Privacy Policy

1. Introduction

This Privacy Policy (this "Privacy Policy") describes the Personal Information and other information that POM Health Systems Inc. and the professional entities to which it provides management services (collectively, "POM Health," "we," "us," or "our") may collect, and how POM Health collects, uses and discloses such information when you access or use our website made available at pomhealth.xyz (the "Website"), a website operated by POM Health, as well as your choices related to your Personal Information.

By accessing or using the Website, you acknowledge and consent to the practices described in this Privacy Policy regarding our collection, use and disclosure of your Personal Information. If you do not acknowledge and consent to the terms of this Privacy Policy, you may not use the Website.

Please note that some privacy rights and obligations may differ in certain locations based on local law, in which case POM Health will comply with local legal requirements.

2. Scope of Privacy Policy

POM Health is a technology platform and not a medical group, health care provider, laboratory, pharmacy, or insurer. Medical, laboratory, and pharmacy services accessible via the Services are provided by independent third parties (collectively, "Providers").

3. The Personal Information We Collect

When you access or use the Website, POM Health may collect Personal Information in the following ways:

Information You Provide:

We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive features of the Website, fill out a medical information questionnaire or other form, make a purchase, request customer support, use our Website or otherwise communicate with us. The types of information we may collect include:

• Account information, such as your name, email address, password, postal address, phone number, date of birth and any other information you choose to provide.
• Health information, such as your past and present medical condition, medication information, and treatment history.
• Transaction information, such as limited payment information from you, including payment method and payment card information; however, we do not collect or store full payment card numbers and all transactions are processed by our third party payment processor.
• Communications & support data, including chats, emails, SMS, call recordings (where permitted), and feedback.
• Any other information that you choose to provide, such as when you participate in a questionnaire, assessment or other interactive area of the Website or when you request technical or customer support.

Information About Your Use of the Website

Usage Information: We may collect information about your use of the Website, including the way you respond to us when we send you emails or communications or your preferences when you interact with our Website. We may use this data to analyze trends and statistics to improve your online experience or our customer service.

Information We Collect Automatically: When you access or use our Website, we automatically collect information about you, including:

• Log Information: We log information about your use of the Website, including the type of browser you use, access times, pages viewed, your IP address, your general location and the page you visited before navigating to our Website.
• Device Information: We collect information about the computer or mobile device you use to access our Website, including the hardware model, operating system and version, unique device identifiers and mobile network information.

We may de‑identify and/or aggregate personal information and use it for any lawful purpose, and we will not attempt to re‑identify de‑identified data except as required by law.

4. Use of Information by POM Health

POM Health may use Personal Information about you for various purposes, including to:

• Provide, maintain and improve our Website and provide you with relevant information;
• Process transactions and send you transaction-related information;
• Send you technical notices, updates, security alerts and support and administrative messages;
• Respond to your comments, questions and requests and provide customer service;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity;
• Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of POM Health and others;
• Comply with our legal and financial obligations; and
• Carry out any other purpose described to you at the time the information was collected.

Communication Preferences

By creating an account or otherwise providing your email address, you consent to receive electronic communications from POM Health (e.g., via email or by posting notices on our Website). These communications may include notices about your account (e.g., transaction receipts, password changes and other transactional information) or other communications that we believe may be of interest to you, each of which are part of your relationship with us. You agree that any notices, agreements, disclosures or other communications that we send to you electronically will satisfy any legal communication requirements, including, but not limited to, that such communications be in writing.

You may manage your communication preferences by clicking the unsubscribe feature included in the email you receive. Please note that if you opt-out of receiving marketing-related emails from POM Health, you may still receive important administrative messages, from which you cannot opt-out.

5. Data Collection Technologies

We and our service providers may use various tracking technologies, including cookies and web beacons, to collect information about you when you interact with our Website. Cookies are small data files stored on your hard drive or in device memory that help us improve the Website and your experience, see which areas and features of the Website are popular, and count visits. Web beacons are electronic images that may be used on the Website or emails and help deliver cookies, count visits and understand usage and campaign effectiveness.

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Website.

Advertising and Analytics Services Provided by Others

We may allow others to serve advertisements on our behalf across the Internet and to provide analytics services. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Website and other websites, including your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by POM Health and others to, among other things, analyze and track data, determine the popularity of certain content and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visitwww.aboutads.info/choices.

Notice Concerning Do Not Track

Do Not Track is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Website for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above. Some web browsers offer users a "Do Not Track" privacy preference setting in the web browser. We do not currently recognize or respond to browser-initiated Do Not Track signals. Please note that "Do Not Track" is a distinct privacy mechanism from the browser-based opt out signals referenced above, which POM Health does honor in accordance with applicable law.

6. Disclosing Your Information

We may share information about you, including Personal Information, as follows, or as otherwise described in this Privacy Policy:

• With Providers and labs, in order to facilitate services you request (e.g., test ordering, sample collection, results delivery). Providers/labs set their own policies and may have their own notices;
• With vendors, consultants and other service providers who need access to such information to carry out work or perform services on our behalf;
• In response to requests from local, state, provincial or federal law enforcement officials, any judicial, administrative or similar proceeding or order, such as a subpoena if we believe disclosure is in accordance with, or required by any applicable law;
• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of POM Health and others;
• To investigate suspected fraud, harassment, physical threats, or other violations of any law, rule or regulation, the Website's rules or policies, or the rights of third parties or to investigate any suspected conduct which we deem improper;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• Between and among POM Health and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
• With your consent or at your direction;
• To comply with transparency or other public reporting obligations; and
• As otherwise permitted or required by law.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

We are based in the United States and the information we collect is governed by U.S. law. By accessing or using the Website or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries, where you may not have the same rights as you do under local law. Where this is the case, we will take appropriate measures to protect information about you in accordance with this Privacy Policy.

7. Security of Personal Information

POM Health has reasonable and appropriate safeguards in place to help protect the Personal Information POM Health collects from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Although POM Health attempts to protect the Personal Information in our possession, no security system is perfect, and POM Health cannot promise that your Personal Information will remain absolutely secure in all circumstances.

8. Retention of Personal Information

POM Health will retain your Personal Information as needed to fulfill the purposes for which it was collected. POM Health will retain and use your Personal Information as necessary to comply with POM Health's business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements.

9. Links to Third Party Websites

Our Website may contain certain links to third party websites. POM Health is not responsible or liable for the privacy practices or content found on these websites. You should check the privacy notice and policies of each website you visit. Links to third party websites are provided solely for your convenience and any use or submission of data to such websites shall be at your sole risk.

10. Transfer of Information to the United States and Other Countries

We are based in the United States and the information we collect is governed by U.S. law. By accessing or using the Website or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S.

11. Changes to the Privacy Policy

POM Health may change this Privacy Policy at any time. Unless we say otherwise, changes will be effective upon the last updated date at the top of this Privacy Policy. Please check this Privacy Policy regularly to ensure that you are aware of any changes. We may try to notify you of material changes to this Privacy Policy, which if we do so may be by means such as by posting a notice directly on the Website, by sending an e-mail notification (if you have provided your e-mail address to us), or by other reasonable methods. In any event, if you use the Website after changes to this Privacy Policy, you have accepted the changes. If you do not agree with the changes, please stop using the Website.

12. Contact Us

If you have any questions or concerns related to this Privacy Policy, please contact us at:

Lucas.bj1@gmail.com