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Last updated June 16, 2020

Thank you for choosing to be part of our community at OPUN (“Company”, “we”, “us”, or

“our”). We are committed to protecting your personal information and your right to privacy. If

you have any questions or concerns about our policy, or our practices with regards to your

personal information, please contact us at privacy@opun.ai.

When you visit our website opun.ai or opun.app or mobile application, and use our services,

you trust us with your personal information. We take your privacy very seriously. In

this privacy policy, we seek to explain to you in the clearest way possible what information

we collect, how we use it and what rights you have in relation to it. We hope you take some

time to read through it carefully, as it is important. If there are any terms in this privacy

policy that you do not agree with, please discontinue use of our Sites or Apps and our

services.

This privacy policy applies to all information collected through our website (such

as opun.ai/opun.app), mobile application, ("Apps"), and/or any related services, sales,

marketing or events (we refer to them collectively in this privacy policy as the "Services").

Please read this privacy policy carefully as it will help you make informed decisions

about sharing your personal information with us.

    PRIVACY POLICY 
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Table of Contents 
WHAT INFORMATION DO WE COLLECT? .................................................................................................. 3 
HOW DO WE USE YOUR INFORMATION? ................................................................................................. 4 
WILL YOUR INFORMATION BE SHARED WITH ANYONE? .......................................................................... 5 
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? ............................................................... 6 
DO WE USE GOOGLE MAPS? ..................................................................................................................... 6 
HOW LONG DO WE KEEP YOUR INFORMATION? ..................................................................................... 6 
HOW DO WE KEEP YOUR INFORMATION SAFE? ....................................................................................... 7 
DO WE COLLECT INFORMATION FROM MINORS? .................................................................................... 7 
WHAT ARE YOUR PRIVACY RIGHTS? ......................................................................................................... 8 
DATA BREACH ......................................................................................................................................... 9 
CONTROLS FOR DO-NOT-TRACK FEATURES ............................................................................................ 9 
DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? .............................................................. 9 
DO WE MAKE UPDATES TO THIS POLICY? ............................................................................................. 10 
HOW CAN YOU CONTACT US ABOUT THIS POLICY? ............................................................................. 10 
 
   

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1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when registering at

the Services or Apps, expressing an interest in obtaining information about us or our

products and services, when participating in activities on the Services or Apps (such as

posting messages in our online forums) or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us

and the Services or Apps, the choices you make and the products and features you use.

The personal information we collect can include the following:

Publicly Available Personal Information. We collect first name, last name, and

nickname; email addresses; phone numbers; birth date and other similar data.

Personal Information Provided by You. We collect data about health, medical records,

; data held by a hospital or doctor; and other similar data.

All personal information that you provide to us must be true, complete and accurate, and

you must notify us of any changes to such personal information.

Information collected through our Apps

In Short: We may collect information regarding your geo-location, mobile device, push

notifications, when you use our apps.

If you use our Apps, we may also collect the following information:

▪ Geo-Location Information. We may request access or permission to and track

location-based information from your mobile device, either continuously or while you

are using our mobile application, to provide location-based services. If you wish to

change our access or permissions, you may do so in your device's settings.

▪ Mobile Device Access. We may request access or permission to certain features

from your mobile device, including your mobile

device's bluetooth, camera, microphone, sms messages, and other features. If you

wish to change our access or permissions, you may do so in your device's settings.

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▪ Push Notifications. We may request to send you push notifications regarding your

account or the mobile application. If you wish to opt-out from receiving these types of

communications, you may turn them off in your device's settings.

Information collected from other sources

In Short: We may collect limited data from Testing Agencies, Health Care Providers , and

other outside sources.

We may obtain information about your Health Status, Test Results from other sources, such

as testing agencies, clinical lab, drive thru Testing camps, as well as from other third

parties. Examples of the information we receive from other sources include: Health Status

and/or Testing results. We will inform you about the source of information and the type of

information and the type of information we have collected about you within a reasonable

period after obtaining the personal data, but at the latest within one month.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business

interests, the fulfillment of our contract with you, compliance with our legal obligations,

and/or your consent.

We use personal information collected via our Services or Apps for a variety of business

purposes described below. We process your personal information for these purposes in

reliance on our legitimate business interests, in order to enter into or perform a contract with

you, with your consent, and/or for compliance with our legal obligations. We indicate the

specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

▪ To facilitate account creation, logon, and account recovery process. If you

choose to link your account with us to a third party account (such as your Google or

Facebook account), we use the information you allowed us to collect from those third

parties to facilitate account creation and logon process for the performance of the

contract.

▪ To deliver services to the user. We may use your information to provide you with

the requested service.

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3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you

with services, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:

▪ Consent: We may process your data if you have given us specific consent to use

your personal information in a specific purpose.

▪ Legitimate Interests: We may process your data when it is reasonably necessary to

achieve our legitimate business interests.

▪ Performance of a Contract: Where we have entered into a contract with you, we

may process your personal information to fulfill the terms of our contract.

▪ Legal Obligations: We may disclose your information where we are legally required

to do so in order to comply with applicable law, governmental requests, a judicial

proceeding, court order, or legal process, such as in response to a court order or a

subpoena (including in response to public authorities to meet national security or law

enforcement requirements).

▪ Vital Interests: We may disclose your information where we believe it is necessary

to investigate, prevent, or take action regarding potential violations of our policies,

suspected fraud, situations involving potential threats to the safety of any person and

illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in

the following situations:

• Business Transfers. We may share or transfer your information in connection with, or

during negotiations of, any merger, sale of company assets, financing, or acquisition of all

or a portion of our business to another company.

• Third-Party Advertisers. We will NOT use third-party advertising companies to serve

ads when you visit the Services or Apps.

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4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your

information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to

access or store information. Specific information about how we use such technologies and

how you can refuse certain cookies is set out in our Cookie Policy.

5. DO WE USE GOOGLE MAPS?

In Short: Yes, we use Google Maps for the purpose of providing better service.

This website, mobile application, uses Google Maps APIs. You may find the Google Maps

APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to

this link.

By using our Maps API Implementation, you agree to be bound by Google’s Terms of

Service. By using our implementation of the Google Maps APIs, you agree to allow us to

gain access to information about you and non-personally identifiable information (such as

location). We will be collecting the following information:

■ location details

For a full list of what we use information for, please see the previous section titled "HOW

DO WE USE YOUR INFORMATION?" and “WILL YOUR INFORMATION BE SHARED

WITH ANYONE?”

The Maps APIs that we use store and access cookies and other information on your

devices. If you are a user currently in the European Economic Area (EU countries, Iceland,

Liechtenstein and Norway), please take a look at our EU User Consent Policy.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined

in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes

set out in this privacy policy, unless a longer retention period is required or permitted by law

(such as tax, accounting or other legal requirements). No purpose in this policy will require

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us keeping your personal information for longer than the period of time in which users have

an account with us.

When we have no ongoing legitimate business need to process your personal information,

we will either delete or anonymize it, or, if this is not possible (for example, because your

personal information has been stored in backup archives), then we will securely store your

personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational

and technical security measures.

We have implemented appropriate technical and organizational security measures designed

to protect the security of any personal information we process. However, please also

remember that we cannot guarantee that the internet itself is 100% secure. Although we will

do our best to protect your personal information, transmission of personal information to and

from our Services or Apps is at your own risk. You should only access the services within a

secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of

age.

We do not knowingly solicit data from or market to children under 18 years of age. By using

the Services or Apps, you represent that you are at least 18 or that you are the parent or

guardian of such a minor and consent to such minor dependent’s use of

the Services or Apps. If we learn that personal information from users less than 18 years of

age has been collected, we will deactivate the account and take reasonable measures to

promptly delete such data from our records. If you become aware of any data we have

collected from children under age 18, please contact us at privacy@opun.ai.

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9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area, you have rights that

allow you greater access to and control over your personal information. You may review,

change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under

applicable data protection laws. These may include the right (i) to request access and

obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to

restrict the processing of your personal information; and (iv) if applicable, to data portability.

In certain circumstances, you may also have the right to object to the processing of your

personal information. To make such a request, please use the contact details provided

below. We will consider and act upon any request in accordance with applicable data

protection laws.

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.

If you are resident in the European Economic Area and you believe we are unlawfully

processing your personal information, you also have the right to complain to your local data

protection supervisory authority. You can find their contact details

here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you have questions or comments about your privacy rights, you may email us

at privacy@opun.ai.

Account Information

If you would at any time like to review or change the information in your account or

terminate your account, you can:

■ Log into your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and

information from our active databases. However, some information may be retained in our

files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our

■ Access your account settings and update preferences.

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10. DATA BREACH

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure

or disposal of personal information. You will be notified about data breaches

when OPUN believes you are likely to be at risk or serious harm. For example, a data

breach may be likely to result in serious financial harm or harm to your mental or physical

well-being. In the event that OPUN becomes aware of a security breach which has resulted

or may result in unauthorized access, use or disclosure of personal information OPUN will

promptly investigate the matter and notify the applicable Supervisory Authority not later than

72 hours after having become aware of it, unless the personal data breach is unlikely to

result in a risk to the rights and freedoms of natural persons.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a

Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference

not to have data about your online browsing activities monitored and collected. No uniform

technology standard for recognizing and implementing DNT signals has been finalized. As

such, we do not currently respond to DNT browser signals or any other mechanism that

automatically communicates your choice not to be tracked online. If a standard for online

tracking is adopted that we must follow in the future, we will inform you about that practice

in a revised version of this privacy policy.

12. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding

access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our

users who are California residents to request and obtain from us, once a year and free of

charge, information about categories of personal information (if any) we disclosed to third

parties for direct marketing purposes and the names and addresses of all third parties with

which we shared personal information in the immediately preceding calendar year. If you

are a California resident and would like to make such a request, please submit your request

in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with

the Services or Apps, you have the right to request removal of unwanted data that you

publicly post on the Services or Apps. To request removal of such data, please contact us

using the contact information provided below, and include the email address associated

with your account and a statement that you reside in California. We will make sure the data

is not publicly displayed on the Services or Apps, but please be aware that the data may not

be completely or comprehensively removed from our systems.

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13. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated

by an updated “Revised” date and the updated version will be effective as soon as it is

accessible. If we make material changes to this privacy policy, we may notify you either by

prominently posting a notice of such changes or by directly sending you a notification. We

encourage you to review this privacy policy frequently to be informed of how we are

protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact our Data Protection

Officer (DPO), by email at dpo@opun.ai.

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM

YOU?

Based on the laws of some countries, you may have the right to request

access to the personal information we collect from you, change that

information, or delete it in some circumstances. To review, update, or delete

your personal information, please use Profile feature in the App. If any

questions please email to privacy@opun.ai and we will respond to your

request within 30 days.