OMRON HEALTHCARE, INC. PRIVACY POLICY

Updated July 9, 2021

This Privacy Policy explains how Omron Healthcare, Inc. (“Omron” “we,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies when you use our website located at https://omronhealthcare.com/ (the “Site”), as well as our other websites, mobile applications, and other online products and services that link to this Privacy Policy (collectively, our “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us. Unless otherwise stated herein, this Privacy Policy does not apply to information collected by (i) any third party (including our affiliates and subsidiaries); and (ii) Omron offline or through any other means. Some Omron affiliates’ sites and services (e.g., Omron.com and Omron247.com) are governed by that Omron affiliate’s own separate privacy policies and practices. Additionally, our online store, including any related payment processing, is operated and handled by our online store service provider and is subject to a separate privacy policy and terms of sale provided at the online store site.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you regarding your personal information. Please also review the Terms of Use linked to the Services that apply to your use of the specific Omron Service.

Additionally, if you are a California resident, you may have additional rights under California law. Therefore, please review the section titled Your California Privacy Rights.

By using our Services, you consent to our Privacy Policy and agree to our Terms of Use. If you do not consent to this Privacy Policy, your choice is to not use our Site or Services.

CONTENTS

Collection of Information
Use of Information
Sharing of Information
Links to Other Websites and Applications
Advertising and Analytics
Visitors to the Site from Outside of the United States
Your Choices and Updating Your Information
Security and Retention
Your California Privacy Rights
Contact Us

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us. The types of personal information we may collect include your
name, date of birth, email address, postal address, phone number, and any other information you choose to provide.
For example, you share information directly with us when you register a product, create an account, sign up to
receive our newsletter or other email communications from us, fill out a form, submit or post content through our
Services, communicate with us via third-party platforms, participate in a contest or promotion, request customer
support, or otherwise communicate with us. You may also choose to add information to your mobile application
account, such as your profile image, biography, race, ethnicity or any other contact information or third-party
email addresses. Additional information that you may provide us if you use a connected Omron device, such as Omron
Complete or a Kardia Mobile Device (collectively referred to as “Omron Device”) may
include:

  • Activity Information: We may collect information about your activity, such as your blood
    pressure, heart rate, blood pressure monitor cuff position, movement error and location on the body where
    the electrocardiogram (“EKG” or “ECG”) recording was taken (e.g. finger tips, chest, limbs, etc.).
  • Health History and Information: We also collect health information that you choose to
    provide through your use of our mobile applications, such as: your (and your family) medical history,
    current medical conditions and diagnoses, current medications, test results, raw EKG measurement data and
    readings, average heart rate, blood pressure readings, pulse rate, irregular heartbeat, average blood
    pressure results and any notes, tags or voice memos to EKG recordings you make.
  • Fitness and Behavioral Information: Lastly, we may collect health and fitness-related
    information that you choose to provide us, including your height, weight, Body Mass Index, skeletal muscle
    percentage, resting metabolism, body fat percentage, visceral fat level, alcohol and caffeine consumption,
    whether you are a smoker or non-smoker, steps you’ve taken, distance walked, aerobic steps, calories burned,
    sleep duration, total awake time, low movement, high movement, auto sleep details, daily fitness goals
    (e.g., steps, sleep, weight, etc.), weight tracking, any notes, tags, dates, times and readings of the
    fitness and behavioral information and any other details relating to your fitness and behavioral information
    where you choose to share.

Information We Collect Automatically When You Interact with Us

We collect information automatically through your use of our Services (including our mobile applications), from
devices and certain services with which you sync, such as Apple Health, Samsung Health and Google Fit or any other
third-party application(s). When you access or use our Services, we automatically collect certain information,
including:

  • Device and Usage Information: We collect information about how you access our Services,
    including data about the device and network you use, such as your hardware model, operating system version,
    mobile network, IP address, unique device identifiers, browser type, application version, device language,
    and accelerometer data (when using the mobile application). We also collect information about your activity
    on our Services, such as access times, pages viewed, links clicked, and the page you visited before
    navigating to our Services.
  • Location Information: In accordance with your device permissions, we may collect
    information about the precise location of your device. You may stop the collection of precise location
    information at any time (see the Your Choices and Updating Your Information
    section below for details).
  • Information Collected by Cookies and Similar Tracking Technologies: We (and our service
    providers) use tracking technologies, such as cookies and web beacons, to collect information about you.
    Cookies are small data files stored on your hard drive or in device memory that help us improve our Services
    and your experience, see which areas and features of our Services are popular, and count visits. Web beacons
    (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our
    emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more
    information about cookies and how to disable them, see our Cookie Policy
    and the Your Choices and Updating Your Information section below.
  • Omron Device Information. We collect information about the specific Omron Device you use,
    such as device identifiers (user ID(s), device model, serial number, and any identifiers you assign to your
    device) and when your Omron Device is near your device to which the Omron Device connects.

Information We Collect from Other Sources

We obtain information from third-party sources. For example, we may collect information about you from advertising
networks, internet service providers, data analytics providers, operating systems and platforms, other third-party
applications with which you connect (e.g., Apple Health, Samsung Health and Google Fit, social networks, data
brokers) and you directly.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make
inferences about your location based on your IP address or infer that you are looking to purchase certain products
based on your browsing behavior and past purchases.

USE OF INFORMATION

We use the information we collect directly, automatically and through third-party applications, such as Apple
Health, Samsung Health, Google Fit and any other third-party applications to deliver the products and services you
request and customize your experience with us. We also use the information we collect to:

  • Provide our Services to you, communicate with you about your use of our Site and Services, respond to your
    inquiries, fulfill your orders, and for other customer service purposes;
  • Tailor the content and information that we may send or display to you, offer location customization, offer
    personalized help and instructions, and otherwise personalize and improve your experiences while using the
    Site or Services;
  • Send marketing and promotional information, including news and newsletters, special offers, and promotions,
    or to otherwise contact you about products or information we think may interest you, including information
    about third-party products and services, to the extent permitted by law and, where required, with your
    consent;
  • Authenticate your identity;
  • Provide, maintain, and improve our products and Services;
  • Better understand how users access and use our Site and Services, both on an aggregated and individualized
    basis, in order to improve our Site and Services and respond to user desires and preferences, and for other
    research and analytical purposes;
  • Send you customer experience surveys, questionnaires, and recall notices;
  • Personalize and improve your experience on our Services;
  • Send you technical notices, security alerts, and support and administrative messages;
  • Respond to your comments and questions and provide customer service;
  • Communicate with you about products, services, and events offered by Omron and others and provide news and
    information that we think will interest you (see the Your Choices and Updating
    Your Information
    section below for information about how to opt out of these communications at any
    time);
  • Provide and administer our loyalty program (see the Financial Incentives section
    for further information);
  • Monitor and analyze trends, usage, and activities in connection with our Services;
  • Personalize the advertisements you see on third-party platforms and websites (for more information, see the
    Advertising and Analytics section below);
  • Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
  • Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal
    activity and protect the rights and property of Omron and others;
  • Debug to identify and repair errors in our Services;
  • Monitor your compliance with any of your agreements with us;
  • Comply with our legal and financial obligations;
  • Manage or transfer our assets or liabilities, for example in the case of an actual or potential acquisition,
    disposition or merger; and
  • Carry out any other purpose described to you at the time the information was collected.

Cross-Device Tracking Use

We and our third-party service providers may use the information that we collect about you (whether directly from
our mobile applications, through your device(s), or from a third-party) to identify other devices that you use
(e.g., a mobile phone, tablet, other computer, etc.).  This information helps us and our service providers
serve targeted advertising on your devices and to send you emails.  See the section in this Privacy Policy
titled Advertising and Analytics below for more information.

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this Privacy Policy:

  • We share personal information with vendors, service providers, and consultants that need access to personal
    information in order to perform services for us, such as companies that assist us with web hosting, shipping
    and delivery, payment processing, fraud prevention, customer service, and marketing and advertising.
  • If you submit a product review or post content in another public area of our Services, we share this
    information publicly on our Services.
  • We share personal information with third-parties for their own services and marketing purposes, unless you
    opt out of this type of sharing by contacting us by phone at (866) 216-1333
    or online by completing this Contact Us
    form
    indicating your request to opt out of such sharing. California residents may also opt out by
    clicking the “Do Not Sell My Personal Information” link that is prominently displayed in our Site’s footer
    or the button below.

  • We may disclose personal information if we believe that disclosure is in accordance with, or required by,
    any applicable law or legal process, including lawful requests by public authorities to meet national
    security or law enforcement requirements.
  • We may share personal information if we believe that your actions are inconsistent with our user agreements
    or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the
    rights, property, and safety of Omron, our users, the public, or others.
  • We share personal information with our lawyers and other professional advisors where necessary to obtain
    advice or otherwise protect and manage our business interests.
  • We may share personal information in connection with, or during negotiations concerning, any merger, sale of
    company assets, financing, or acquisition of all or a portion of our business by another company.

In addition to the above, if you use one of our mobile applications, we may share your personal information as
follows:

  • With your consent and direction, we may share or disclose your information, including information collected
    from your Omron Devices, with third parties that you designate to receive your information. If you choose to
    share your information with such third parties, this privacy policy will not apply to those third parties’
    use of your personal information. Those third parties’ privacy policies and practices will govern such use;
    therefore, please review such third parties’ privacy policy or similar notice regarding that third party’s
    practices with respect to your personal information.
  • With your consent, we may share your personal information, including data collected from your Omron Devices,
    with other health-focused mobile applications installed on your mobile device, such as Apple Health, Samsung
    Health or Google Fit, to help you track your health and wellness information.
  • If you choose to participate in a clinical trial study (“Study”), you will first
    be required to sign an authorization form (“Informed Consent”) from the physicians
    or other health care providers, clinical trial programs or other related third parties (“Study
    Team
    ”) for that specific Study. By connecting to our mobile application or using data
    obtained from your Omron Device to participate in the Study, you consent to the collection of your personal
    information through the mobile application, as outlined in the applicable Informed Consent for that Study.
    The personal information we collect through the mobile application may be shared with the Study Team, in
    accordance with our agreement with the Study Team and any privacy notices provided to you by the Study Team.
    Please note that deleting the mobile application will not withdraw you from the Study. Contact the Study
    Team directly if you have any questions about the Study or wish to withdraw from participating in such
    Study.

We also share aggregated or de-identified information that cannot reasonably be used to identify you, including data
collected through our Services (including our mobile applications), with healthcare researchers, research
organizations, and other third parties.

LINKS TO OTHER WEBSITES AND APPLICATIONS

The Site or our other Services, including our mobile applications, may contain various links to, as well as plug-ins
or widgets from, social media and other third-party websites or applications, which may provide additional
information, goods, services, and/or promotions. These third-party websites or applications are owned and operated
independently of Omron and have their own separate privacy and data collection practices. We are not responsible for
the privacy practices of any third party; therefore, you should review their privacy policies and practices prior to
interacting with their websites or applications, using any of their tools, or sharing any of your personal
information with them.

ADVERTISING AND ANALYTICS

We allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile
applications. These entities may use cookies, web beacons, device identifiers, and other technologies to collect
information about your use of our Services and other websites and applications, including your IP address, web
browser, mobile network information, pages viewed, time spent on pages or in mobile applications, links clicked, and
conversion information. This information may be used by Omron and others to, among other things, analyze and track
data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our
Services and other websites, and better understand your online activity.

We also work with third parties to serve ads to you as part of customized campaigns on third‑party platforms (such
as Facebook and Instagram). As part of these ad campaigns, we or the third-party platforms may convert information
about you, such as your email address and phone number, into a unique value that can be matched with a user account
on these platforms to allow us to learn about your interests and serve you advertising that is customized to your
interests. Note that the third-party platforms may offer you choices about whether you see these types of customized
ads.

Additionally, when you use our mobile application or its content, certain third parties may collect information
about you or your device. We use automated applications, such as Google BigQuery, Segment and Mixpanel, to evaluate
usage of our mobile application. We also may evaluate our mobile application using other analytic means. We use
these tools to help us improve our mobile application, services, performance, and user experiences. These third
parties may use tracking technologies to collect information about you when you use the mobile application. The
information they collect may be associated with your personal information and online activities over time and across
different apps and other online services.

The device you use to access and use our Services may allow you to opt out of having certain information collected,
including through mobile applications, and used for behavioral advertising purposes (e.g., “Limit Ad Tracking” on
iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android).

Online Tracking & Shine the Light

For more information about interest-based ads and how to opt out of having your web browsing information used for
behavioral advertising purposes, please visit www.aboutads.info/choices. You may
also contact us directly by phone at (866) 216-1333 or online by completing this Contact Us form.

California law permits residents of California to request certain details about how their information is shared with
third parties for direct marketing purposes. If you are a California resident and would like to make such a request,
please contact us at (866) 216-1333 or online by completing this Contact Us form.

VISITORS TO THE SITE FROM OUTSIDE OF THE UNITED STATES

Omron is headquartered in the United States, and we have operations and service providers in the United States and
other countries. If you are visiting the Site from a location outside of the U.S., your connection will be through
and to servers located in the U.S. Therefore, we and our service providers may transfer your personal information
to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to
those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate
level of protection in the jurisdictions in which we process it. By using the Site or providing us with any
information, you consent to the transfer to, and processing, usage, sharing and storage of your information in the
United States and in other countries, as set forth in this privacy policy.

YOUR CHOICES AND UPDATING YOUR INFORMATION

Account Information

We will make a reasonable effort to ensure that your personal information used or disclosed by us is accurate and
complete. In most cases, however, we rely on you to ensure that your information is current, complete, and accurate.
Some of our Services may allow you to update your account information. If so, you may do so at any time by logging
into your account or by contacting us at this Contact
Us form
. If you wish to delete your account, please contact us by phone at (866)
216-1333
or directly at this Contact Us
form
, but note that we may retain certain information as required by law or for our legitimate business
purposes.

If you demonstrate the inaccuracy or incompleteness of the information we maintain about you, we will assist you in
updating the information as required. If appropriate, we will send the amended information to third parties to whom
the information has been disclosed. When a challenge regarding the accuracy of personal information is not resolved
to your satisfaction, we will annotate the personal information under our control with a note that the correction
was requested but not made.

Location Information

To the extent any of our mobile applications collect location information, you will be asked to consent to the app’s
collection of this information when you first pair your Omron Device to such app and each time thereafter when you
sync with such apps. If you initially consent to our collection of such location information, you can withdraw
consent at any time by changing the preferences on the mobile device you use to access the mobile application (e.g.,
mobile phone, tablet, etc.). You may also stop our collection of this location information by following the standard
uninstall process to remove all of our mobile applications from your device. However, please note that some features
of our Services may no longer function properly if you stop our collection of this location information.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings
to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability
and functionality of our Services. For more information about cookies and how to disable them, see our Cookie Policy.

Communications Preferences

You may opt out of receiving text messages or promotional emails from Omron by following the unsubscribe or opt out
instructions in those communications or completing the Email Preference Center Form
or by contacting us directly by calling (866) 216-1333 or at this Contact Us form.

If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing
business relations.

Mobile Push Notifications

With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any
time by changing the notification settings on your mobile device.

SECURITY AND RETENTION

Security of My Personal Information

We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized
access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures
can guarantee security completely. Although we do our best to protect your information, we cannot guarantee the
security of your personal information transmitted through our Services, including our mobile applications. Further,
we are not responsible for circumvention of any privacy settings or security measure we provide. Please take steps
to protect against unauthorized access to your password, phone, mobile device, or computer by, among other things,
signing off after using a shared computer or device, choosing a robust password that nobody else knows or can easily
guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised
passwords or for any activity on your account via unauthorized password activity. If you have a security-related
concern, please contact us by phone at (866) 216-1333 or directly at this Contact Us form.

Data Retention

We keep your personal information only for so long as necessary to fulfill the purposes for which it was collected
and for other legitimate business purposes, including to meet our legal, regulatory, or other compliance
obligations. Omron will retain your information indefinitely if it believes in good faith that we have a legal
obligation to do so.

YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) and the Shine the Light
law (Cal. Civ. Code § 1798.83) afford consumers residing in California certain rights with respect to their personal
information. If you are a California resident, this section applies to you. This section of the Privacy Statement
applies to information collected online and offline through or in connection with our Site, mobile applications, or
other Services.

California Consumer Privacy Act

In the preceding 12 months, we have collected the categories of personal information set forth in the table below.
For details about the precise data points we collect and the categories of sources of such collection, please see
the Collection of Information section above. We collect personal information
for the business and commercial purposes described in the Use of Information section
above. In the preceding 12 months, we have disclosed the following categories of personal information for business
purposes to the following categories of recipients:

Category of Personal Information Categories of Recipients
Identifiers (such as name, email address, telephone number, IP address,
unique device ID, etc.)
Vendors and service providers such as payment processing, web hosting, information technology, customer
service, cloud service, data analytics, social networks, marketing and advertising
Internet or Other Electronic Network Information (such as domain information, browsing activity, session
information, cookie information)
Vendors and service providers such as payment processing, web hosting, information technology, customer
service, cloud service, data analytics, social networks, marketing and advertising
Commercial Information (such as information about Services purchased, obtained, or considered) Vendors and service providers such as payment processing, web hosting, information technology, customer
service, cloud service, data analytics, social networks, marketing and advertising
Geolocation Information Vendors and service providers such as payment processing, web hosting, information technology, customer
service, cloud service, data analytics, social networks, marketing and advertising
Inferences (such as characteristics, interests, and trends) Vendors and service providers such as payment processing, web hosting, information technology, customer
service, cloud service, data analytics, social networks, marketing and advertising
Protected Classifications (such as gender, age, household information) Vendors and service providers such as payment processing, web hosting, information technology, customer
service, cloud service, data analytics, social networks, marketing and advertising
Biometric Information (such as blood pressure, electrocardiogram information, and weight) from our
mobile application
Vendors and service providers such as payment processing, web hosting, information technology, customer
service, cloud service, data analytics, social networks, marketing and advertising

Do Not Sell My Personal Information

We do not sell your personal information for money but we and our business partners use tracking technologies to
help us to understand our customers and visitors to the Services, to enhance your online experience, and to
customize our offerings in ways that may be deemed a “sale” of personal information under the CCPA. This includes
working with third parties such as ad networks that collect personal information via tracking technologies to
personalize advertisements on and off our Services and to provide us with data collection, reporting, and ad
response measurement. To the extent we or our partners use such technologies on the Services, we offer a “Do Not
Sell My Personal Information” opt-out (

), as discussed in the Advertising and
Analytics
section above. If you elect to opt out, then we will notify third parties of your request.

We do not knowingly sell personal information about consumers under the age of 16.

Your Rights under the CCPA

Subject to certain limitations, you have the right to (1) request to know more about the categories and specific
pieces of personal information we collect, use, disclose, and sell, (2) request deletion of your personal
information, (3) opt out of any “sales” of your personal information that may be occurring, and (4) not be
discriminated against for exercising these rights.

The rights to know and delete are subject to our being able to reasonably verify your identity and authority to make
these requests. In order to verify your identity when you submit a request, we will ask you to provide two (2) or
three (3) pieces of personal information to confirm in our records. For example, if you purchased an Omron product
or Service through our Site, you will be asked to provide at least your name and details of your recent interactions
with us.

How to Submit a Request Under the CCPA

If your Personal Information is subject to the CCPA, you may make these requests by calling (866) 216-1333 or completing this Consumer Request
Submission Form
. You may also authorize someone to exercise these rights on your behalf. In order to do so,
we require signed permission. If we receive your request from an authorized agent, we may ask for evidence that you
have provided such agent with power of attorney or equivalent document that the agent otherwise has valid written
authority to submit requests to exercise rights on your behalf. We will not discriminate against you if you exercise
your rights under the CCPA.

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with
a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on
your behalf. Once we have a copy of the valid signed authorization, your designated representative/authorized agent
will be able to exercise these rights with respect to the account(s) listed on such authorization for the life of
the account, unless there is a specified term or expiration date on the authorization form. Any information gathered
as part of the verification process will be used for verification purposes only. Responses to verifiable consumer
requests will be delivered through secure email or postal mail, depending on your election when you submit such
requests.

If you are an authorized agent seeking to make a request, please contact us by phone at (866)
216-1333
or online by completing this Consumer
Request Submission Form
.

Financial Incentives

We provide price discounts, rewards, services, and other perks for members of our loyalty programs related to
certain Omron Services (collectively “rewards programs”) and members of our mailing list.
Through these offerings, consumers like you provide us with some personal information (e.g., names, emails, phone
numbers, health and medication information, and information about your daily routine) when you opt in and
participate in our rewards programs. There is no obligation to opt in and you, as well as other consumers, may opt
out at any time. The details of each rewards program are contained in the applicable offering. Our rewards programs
can be found in the “Rewards” section of our mobile applications. We offer these rewards programs, among other
things, to enhance our relationship with you so you can enjoy more of our products/services at a lower price. We
invest heavily in our marketing and brands, in part, so we can provide rewards programs to our customers. Consumer
data is valuable to our business only when it is combined with a sufficient number of other consumer data and after
it is enhanced by our efforts described below. The value to our business of any individual consumer’s personal
information is dependent on a number of factors, including, for example, whether and to what extent you take
advantage of any offerings, whether and to what extent you opt out of any offerings, and whether we are able to
enhance the data through our efforts described below. Our ability to create any value from the rewards programs is
heavily based on our ability to leverage said intellectual properties. We do not calculate the value of consumer
data in our accounting statements. We make this good faith estimate for California residents. To the extent we
create overall value from our rewards programs to our business that could be directly or reasonably related to the
value of customer data, the method for calculating the same would include: (1) the expenses associated with the
offer, provision or imposition of any financial incentive or price or service differences, such as our intellectual
property, data analytics, and marketing operations, (2) the expenses related to the collection, retention and
enhancement of customer’s personal information, and (3) all other expenses reasonably related to the rewards
programs.

You can opt-in to, or opt-out of, our rewards programs at any time through the same means they are offered, or by
contacting us at this Contact Us form or by
phone at (866) 216-1333.

CONTACT US

If you have any questions about this Privacy Policy, please contact us this Contact Us
form
or by phone at (866) 216-1333.