enableCV Privacy Policy

Last Updated February 6, 2026

Download this Privacy Statement as a PDF

Who We Are

enableCV, LLC (“enableCV” “our,” or “we”) recognize the importance of online privacy and are committed to respecting your privacy. This Privacy Statement describes our policies and practices on the collection, use, disclosure, and storage of Personal Information and the steps we take to protect it from unauthorized use or disclosure.

Purpose and Reach of This Privacy Statement

This Privacy Statement applies to all enableCV websites, online or digital services activities, and mobile applications, including, but not limited to www.enableCV.com, in which this Privacy Statement is posted or linked (collectively our “Sites”) and, where applicable, will apply to Personal Information that we obtain and process other than through the Sites (for example, Personal Information about our customers, vendors, or service providers in the course of doing business).

enableCV is headquartered in Midvale, Utah, in the United States. Our IT and other functions are administered centrally by enableCV in the United States, and any information that you provide or we collect may be transmitted to a country other than your country of residence for processing or storage, and it may also be communicated to third parties hired by us to provide services such as website hosting, database management, or analytics. By using this Site, you consent to the collection, use, storage, and processing of your Personal Information in the United States and in any country to which we may transfer your Personal Information in the course of our business operations. For more information, please see Transfer of Personal Information to Other Countries.

If your Personal Information is processed in the European Economic Area (“EEA”), please see our Supplemental European Privacy Statement, which we have developed pursuant to European data protection laws.

If you are a consumer residing in a U.S. state with a comprehensive privacy law, please see our Supplemental U.S. Privacy Statement, which we have developed pursuant to relevant U.S. state laws, such as the California Consumer Privacy Act (“CCPA”). The Supplemental U.S. Privacy Statement includes general information regarding our collection, use, and disclosure of Personal Information of consumers in those states, as well as information regarding data subject rights requests. If you are a consumer residing in a U.S. state with a comprehensive consumer health data privacy law, such as the state of Washington, please review our Consumer Health Data Privacy Policy for our privacy practices related to consumer health data.

If you are a resident of California interacting with us as an applicant for a job posting or in a professional capacity—for example, if you are a healthcare provider or an employee of a company with which we do business, or when we undertake employment recruiting activities of California residents—please see the Supplemental U.S. Privacy Statement for information regarding the processing of your Personal Information.

If you are a resident of California interacting with us as an employee or former employee, or a dependent or beneficiary of an employee or former employee, this Privacy Statement does not apply to you.

Please note that our Sites might offer links to other websites that are owned or controlled by third parties. This Privacy Statement applies only to enableCV’s Sites. We do not control or endorse the content of any third-party sites and cannot accept responsibility for the privacy practices of any websites not controlled by us. We encourage you to review the privacy policies of any third-party sites prior to providing them with any of your Personal Information.

Please review this Statement carefully. To the extent permitted by applicable law, by providing us your Personal Information or otherwise interacting with us, you are agreeing to this Statement.

Continue scrolling to read this Privacy Statement in its entirety.

Information We Collect on Our Sites

This section describes information that individuals might choose to provide to us voluntarily, as well as our practices for the automatic collection and use of visitors’ device-related information and analytics information, such as visitors’ IP addresses and information related to the use and navigation of our Sites.

Information You Provide

We define Personal Information as information that can (directly or indirectly) identify, locate, or be used to contact you or communicate with you, such as your name, address, telephone number, e-mail address, characteristics, or descriptions (such as gender and date of birth), and other similar and associated information (“Personal Information”). Personal Information includes certain subsets of Personal Information that are considered “sensitive” pursuant to applicable laws, such as information about health or medical status, and healthcare products used or services received (“Sensitive Personal Information”).

In most cases, we collect Personal Information directly from you. We will ask you for Personal Information, for example, when you interact with us, such as registering on our Sites, using any interactive features or applications, signing up to receive a newsletter, or, a user of one of enableCV’s products may choose to share his or her experiences with us; a person seeking employment may choose to apply for a job online or request additional information about job opportunities; a health care professional might ask that we send information about one or more of our products. Before providing Sensitive Personal Information to us, we urge you to carefully consider whether to disclose it. If you do provide Sensitive Personal Information to us, you are consenting to its use and disclosure for the purposes and in the manner described at the time of collection and as set forth in this Privacy Statement.

Through your use of the Sites, you may choose to provide us with Personal Information that identifies you or your family members. This Personal Information may include a person’s name, postal or email address, phone number, Social Security or national identifying number, information about your health or medical condition, or any other information that would allow enableCV to identify or contact you. For example, a person seeking employment may choose to apply for a job online or request additional information about job opportunities. A health care professional might ask that we send information about one or more of our products, or they might report information about a specific patient. A charitable organization might request a donation.

In addition, some aspects of our Sites may be restricted to use only by licensed health care professionals, and access to those portions of the Sites may require Personal Information to facilitate registration and verification.

In these instances, in order to fulfill your request to use the features of our Sites, we may ask for Personal Information such as your name, postal or email address, phone number, and perhaps a medical license number or other information to verify eligibility to view certain restricted content or to allow you to register for an event. In limited circumstances, such as an adverse event with one of our products, we may also be required to obtain Personal Information about your medical condition to enable required reporting to government regulatory agencies. Health care professionals should ensure that they have obtained their patient’s consent (where required) before submitting personal or medical information about their patients.

Information We Collect Automatically

Additionally, through your use of the Sites, we collect information related to your use by automated means, such as the date and time of your website sessions, movements across our Sites, and the browser information and operating system you use and other system settings, as well as the language your system uses and the country, region, and time zone where your device is located (collectively, “Usage Data”).

Usage Data also includes the IP Address of the device you use to connect to the Internet that is collected by our Site server logs. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. In certain circumstances, where we link Usage Data and Personal Information, Usage Data may be considered Personal Information. Usage Data may also allow us to identify the country you are visiting from, so that we may direct you automatically to the content that is appropriate for your country.

Digital Advertising, Cookies and Other Data Collection Technologies

When you use our Sites, we collect different types of Usage Data by automated means, using technologies such as APIs, web services, scripts, cookies, pixels, tags, web beacons, browser analysis tools, and server logs. Using these technologies, we may also collect data about the website you were visiting before you came to our Site, and the website you visit after you leave our Site. We may also use vendors, such as Adobe and Google, to place cookies and collect data to enable certain services we use, including advertising, visitor tracking, personalization, site analytics and security services, including reCAPTCHA, and the data may be disclosed to our vendors for these purposes.

Other data may be disclosed to vendors providing additional services integrated into our Sites, including performance monitoring, user experience components such as user interface frameworks, images and web fonts, maps, and ecommerce functionality. When we send email communications, we may place a web beacon or similar tracking technology in the email to know whether your device is capable of receiving HTML emails, or to collect data on whether the email or an attachment or link in the email has been opened or forwarded.

When you use our Sites, we may place cookies on your computer. Cookies are small text files that websites or mobile apps send to your computer or other Internet-connected device to uniquely identify your browser or to store data or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. Some of our Sites may use Web Storage instead of cookies.

We may use or request to use cookies from third-party advertising companies that may place an advertising tag on your web browser. The advertising tag allows third parties to serve our ads to you on other websites and digital services. These companies may use information obtained from cookies and other data collection tools in order to measure advertising effectiveness and to provide advertisements of interest to you on these other websites.

You can also opt-out of receiving targeted advertising from Network Advertisers by clicking the “Ad Options” icon on the advertisements or by going to www.networkadvertising.org. In addition, the Digital Advertising Alliance maintains a web site where consumers can opt out from receiving interest-based advertising from some or all of the network advertising companies participating in the program (www.AboutAds.info/choices).

In many cases, the data we collect using cookies and other tools is only used in a non-identifiable way, without any reference to Personal Information. However, under some privacy and data protection laws, this data could be considered Personal Information. This Privacy Statement governs how we use this data when it is considered your Personal Information.

Information Provided to Us Outside the Sites

We recognize that we might receive Personal Information in ways other than through our Sites. We collect information about our customers and potential customers for the purposes of providing our products and services – such as contact information, financial/billing information, and any other information that is provided to us during the course of doing business. For example, physicians may notify us of complaints or adverse events with our products and may inadvertently include information about the patient’s health. Job applicants may submit paper applications. We also maintain records of purchases by our physician customers and their attendance at educational and other events we host.

We also collect information from our vendors, suppliers, consultants, professional advisors, and other third parties for the purposes of managing and operating our business. For example, we will collect business contact information, financial information, and other information necessary to engage our suppliers and other business partners and to evaluate their performance.

Personal Information is given the same protection by us, whether we receive it through a website or by other means. The descriptions below apply to Personal Information collected or received by us, no matter how the information was received.

How We Use the Information We Collect

If you choose to provide Personal Information to us, enableCV may use your Personal Information for a range of business, operational, and legal purposes, including:

• To respond to your specific inquiry or request, and to provide you with information and access to resources that you have requested from us;
• To provide, operate, and maintain the Sites;
• To improve the navigation and content of our Sites, system administration, and security;
• To provide you with general health information (such as information on certain health conditions) as well as information about our products and services;
• To provide you with marketing communications and offers for products and services and to deliver advertising (including targeted advertising) to you on this and other websites;
• To process and complete transactions;
• To manage our customer relationships, including to respond to inquiries and comments and providing customer service and support;
• To provide our products and services;
• To create anonymized or de-identified data so that it is no longer Personal Information;
• To carry out research and development to improve our products and services;
• To assess financial, credit or insurance risks arising from any relationship or prospective relationship with a customer, supplier, distributor, or business partner; or
• To carry out other legitimate business purposes, and other purposes about which we will notify our users and customers.

Furthermore, if you visit one of our facilities, we collect certain limited personal information as part of our visitor management processes including your name; your contact details, your host’s name, your photograph, and license plate number for the purposes protecting the health and safety of all those that visit and work from our facilities. At certain locations, we may use CCTV which takes recordings for security surveillance purposes.

We will give you an opportunity to tell us whether we may use your Personal Information to send you other information about enableCV’s products, activities, or opportunities. In most circumstances, you will be able to “unsubscribe” from these communications by following the instructions provided at the time you sign up for the communications or that are included in such communications. enableCV does not sell Personal Information to third parties for the third parties’ marketing purposes.

We may use the Usage Data we and our partners collect during your future visits. This information allows us to direct you to specific content on the Sites that may be of interest and to remember your computer/device the next time you visit. If you visit multiple enableCV Sites, we may aggregate the Usage Data from your visits to better understand usage of our Sites.

We may use the device-related and analytics information we and our partners collect (about your computer’s IP address and through the use of cookies) during your future visits. This information allows us to direct you to specific content on the Sites that may be of interest and to remember your computer the next time you visit. If you visit multiple enableCV Sites, we may aggregate the information from your visits to better understand usage of our Sites.

We may also aggregate this device-related and analytics information we collect from all visitors, which helps us to improve our Sites by monitoring interest in the various Site content and understanding how our visitors navigate the Sites. This information may also help us diagnose any problems with our Sites.

If you choose to provide Personal Information to us, we may combine that information with the non-Personal Information collected through IP address recognition and cookies, to help us understand your specific interests and to deliver pertinent information to you.

Transfer of Personal Information to Other Countries

Any information that you provide or we collect will be available to enableCV affiliates and vendors around the world for purposes that are consistent with this Privacy Statement. This means that your information may be communicated to a country other than your country of residence for use, processing, or storage, and it may also be communicated to third parties hired by us to provide services such as website hosting, database management, or analytics services. Some of these countries may not have data protection laws that are equivalent to the laws of the country where you reside and governments of some of these countries, such as the United States, may have access to your Personal Information, but we have taken measures to ensure your Personal Information remains protected to the standards described in this Privacy Statement, wherever it is processed.

If you choose to provide your Personal Information to us via the Sites, this provision of information and your continued use of our Sites constitutes your acknowledgement of and consent to such transfers.

In addition, where necessary and applicable, enableCV may transfer Personal Information relating to individuals in the European Economic Area, the United Kingdom, and Switzerland to other countries in reliance on the Standard Contractual Clauses or other similarly approved contractual language.

Disclosure of Information to Third Parties

While we do not directly sell, rent, or loan your Personal Information, we may share your information with companies, organizations, and individuals outside of enableCV as described below.

Please note that certain U.S. state laws have adopted a broad definition of a “sale” and may treat certain of these disclosures as “sales” under their definitions. Please see our “Supplemental U.S. Privacy Statement” for additional information.

We may share your Personal Information with enableCV’s affiliates, with our business collaborators, and our product co-promotion and co-development partners, marketing and advertising agencies, and social media companies and platforms for the purposes set forth above and elsewhere in this Privacy Statement.

We may share Personal Information with our service providers, who are bound by law or contract to protect Personal Information and only use Personal Information in accordance with our instructions or the agreements we have signed. For example, we may share Personal Information with service providers who provide data processing or fulfilment services for us.

We may disclose Personal Information for legal and law enforcement purposes. This includes in response to legal process, for example, in response to a court order or a subpoena, or in response to a law enforcement agency’s request. For example, if you use a Site to report an adverse product experience, we may be required to report that information to the U.S. Food and Drug Administration (FDA) or to similar regulatory agencies in other countries.

We also may disclose such information to third parties: (i) in connection with fraud prevention activities, (ii) where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, (iii) in situations that may involve violations of our terms of use or other rules, (iv) to protect our rights and the rights and safety of others, (v) as needed to support external auditing, compliance and corporate governance functions, and (vi) as otherwise required by law.

We may also disclose your Personal Information to a third party in connection with the sale, assignment, or other transfer of an enableCV asset(s), which may include associated Sites to which the information relates. We will make it clear to the third party purchaser that it may only use Personal Information that is received from us for purposes consistent with this Privacy Statement. However, in the event of a sale or merger, your continued use of this Site signifies your agreement to be bound by the Privacy Statement and other applicable terms of the subsequent owner or operator.

Please note that we may also disclose data about you that is not personally identifiable. For example, we may publish reports that contain aggregate and statistical data about our customers.

Finally, we may alternatively request your consent to share your Personal Information with some third parties. In those circumstances, we will only share your Personal Information with your consent.

How We Protect Information

Consistent with applicable laws and requirements, we have put in place reasonable physical, technical, and administrative safeguards designed to protect Personal Information from loss, misuse, alteration, theft, unauthorized access, and unauthorized disclosure consistent with legal obligations and industry practices. However, as is the case with all websites, applications, products, and services, we unfortunately are not able to guarantee security for data collected through our Products and Services.

We are not responsible for any interception or interruption of any communications or for changes to or losses of data through the internet. Users of the Sites are responsible for maintaining the security of any password, user ID, or other form of authentication involved in obtaining access to password protected or secure areas of the Sites. It is your responsibility to safeguard any passwords, ID numbers, or similar individual information associated with your use of the Products and Services. Any access to the Sites through your user ID and password will be treated as authorized by you. If we believe it is necessary or advisable to help protect your Personal Information and/or the integrity of the Sites, we may suspend your use of all or part of the Sites, without notice.

Unauthorized access to any of the Sites is prohibited and may lead to criminal prosecution.

How Long We Retain Personal Information

We retain information as long as it is necessary and relevant for our business, operational, and legal purposes. In addition, we retain Personal Information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, and other actions permitted by law. When your Personal Information is no longer needed for enableCV’s business, operational, and legal purposes, we dispose of it subject to applicable law. Whenever possible, we aim to de-identify the information or otherwise remove some or all information that may identify you from records that we may need to keep for periods beyond the specified retention period.

Your Privacy Rights

In your use of the Sites, you will be given opportunities to make choices about the data we receive and how we use it.

Opting Out of Communications 

If you provide Personal Information to us, we may from time to time send you communications, including electronic communications about products or services. You may change your mind at any time and opt out of communications by following the instructions in any email communications we send you.

Cookie Preferences

We use first party and third-party cookies for several reasons, as described above. Some cookies are required for technical reasons in order for our Sites to operate, and we refer to these as “essential” or “strictly necessary” cookies. These cookies are required. Other cookies (including third party cookies) enable us to track the interests of our users in order to help us deliver more relevant marketing communications and to improve the features of our Sites. The specific types of first- and third-party cookies served through our Sites and the purposes they perform are described in the Cookie Preference Center.

Your Web browser settings allow you to change your cookie settings, and you may modify your cookie preferences by clicking “Cookie Preferences” in the website footer of the site you are visiting. Please be aware that if you choose to reject cookies, you may still use our Sites though your access to some functionality and areas of our Sites may be restricted. You also have the options described above in the Digital Advertising, Cookies and Other Data Collection Technologies section of this Privacy Statement.

Data Privacy Rights – U.S. States with Privacy Laws 

U.S. consumers residing in a state with a comprehensive privacy law, such as California, should visit the Supplemental U.S. Privacy Statement for more information regarding their privacy rights and the designated methods for making data subject rights requests under their respective state laws.

If you are a consumer residing in a U.S. state with a comprehensive consumer health data privacy law, such as the state of Washington, please review our Consumer Health Data Privacy Policy for our privacy practices related to consumer health data.

Data Privacy Rights – EEA

Consumers whose data is processed in the EEA should visit our Supplemental European Privacy Statement for more information regarding their privacy rights and choices.

Children’s Privacy

enableCV does not intend to collect Personal Information from children under the age of majority without consent from the child’s parent or legal guardian. We do not share Personal Information of anyone under the age of majority with anyone outside of enableCV (except where required by law, with consent, or to our agents who have committed to maintain data privacy).

Children under the age of majority should not submit any Personal Information to us without the express permission of their parent or legal guardian. If enableCV learns that a child under the age of majority has provided us with personal information about themselves or that another user has provided such information without appropriate parental or guardian consent, we will delete such information from our active databases in accordance with applicable law, unless we are required by law to retain it. If you believe that your child has submitted Personal Information and you would like to request that their information be removed from our systems, please use the contact information in the Contact Us section below. We will make reasonable efforts to comply with your request.

Supplemental European Privacy Statement

This Supplemental European Privacy Statement (“European Statement”) supplements this Privacy Statement and addresses legal obligations and rights arising from European privacy laws, such as the General Data Protection Regulation (“GDPR”) and UK General Data Protection Regulation (“UK GDPR”). This Supplemental European Privacy Statement only applies to individuals whose personal data is processed within the EEA.

Controller

The data controller means the person who determines the purposes and means of the processing of your personal data.  The data controller is enableCV. This interaction may occur through contract conclusion, premises visits, participation in an event, or other negotiations.

Consent to Processing and Transfer

enableCV is headquartered in Midvale, Utah in the United States. Our IT and other functions are administered in the United States, and your information may be transmitted to a country other than your country of residence for processing or storage, and it may also be communicated to third parties hired by us to provide services such as website hosting, database management, or analytics. Your use of the Sites means you consent to these transfers. Where the GDPR / UK GDPR applies, your Personal Information will be transferred to, and processed in accordance with the European Commission’s Standard Contractual Clauses (pursuant to the European Commission’s decision (CID (EU) 2021/914).

In addition to that, we have taken measures to ensure your personal information remains protected to the standards described in this policy, wherever it is processed. In respect of inter-company transfers, we have entered into inter-company agreements which implement the European Commission’s Standard Contractual Clauses (pursuant to the European Commission’s decision (CID (EU) 2021/914). As for transfers to third parties, we ensure compliance to requirements regarding cross-border transfers through the Standard Contractual Clauses and through consent, where applicable.

Do Not Track Signals

Some web browsers incorporate other “do-not-track” (“DNT”) or similar features that signals to websites with which the browser communicates that a visitor does not want to have their online activity tracked. As of the Effective Date, not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, enableCV Sites along with many other digital service operators do not respond to all DNT signals.

If you visit more than one enableCV Site, we do track your activities on all enableCV-run websites, so that we can improve your overall experience with enableCV.

Data Subject Rights

Where applicable under the GDPR, you have or may have the following data subject rights:

• Right of access: The right to know what specific personal information we hold about you, the categories of sources of that information, the purpose(s) for collecting the information, disclosures that have been made for business purposes, and the categories of third parties to whom it was disclosed.
• Right to rectification: The right to rectification of inaccurate personal data and the right to have incomplete personal data completed.
• Right to erasure: Under certain circumstances as required by law, the right to have your personal information deleted.
• Right to restriction of processing: The right to restrict the processing of your personal data upon your request.
• Right to data portability: The right to receive a copy of your personal data in a structured, common, and machine-readable format and to request that these data are transferred to another data controller.
• Right to object: If we base processing on our legitimate interest, you may have the right to object on grounds relating to your particular situation at any time to the processing of personal data concerning you.
• Right to withdraw consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note, however, that this will not affect the lawfulness of the processing before its withdrawal.
• Right to lodge a complaint with a supervisory authority: The right to lodge a complaint with a supervisory authority against the processing of your personal data if you believe that the processing of your personal data violates data protection regulations.

Requests may be submitted by contacting enableCV at the following link Contact – enableCV. We will respond within the legally-required timeframe. Please note that the law requires we verify your identity before responding to the request. We will not discriminate against you for exercising any of your privacy rights.

Our Commitment to Data Security and Protection

enableCV understands that the security of your personal information is of the utmost importance, and we work to maintain your trust. We use industry-standard technological and organizational measures to protect the security of the information that we collect and that which you provide to us.

If you have any questions or concerns regarding our approach to data security and protection, you can contact us using the contact information below and we will attempt to resolve your question or concern. We will also cooperate and comply with any investigation, decision or advice made or given by competent data protection authorities regarding personal information we receive.

Despite these reasonable efforts to safeguard personal information from loss, theft, alteration, or other types of misuse, we cannot guarantee that such loss will never occur. There is always a risk that a third party, without our authorization, might unlawfully access our systems or otherwise access personal information.

If You Have Concerns about Your Personal Information

If you have any questions about this Privacy Statement or about your personal information or if you want to exercise your privacy rights, you may contact us using the information below:

• By emailing Privacy@enableCV.com
• Privacy Office
  enableCV, LLC
  6967 S. River Gate Dr., Suite 104
  Midvale, Utah, 84047 USA

If you wish to receive a response by email, please be sure to include your name, postal address, and email address. If we do not receive an email address, we will respond by postal mail.

Supplemental U.S. Privacy Statement

This Supplemental U.S. Privacy Statement (“U.S. Statement”) supplements this Privacy Statement and addresses legal obligations and rights arising from U.S. state privacy laws, such as those in California and Virginia. This Supplemental U.S. Privacy Statement only applies to residents of states with comprehensive privacy laws. If you are a consumer residing in a U.S. state with a comprehensive consumer health data privacy law, such as the state of Washington, please review our Consumer Health Data Privacy Policy for our privacy practices related to your consumer health data.

Definition of Personal Information

“Personal Information” is any information—as electronically or otherwise recorded—that can be used to identify a person or that we can link to or associate with a specific individual. Personal Information may include information considered sensitive in some jurisdictions, such as biometric information, genetic information, health information, financial account information, specific geolocation, ethnic or racial origin, information concerning your sex life or your sexual orientation, social security number, driver’s license, state identification card, passport number, and other similar information. Some of the Personal Information we collect may be considered “Sensitive Personal Information.” For more information about how we collect, disclose, and share your Personal Information, please see the dropdowns below that represent your relationship with enableCV. Data that could be considered Sensitive Personal Information is noted with an asterisk (*) in the dropdowns below.

We will process any Personal Information we collect in accordance with applicable law and as described in this Statement (unless, as explained above, a separate policy or notice governs). In some circumstances, if you do not provide us with your Personal Information, certain Products and Services may be unavailable to you.

This U.S. Statement provides the information required under applicable U.S. state laws and applies to both enableCV’s online and offline activities relative to our processing of your Personal Information. This U.S. Statement and the relevant U.S. state laws do not apply to information that has been de-identified or aggregated. Some of the Personal Information that we collect, use, and disclose may, pursuant to provisions in the relevant laws, be exempt because it is regulated by other federal and state laws that apply to us.

FOR CONSUMERS

(Including those interested in our products or services, patients, caregivers, facility visitors, etc.): The following table provides you with a notice of the Personal Information we may collect from or about you, including Sensitive Personal Information, as well as information about how we will use it and the manner in which it will be processed and information about the categories of third parties with whom it is shared.

Some of this will depend on the nature of our interaction with you but can include the following with respect to Personal Information categories that we may have collected in the preceding twelve (12) months:

CALIFORNIA PROFESSIONALS

The following table provides detail for residents of California who interact with us in a professional capacity, such as (i) health care providers and their staff, (ii) clinical investigators and their staff, (iii) employees of companies with whom we conduct business, including employees of service providers, with respect to the category of Personal Information collected, the source of that information, the purposes for collection and sharing/disclosure, and the categories of third parties to whom the category of Personal Information is shared.

CALIFORNIA JOB APPLICANTS

The following table provides detail for residents of California who interact with us applicants for jobs, with respect to the category of Personal Information collected, the source of that information, the purposes for collection and sharing/disclosure, and the categories of third parties to whom the category of Personal Information is shared.

Other Uses of Personal Information

Mergers and Acquisitions.  In addition to the uses set forth above, in certain circumstances, we will use and disclose your Personal Information to facilitate a merger, consolidation, transfer of control or other corporate reorganization in which enableCV participates, or pursuant to a financial arrangement undertaken by enableCV and your Personal Information will be disclosed to the buyer, assignee, or transferee.

Data Retention.  We will retain your Personal Information for as long as needed or permitted to fulfill the purpose(s) for which it was collected or obtained, and as outlined in this Privacy Statement.  The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject that affects the Personal Information; and (iii) whether retention is determined to be necessary or advisable for enableCV due to applicable statutes of limitations, litigation, or other legal or regulatory obligations. We take reasonable steps to dispose of Personal Information upon the expiration of retention periods taking into consideration these litigation, legal, or regulatory obligations.

De-Identification.  We may de-identify your Personal Information, which means it will remove certain data from your Personal Information, such as Contact Information, such that the resulting data would not be able to identify you or anyone else as the subject of the data.  The de-identified data will no longer be Personal Information and may no longer be subject to data protection laws.  We will not attempt to re-identify you or anyone else from this de-identified data and if we disclose it to third parties, we will require that they commit to not attempting to re-identify you or anyone else from the de-identified data.  We will use de-identified data for our business purposes.

Third Parties

Third Party Advertising: We disclose Personal Information about you (as set forth in the table above) to third-party advertising network companies. We use third-party advertising network companies to place ads on other websites, including network advertising companies with whom we work who place their own cookies on your browser when you visit our Site. This enables these third-party advertising network companies to collect and use data from their cookie on your browser, which may include information about your visits to this and other websites. These advertising companies use and further disclose this information in order to deliver advertisements about our goods and services to you when you are on other websites. These advertisements will often be tailored to you. These advertisers may in turn disclose the information about you collected from their cookies to other advertisers to allow those advertisers to display ads to you as well.

In some jurisdictions, these cookies are disabled until you opt-in; in others, these are enabled by default, but you may have the right to opt out. You may opt-out of our disclosure of your Personal Information for these purposes as set forth below.

For additional information about how else we use cookies and other digital technologies, please see the Digital Advertising, Cookies and Other Data Collection Technologies section of the Privacy Statement.

Service Providers: Service providers acting on our behalf must execute agreements requiring them to maintain confidentiality and to process Personal Information as necessary to perform their functions in a manner consistent with this Statement, other applicable privacy notices, and as explicitly permitted or required by applicable laws, rules, and regulations.

Combination of Data with Data Received from Third Parties: We may combine information we collect, including Personal Information, with Personal Information that we may obtain from third parties.

Links to Other Websites: Our Products and Services may contain links to other websites, applications, products, or services that are not owned or operated by enableCV, such as social media websites and applications like Facebook and Twitter. You should carefully review the privacy policies and practices of other websites, products, and services as we cannot control and are not responsible for privacy policies, notices, or practices of third-party websites, applications, products, and services.

Do Not Track Signals and Global Privacy Control

Some web browsers incorporate other “do-not-track” (“DNT”) or similar features that signals to websites with which the browser communicates that a visitor does not want to have their online activity tracked. As of the Effective Date, not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, enableCV Sites along with many other digital service operators do not respond to all DNT signals.

Certain web browsers and other programs may transmit “opt-out” signals, such as the Global Privacy Control (or GPC) signal (we refer to these as “GPC Signals”), to websites with which the browser communicates.  In most cases you will need to change your web browser’s settings or add an application to your web browser to enable your browser to send a GPC Signal. Our websites will recognize GPC Signals for website users differently based on the location of the user when they access our websites.  For users that access our websites from U.S. states that have laws requiring recognition of GPC Signals, we will recognize and apply the GPC Signal to inactivate all but essential cookies for that website. (Essential cookies are necessary for the website to operate).  Regardless of your location, you may modify your cookie settings for the website you are visiting by clicking on the “Cookie Preferences” link in the website footer. For more information about the Global Privacy Control, please visit https://globalprivacycontrol.org.

Your Data Privacy Rights Regarding Your Personal Information

Please note that in many circumstances, we cannot effectively do business with you without processing some Personal Information about you (e.g., your contact information). For example, when you contact our customer service representatives, we may require you to provide information to authenticate your identity to assist you with your request. If you are unable to provide this information, we may be unable to process your request.

To the extent that the state in which you live has a data protection law that requires us to offer some or all of the following rights to you, we will provide the following rights to you based on your state’s law:

• To opt-out of selling or sharing your Personal Information for cross-context behavioral advertising or, in other states, to opt-out of targeted advertising,
• To opt out of profiling in furtherance of decisions that produce legal or similarly significant effects,
• To request access to and a copy of your Personal Information and/or your Sensitive Personal Information, including a request to provide a copy directly to another organization (i.e., a right to data portability),
• To request to confirm or know about the Personal Information we process about you or, in other states, to request to acknowledge our processing of your Personal Information,
• To request that we correct your Personal Information,
• To request that we delete your Personal Information (and notify any affiliates, processors, contractors, or other third parties with which we shared to delete it as well),
• To request that we limit the processing of your Sensitive Personal Information,
• To opt-out of processing of Sensitive Personal Information,
• To withdraw consent to the collection or sharing of your Sensitive Personal Information,
• To appeal the denial of a request, and
• To lodge a complaint with the data protection authority in your jurisdiction.

To learn which rights are provided in the state in which you live and to exercise any of these rights with respect to your Personal Information, please see the following section on How to Submit a Data Privacy Rights Request. We will not discriminate against you for exercising any of the rights described above, although we may not be able to continue to provide you Products and Services, or it may otherwise affect the way we are able to interact with you.

How to Submit a Data Privacy Rights Request

To submit a request to opt-out of targeted advertising, you may contact us using the information in the Contact Us section below.

To submit a request pursuant to your data privacy rights under U.S. state privacy laws, we have designated the following option for you to submit a data privacy rights request:

• by emailing us at Privacy@enableCV.com

We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. We may, after receiving your request, require additional information from you to honor your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.

You may designate an authorized agent to assist you in exercising any of your rights stated above. When you use an authorized agent to submit a request to exercise your rights, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

In the event you wish to make a complaint about how we process your Personal Information or appeal a response to your request, please contact us using the information in the Contact Us section below, and we will handle your request as soon as possible in accordance with applicable laws. Even if you make a complaint to us, you may always lodge a complaint with the relevant authority in your location.

When we receive your Personal Information from our customers and process your Personal Information on their behalf, we do so at their request and subject to their instructions. We do not have control over our customers’ privacy and security practices and processes. If your Personal Information has been submitted to us by an enableCV customer and you wish to exercise any of the above-mentioned rights, please contact the relevant customer directly.

Right of Non-Discrimination for Exercise of Your Privacy Rights

We will not discriminate against any person exercising his or her rights under applicable state data protection laws, as described above. Discrimination, in this context, includes that, as a result of exercising any of your data privacy rights, you are denied goods or services, charged different prices for goods or services, or provided a different level of quality.

Residents of U.S. states with comprehensive privacy laws who are unable to review or access this Supplemental U.S. Privacy Statement due to a disability may contact us to request access to this Statement in an alternative format. Please contact us using the information in the Contact Us section below.

Nevada Residents

enableCV does not sell Covered Information as defined under Nevada law. If you would like to make a further inquiry regarding the selling of your Covered Information as defined under Nevada law, please send an email to the Privacy Office at the email address provided below.

Contact Us

To exercise any rights you might be entitled to under applicable privacy laws, please utilize the designated mechanisms provided in the Supplemental European Privacy Statement or the Supplemental U.S. Privacy Statement. If you have any questions or concerns about this Privacy Statement or about your Personal Information, you may contact us as follows:

Privacy Office enableCV Legal Department

• email us at Privacy@enableCV.com

If you wish to receive a response by email, please be sure to include your name, postal address, and email address. If we do not receive an email address, we will respond by postal mail.

Changes to Our Privacy Statement

We may update this Privacy Statement from time to time. When we do update it, we will make the updated statement available on this page, and we will update the effective date at the top of the policy. Our intention is to use Personal Information in accordance with the Privacy Statement in place at the time the information was collected.

Consumer Health Data Privacy Policy

enableCV is committed to respecting your privacy. Our Privacy Statement above, describes how we handle your personal information generally.  This Consumer Health Data Privacy Policy supplements our Privacy Statement and applies to the collection of “Consumer Health Data” as defined in relevant comprehensive consumer health data privacy laws, including Washington’s My Health My Data Act (“WA MHMDA”).

In the event of a conflict between any other policy, statement, or notice and this Consumer Health Data Privacy Policy, this Policy will prevail as to Consumer Health Data collected under WA MHMDA and similar comprehensive consumer health data privacy laws.

“Consumer Health Data” means personal information that (1) is linked or is reasonably linkable to a consumer and (2) that identifies past, present, or future physical or mental health status. Consumer Health Data includes information about medical conditions, as well as non-medical information such as biometric data, information about use of non-prescription health-related products, and attempts to access reproductive or gender-affirming care. This policy does not apply to any personal information that does not fall under this definition.

Categories and Uses of Consumer Health Data that We Collect

enableCV only collects your Consumer Health Data as needed to provide you with the products or services that you request, or with your explicit consent.

enableCV may collect the following categories of Consumer Health Data:

• Individual health condition, treatment, disease, or diagnosis information;
• Social, psychological, behavioral, and medical intervention information;
• Health-related surgery or procedure information;
• Use or purchase of prescribed medication information;
• Bodily function, vital sign, symptoms, or measurement of health information;
• Diagnosis or diagnostic testing, treatment, or medication information;
• Biometric data;
• Information about your access to healthcare, including precise location information that could reasonably indicate an attempt to acquire or receive health services or supplies; or
• Information processed to associate or identify an individual with the data listed above that is derived or extrapolated from non-health information.

enableCV may process the categories of Consumer Health Data described above to the extent necessary to provide requested products or services, or with your consent, including:

• To determine and verify program, product, and service eligibility and coverage;
• To enroll you in our programs and provide our products and services to you;
• To administer, manage, analyze, and improve our programs, products, and services;
• To procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations;
• To analyze and better understand your needs, preferences, and interests, as well as those of other consumers;
• To conduct internal business analysis and market research;
• To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements;
• To comply with legal and regulatory obligations; or
• For our everyday business purposes.

Sources of Consumer Health Data

enableCV collects Consumer Health Data from the following sources:

• Directly from you, if you:
  • request health-related products and services;
  • enroll in our biometric access programs;
  • register to use our health or wellness-related apps;
  • join our email lists or loyalty programs; or
  • volunteer the information in connection with surveys or promotions.
• Indirectly from you (gathered directly by social media, other websites, or apps), if you:
  • interact with us by using our apps, accessing our systems, or entering our facilities;
  • enable certain mobile app functions, such as location tracking;
  • enable data syncing between our medical devices and your enrolled health-related app;
  • make your health data publicly available on social media or other websites; or
  • like, follow, or comment about health-related products on our social media sites.
• From healthcare professionals or hospital systems, when:
  • Contact information, financial/billing information, product requests, and other information are necessary for the purpose of providing our products and services;
  • An adverse event concerning an enableCV product occurs; or
  • A patient complains about an enableCV product.
• From our vendors, suppliers, consultants, professional advisers, and other third parties, when:
  • Business contact information, financial information, and other data is necessary for the purpose of managing and operating our business.
• From third parties who provide program enrollment, benefit verification, or product fulfillment services.
• Health Insurance Companies or other payors, when:
  • Information is necessary for the purpose of providing our products and services;
  • Information is necessary to determine program eligibility; or
  • Information is necessary to comply with legal and regulatory obligations.
• Your authorized legal representative, family members, or caregivers.

How We May Share Consumer Health Data

enableCV only shares or discloses your Consumer Health Data as needed to provide you with the products or services that you request, or with your explicit consent. We may share or disclose any or all of the above categories of Consumer Health Data to the following entities, who shall use the data only as permitted for the purposes set forth above, and within the bounds of our contracts with them:

These general categories of third parties:

• Business Collaborators,
• Product co-promotion partners,
• Product co-development partners,
• Marketing and Advertising Agencies,
• Social Media Companies and Platforms,
• Service Providers (including those hosting or analyzing data on our behalf, those assisting with fraud prevention, those assisting in program administration, those assisting in incident management and reporting, those administering our call center and websites, and those who assist with our Information Technology and Security programs),
• Emergency Personnel,
• Healthcare Providers (including pharmacies),
• Health Insurance Companies and health plans, or other payors,
• Authorized/legal representatives, family members, and caregivers,
• Third parties (including those with whom enableCV has joint marketing and similar arrangements, those who provide marketing and data analytics services, those who provide program enrollment or product fulfillment, those to whom disclosure is permitted by HIPAA and/or CMIA for treatment, payment, and authorization, other third parties as necessary to complete transactions and provide products/services, or where required by law),
• enableCV lawyers, auditors, and consultants, or
• Legal and regulatory bodies.

In addition, we may share or disclose Consumer Health Data as permitted or required by law, such as (i) to an acquiring organization if we are involved in a sale or a transfer of our business, (ii) as needed to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, (iii) in situations that may involve violations of our terms of use or other rules, (iv) to protect our rights and the rights and safety of others, (v) as needed to support external auditing, compliance and corporate governance functions, (vi) as needed to preserve the integrity or security of our systems, or (vii) to investigate, report, or prosecute those responsible for any action that is illegal under applicable state or Federal law.

Your Consumer Health Data Privacy Rights

Subject to certain legal limitations and exceptions, you have the following rights with respect to any Consumer Health Data we may collect about you:

• The right to confirm whether we are collecting, sharing, or selling your Consumer Health Data and to access such data, including to receive a list of affiliates or specific third parties with whom we have shared or sold your information, along with contact information such as an active email address for each third party;
• The right to review and request corrections to your Consumer Health Data;
• The right to withdraw consent from our collection or sharing of your Consumer Health Data; and
• The right to request that we delete your Consumer Health Data.

You may submit a request pursuant to any of these rights:

• by emailing us at Privacy@enableCV.com

enableCV will not discriminate against you for exercising any of your rights. We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. Please allow 45 days for a response.  We may, after receiving your request, require additional information from you to authenticate your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.

If we deny your request, you have the right to appeal that denial by contacting us again at the email above. We will process and respond to your appeal within the time permitted by applicable law. If you are a Washington resident and your appeal is unsuccessful, you may file a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

Changes to Our Consumer Health Data Privacy Policy

We may update this Consumer Health Data Privacy Policy from time to time. When we do update it, for your convenience, we will make the updated statement available on this page. Our intention is to use Consumer Health Data in accordance with the Consumer Health Data Privacy Policy in place at the time the Consumer Health Data was collected.

Nevada Supplemental Consumer Health Data Privacy Policy

This Supplement applies to Nevada consumers for purposes of providing additional disclosures required by Nevada’s Consumer Health Data Privacy Law. We collect, use, process, and share Consumer Health Data for the purposes and manners described above in our Consumer Health Data Privacy Policy.

Third Party Collection of Consumer Health Data on enableCV Websites. We limit third party collection of Consumer Health Data over time and across different Internet websites or online services when Nevada consumers use our websites or online services. We do this by disabling certain cookies or by ensuring that entities whose cookies, web beacons, pixels, and other online trackers we use on our websites and online services are our service providers or processors under applicable U.S. state privacy or consumer health data privacy laws. Nonetheless, please note that other third parties may still be able to process Consumer Health Data from you over time and across different websites depending on your browser, browser settings and add-ons, and associated permissions you have set on your device. This collection of Consumer Health Data by those third parties is unrelated to enableCV processing of Consumer Health Data from you, and we encourage you to review your browser settings and review those third parties’ privacy notices for more information about their Consumer Health Data practices.

Review and Revision of Consumer Health Data. If you would like to review and/or revise your Consumer Health Data, you may submit a request to us via any of the methods listed in Your Consumer Health Data Privacy Rights.

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