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California Residents' Privacy Rights

Effective August 8, 2025

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the "CCPA") provides California residents with additional rights regarding Our use of their Personal Data.

This Privacy Policy for California residents supplements the information contained in the Company's Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with the CCPA and any terms defined in the CCPA have the same meaning when used in this Policy.

The Personal Data that We collect from You depends on how You interact with Us, the Services, and our Website. The following table lists the categories of Personal Data and the specific pieces of Personal Data We have collected within the last twelve (12) months.

We do not sell the Personal Data We collect, but we share certain Personal Data with third parties for targeted advertising, which is deemed a sale/sharing under the CCPA for which you may Opt-Out. We will not sell the Sensitive Personal Data We collect. We also will not share it with third parties for targeted advertising.

Personal Data Collection Categories

CategoryInformation in CategorySpecific Information CollectedBusiness Use PurposeSold or Shared
A. IdentifiersReal name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, SSN, driver's license number, passport number, or other similar identifiersReal name, email address, IP address, account identifiersTo provide Our Services and Website; process applications; maintain records; advertising; analyticsYES, shared with service providers; advertising networks; analytics partners
B. Personal information categories (Cal. Civ. Code § 1798.80(e))Name, signature, SSN, physical characteristics, address, telephone number, passport number, driver's license, insurance policy number, education, employment history, financial informationName, address, telephone number, education, employment historyTo provide Our Services; process applications; maintain personnel records; advertisingYES, shared with service providers; advertising networks; analytics partners
C. Protected classification characteristicsAge, race, color, ancestry, national origin, citizenship, religion, marital status, medical condition, disability, sex, sexual orientation, veteran status, genetic informationAge, race, gender, marital status, citizenship or disability may be on employment documentationTo provide Our Services; process employment applications; maintain personnel recordsProviders may view Patient Personal Data shared via File Transfer or photo capture
D. Commercial informationRecords of Services purchased, or considered, or other purchasing or consuming historiesRecords of Services purchasedTo provide Our Services and Website; advertising; analyticsYES, shared with service providers; advertising networks; analytics partners
E. Internet or network activityBrowsing history, search history on Website, interaction with WebsiteBrowsing history and search history on the WebsiteTo facilitate efficient use of Our systems; advertising; analyticsYES, shared with service providers; advertising networks; analytics partners
F. Professional/employment informationCurrent or past job history or performance evaluationsCurrent or past job history or performance evaluationsTo process employment applications; verify employment; maintain recordsYES, shared with service providers
G. Inferences from Personal DataProfile reflecting preferences, characteristics, behavior, attitudes, abilitiesAnalytics dataAdvertising and analyticsYES, shared with service providers; advertising networks; analytics partners
Sensitive Personal Data
H. Racial or ethnic originRace, color, ethnicity, ancestry, religion, citizenship, national originMay be disclosed in File Transfer or PhotoCapture at Patient discretionTo provide the ServicesNot shared or sold. Providers may view Patient data shared via File Transfer
I. Genetic dataData from analysis of biological sample concerning genetic materialMay be disclosed in File Transfer or PhotoCapture at Patient discretionTo provide the ServicesNot shared or sold. Providers may view Patient data shared via File Transfer
J. Health/sexual orientation informationHealth conditions, medical history, sexual health, sexual orientation, gender identityMay be disclosed in File Transfer or PhotoCapture at Patient discretionTo provide the ServicesNot shared or sold. Providers may view Patient data shared via File Transfer

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Data. This section describes Your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that We disclose certain information to You about Our collection and use of Your Personal Data over the past twelve (12) months (the "right to know"). Once We receive Your request and confirm Your identity, We will disclose to You:

  • The categories of Personal Data We collected about You.
  • The categories of sources for the Personal Data We collected about You.
  • Our business or commercial purpose for collecting that Personal Data.
  • The categories of third parties with whom We share that Personal Data.
  • The specific pieces of Personal Data We collected about You (also called a data portability request).

Right to Correct

You can review and change Your Personal Data by sending Us an email at support@feelpath.com to request access to or correct any Personal Data that You have provided to us. Once We receive Your request and confirm Your identity, We may not accommodate a request to change information if We believe the change would violate any law or legal requirement or cause the information to be incorrect.

Right to Delete

You have the right to request that We delete any of Your Personal Data that We collected from You and retained, subject to certain exceptions (the "right to delete"). Once We receive Your request and confirm Your identity, We will review Your request to see if an exception allowing Us to retain the information applies. We may deny Your deletion request if retaining the information is necessary for Us or Our service provider(s) to:

  1. 1. Complete the transaction for which We collected the Personal Data, provide a good or service that You requested, take actions reasonably anticipated within the context of Our ongoing business relationship with You, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform Our contract with You.
  2. 2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. 3. Debug products to identify and repair errors that impair existing intended functionality.
  4. 4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. 5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. 6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
  7. 7. Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with us.
  8. 8. Comply with a legal obligation.
  9. 9. Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

We will delete or de-identify Personal Data not subject to one of these exceptions from Our records and will direct Our service providers to take similar action.

Exercising Your Rights to Know, Delete, or Correct

To exercise Your rights as described above, please submit a request by either email or visiting the website as listed in the Contact Us section below.

Only You, or someone legally authorized to act on Your behalf, may make a request to know, delete, or correct Your Personal Data.

You may only submit a request to know twice within a 12-month period. Your request to know, delete, or correct must:

  • Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected Personal Data or an authorized representative, which may include:

    • ◦ Matching at least two (2) data points You provide to Us with other reliable data points We already maintain about You.
    • ◦ Verifying a parent or guardian's identity by checking a form of government-issued identification against databases of such information or by calling Us at the number listed below in the Contact Us section.
  • Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.

We cannot respond to Your request or provide You with Personal Data if We cannot verify Your identity or authority to make the request and confirm the Personal Data relates to You.

We will only use Personal Data provided in the request to verify the requestor's identity or authority to make it.

Response Timing and Format

We will confirm receipt of Your request within ten (10) business days. If You do not receive confirmation within the 10-day timeframe, please contact us (see Contact Us below).

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If We require more time (up to another forty-five (45) days), We will inform You of the reason and extension period in writing.

If You have an account with us, We will deliver Our written response to that account. If You do not have an account with us, We will deliver Our written response by mail or electronically, at Your option.

Any disclosures We provide will only cover the 12-month period preceding Our receipt of Your request. The response We provide will also explain the reasons We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide Your Personal Data that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to Your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If We determine that the request warrants a fee, We will tell You why We made that decision and provide You with a cost estimate before completing Your request.

Sale of Personal Data and Sensitive Personal Data Opt-Out and Opt-In Rights

Notice of Right to Opt Out of Sale/Sharing

To exercise the right to opt-out, You (or your authorized representative) may submit a request to Us by contacting us. Please see "Contact Us" below.

Once You make an opt-out request, We will wait at least twelve (12) months before asking You to reauthorize Personal Data sales. However, You may change your mind and opt back in to Personal Data sales at any time by emailing Us at the email address below.

You do not need to create an account with Us to exercise Your opt-out rights. We will only use Personal Data provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against You for exercising any of Your CCPA rights. Unless permitted by the CCPA, We will not:

  • Deny You goods or services.
  • Charge You different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide You a different level or quality of goods or services.
  • Suggest that You may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, We may offer You certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive We offer will reasonably relate to Your Personal Data's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires Your prior opt-in consent, which You may revoke at any time.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of Our Website that are California residents to request certain information regarding Our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please contact us.

Contact Us

Certain inquiries are required to be in written format. If You have any questions about this policy, You may contact us at:

  • Email: support@feelpath.com
  • Visit our contact page on the website
  • By mail: Feelpath Inc., Privacy Department, California Privacy Rights