of any personal identifiable information (PII) and personal health information (PHI) for purposes that we have identified. Individuals who sign up for a SKIIN account will provide explicit consent during account creation.

By using the Service or providing us with any PII and PHI, you consent to the transfer to, and processing, sharing and storage of your information as set forth in this Privacy Policy. Please note that other countries may have privacy and data protection regulations that are not on par with the regulations in Canada and may not provide the same level of protection.

We will always ask for your consent if we ever share or use your PII and/or PHI for a purpose other than what is in this Privacy Policy. At any point, you can withdraw your consent by contacting us at privacy@skiin.com.

Your privacy is important to Myant Inc., and we enforce privacy measures to ensure that your PII and PHI is protected against unauthorized access, use and modification.

• All data is protected through an AES256-bit encrypted database and data during any transfer between the database, server and mobile application is encrypted using HTTPS.
• Our data exists in a private virtual cloud, hosted by Amazon Web Services (AWS). AWS has ISO 27001, ISO 27017, and ISO 27018 certifications, ensuring it meets international standards for information security management systems, security controls for cloud services and security techniques for protection of personally identifiable information.
• During SKIIN account creation, a complex password (between 8 to 30 characters and a minimum of one special character or number) is required for all users.
• Only authorized individuals can access users' PII and PHI data on secure databases, which can only be accessed through secure passwords.

We also encourage you to take your own security measures, such as:

• Not sharing your password with anyone else
• Remembering to log out of the Service if accessing it on someone else's personal device
• Updating your password regularly
• Having a password on your personal device
• Locking your personal device when not in use

As per the Applicable Privacy Laws, when impermissible or unauthorized access, acquisition, use, and/or disclosure of an individual's Personal Information or Protected Health Information (PHI) handled by Myant Inc. occurs, we are required to keep records and notify any involved individuals of all breaches and to report to the Privacy Commissioner of Canada and the Commission d'accès à l'information of any security breaches that pose a real risk of significant harm to any individual or the public.

You have certain rights regarding your PI and/or health information, which are explained below. You may exercise these rights by submitting a request in writing to privacy@skiin.com.

• Right to inspect and copy: If you would like to inspect or receive a copy of your PHI that is contained in a designated record set, we are required to provide you access to such information within 30 days after receipt of your request (with up to a 30-day extension if required with notice). We may charge you a reasonable fee to cover duplication, mailing and other costs.
• Right to Request Restrictions on Use and Disclosure: You have the right to request a restriction or limitation on certain uses and disclosures of your PI or health information.
• Right to Request Amendment: If you believe that any PI or health information we have about you is incorrect or incomplete, you have the right to ask us to change the information for as long as Myant Inc. maintains the information.
• Right to Receive Confidential Communications: You have the right to request that we communicate with you about your health information in a confidential manner or at a specific location.
• Right to Receive an Accounting of Certain Disclosures: With some exceptions, you have the right to receive an accounting of certain disclosures we have made, if any, of your health information.
• Right to Obtain a Copy of this Notice: You have the right to receive a paper copy of this Notice upon request, even if you have agreed to receive the Notice electronically.
• Right to Cancel Authorization to Use or Disclose: You have the right to revoke your authorization in writing at any time, and we will discontinue future uses and disclosures of your health information for the reasons covered by your authorization.

We may send periodic promotional emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 15 business days for us to process opt-out requests. We may still send you emails about your account or any services you have requested or received from us.

Our Service is not designed for users under 18. If we discover that a user under 18 has provided us with personal information, we will delete such information from our systems.

SKIIN uses tracking technology ("cookies" and related technology such as tags, pixels and web beacons) in the Service and by interacting with the Service you agree to the use of essential cookies. Cookies are small text files placed on your computer or device when you visit a website or use an online service, in order to track use of the site or service and to improve the user experience by storing certain data on your computer or device.

You can use our cookie management tool in the cookie banner presented to you to decline categories of non-essential cookies, specifically analytics cookies.

Specifically, we use cookies and related technologies for the following functions:

• To enable your logging-in to the Service
• To facilitate the purchase of SKIIN products
• To provide general internal and user analytics on the Service
• To assist in identifying possible fraudulent activities

Your browser or device can be set to refuse cookies or delete them after they have been stored. You can refer to your browser's or device's help section for instructions.

Under the ARPPIPS, Quebec residents have certain additional data protection rights as mandated by the law, in addition to the rights found elsewhere in this Privacy Policy. These rights include the following:

• The right to have your personal information erased from Myant's records
• The right to have any hyperlink from Myant or the Service that is attached to your name removed
• The right to access your personal information and any relevant information around its use
• The right to have a copy of your personal information given to you in an easy-to-read format so that you can transfer it to another company
• The right to have your personal information corrected or updated if you believe it is inaccurate or out of date

To exercise any of these rights, please make your request to privacy@skiin.com. Please note that we may ask you to verify your identity before responding to such requests.

Transfer of Your Personal Information Outside Quebec

For our Quebec users, please note we transfer your personal information to organizations (including service providers) in other provinces or countries. When this happens, we do the following to safeguard your personal information:

1. We will perform what the ARPPIPS calls "Privacy Impact Assessment," or "PIA" prior to the personal information leaving Quebec. If the PIA does not meet our standards and the standards required by the ARPPIPS, we will not transfer your personal information.
2. If the PIA allows us to transfer the personal information to such an organization outside Quebec, we will sign what is generally called a "Data Processing Agreement," or DPA, or conclude other contractual provisions with the organization, which protects the personal information transferred to them and limits their use of it to what we have contracted with them to do.

If you believe that we have violated your privacy rights, you may file a complaint with us by notifying us at privacy@skiin.com. You may also file a complaint with (depending on your location) the Office of the Information and Privacy Commissioner of Ontario, the Office of the Privacy Commissioner of Canada, or the Commission d'accès à l'information if you feel that your rights have been violated. There will be no retaliation from Myant Inc. for making a complaint.

SKIIN
Attn. Privacy
2660 Speakman Drive
Mississauga, ON Canada L5K 2L1