Last Updated: April 27, 2021

This Privacy Policy (“Policy”) describes the manner in which 4YouandMe (“4YouandMe”, “we,” or “us”) and our mobile application (the “App”) use and collect data from individuals. This Policy, which is incorporated into and is subject to the 4YouandMe Terms of Service, describes the information that we gather from you on the App, how we use and disclose such information, and the steps we take to protect such information. The App is only intended for use in connection with your participation in a 4YouandMe research study)” (the “Study”). Additional information about how we use and collect data is described in the Participant Information and Consent Form (the “ICF”) provided to you in connection with the Study, which is hereby incorporated by reference and made a part of this Policy. If you have not signed an ICF, then you may not use the App.

Below is a description of information, including personal information and health information, we may collect from you. To the extent required by law, we will obtain your consent (and any data related to your consent) before collecting this information. The information we collect differs from study to study, so please refer to your study-specific ICF for details on the exact information we will collect from you in the study you are participating in.

Information We May Collect on the App:

∙ User-provided Information. When you use the App, we may collect information about you, including your name, email address, user credentials, preferences, survey responses, measurements you provide, video diaries you create, and other electronic data. You may provide us with information in various ways on the App. For example, you provide us with information when you register for an account or use the App to complete questionnaires relating to the Study. The information you provide may include personal information and details regarding your health.

∙ Passively Collected Information. The App passively collects information, such as MAC address, SSID, battery level, and your interactions with the App, including when the App is opened, and time spent on each screen of the App.

∙ Location Information. If you consent, the App may collect your phone’s precise geolocation (i.e., your GPS coordinates) and use that information to calculate the direction you have moved and the distance you have traveled relative to your original location (“Relative Location Information”). Your precise geolocation is not retained by 4YouandMe or used for research purposes. Your Relative Location Information may be used to understand how far you traveled and the speed at which you traveled.

∙ Information from Other Sources. We may obtain information from third parties and sources other than the App, including (but not limited to) information that you provide to your study coordinator, and data that third-party services and devices collect in connection with the Study.

∙ Communications. If you contact us directly, we may receive additional information about you. For example, when you contact us, we may receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide.

How We Use the Information We Collect. We use information we collect on the App in a variety of ways in providing the App and conducting the Study, including the following:

∙ We use information that we collect on the App in accordance with the ICF.

∙ We use the information that we collect on the App to operate, maintain, enhance and provide all features of the App.

∙ We may use your email address or other information we collect to contact you for administrative purposes such as to send communications, or to help you recover your account.

∙ We use the information that we collect to communicate with you, provide you with updates and other information relating to the App and the Study, provide information that you request, respond to comments and questions, and otherwise provide support.

- We may use the information we collect to find and prevent fraud and respond to trust and safety issues that may arise.

∙ We may use the information that we collect for compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

∙ We may use the information that we collect for other purposes for which we provide specific notice at the time the information is collected.

When We Disclose Information. Except as described in this Policy, including the ICF, we will not disclose information about you that we collect on the App to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

∙ The Study may be conducted in collaboration with multiple third parties, as discussed in the ICF. Information about you may be shared with such Study collaborators, or as otherwise described in the ICF.

∙ We work with third party service providers to provide website, application development, hosting, maintenance, and other services for us. These third parties may have access to or process information about you as part of providing those services for us. Generally, we limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.

∙ We may disclose information about you if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

∙ If we are authorized to do so under the law, we also reserve the right to disclose information about you that we believe, in good faith, is appropriate or necessary to: (i) take precautions against liability; (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity; (iii) investigate and defend ourselves against any third-party claims or allegations; (iv) protect the security or integrity of the App and any facilities or equipment used to make the App available; or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

∙ Information about our users may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

Your Choices

You may, of course, decline to share certain information with us, in which case we may not be able to provide to you some of the features and functionality of the App. You may request to update, correct, or delete your account information and preferences at any time by contacting your study coordinator. If you wish to access or amend any other personal information we hold about you, you may contact your study coordinator. While you may change your account information and preferences or decline to share information in the future, these changes will not apply to data you have already shared, and such data may be retained without changes.

Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we will retain your personal information as long as required to fulfill the purpose of the collection, as long as required to comply with applicable laws, or in conformity with the ICF, whichever is longer..

Location Information. You can prevent your device from sharing your precise location information at any time through your device’s operating system settings.

Third-Party Apps

The App may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the App. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the App. We encourage you to learn about third parties’ privacy and security policies before providing them with information.

Data Security

We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of information that we collect and maintain. Please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

Retention and Hosting

We retain your personal information as long as required for us to contribute to the studies, and in accordance with the information in the ICF, unless we are required by applicable laws to retain your personal information longer. When using our services, your personal information may be transferred in other territories than where you are located. For example, your data may be processed and stored in the United States, where the app is hosted. This means that different laws may apply to your personal information in these territories. Prior to transferring your personal information, we make efforts to enter into contractual terms that are adequate to protect your personal information in this country, and to enforce this privacy policy.

Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through the App, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the App for the first time after such material changes are made. Your continued use of the App after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of this Policy.

How to Contact Us

If you have any questions or concerns about how we manage your personal information and protect your privacy, contact your Study coordinator, who can provide detailed information about the specific Study you are participating in.. You can always contact us to exercise your rights, such as the right to access your personal data or otherwise. You can contact our Privacy Officer at:

● Email: info@4youandme.org

If you are located in Canada, you have the right to complain to the Office of the Privacy Commissioner of Canada if you are concerned that we violated privacy obligations regarding personal health information or personal information. If you are located in Ontario, the Information and Privacy Commissioner of Ontario may also receive complaints on personal health information.