Digital Health Program, powered by Independent Pharmacy Cooperative Privacy Policy Effective Date: March 23, 2024

IPC DIGITAL HEALTH respects and is committed to protecting your privacy. Please read this Privacy Policy carefully to understand our privacy policies, and how we collect, use, and disclose information about you that we receive from you and others. This Privacy Policy, together with the IPC DIGITAL HEALTH Terms of Use & End-User License Agreement (“Terms and Conditions”), describes our practices in connection with the information that we collect through software applications (including mobile applications) and websites (including the website currently located at www.myicareplus.com) that we operate and that contain or link to this Privacy Policy (Such applications and websites are collectively referred to as the “Applications”). By downloading, accessing, or using the Applications, or providing information to us in connection with the Applications, you agree to the terms and conditions of this Privacy Policy and, in particular, you consent to the processing of your information in the manner described below. This Privacy Policy does not address the privacy practices of any third party. We are not responsible for the privacy practices of any such third parties, including those to whom we disclose Personal Data in accordance with this Privacy Policy or to whom you submit Personal Data having accessed such third-party applications or website via the Applications. We do not endorse any applications or websites which may be linked via the Applications. We may collect and process Personal Data, Non-Personal Data and Health Information (as defined below) in connection with the Applications.

PERSONAL INFORMATION WE MAY COLLECT AND HOW WE MAY USE OR DISCLOSE IT

“Personal Data” is data that identifies you. We may collect the following Personal Data from you:

• First name, last name, address, email, and phone number

• Height, Weight, Blood Type, Gender, Birthdate and

• “Health Information,” which includes data that relates to your physical or mental health history or conditions, to treatment you have received for those conditions, or to payments for those conditions. For example, we may collect information regarding whether you are pregnant, or information describing medications you are taking or otherwise relating to your health, such as details of allergies, conditions, blood pressure, sleeping patterns, and so on.

We may use Personal Data:

• To send you information regarding the Applications.

• To send you details about changes to our Terms and Conditions and to this Privacy Policy and other policies.

• To send to you marketing communications that we believe may be of interest to you, but we will use Health Information for these purposes only if you opt-in to receiving marketing communications. To personalize your experience on the Applications by presenting products and offers tailored to you if you opt-in to learning about such products and offers.

• To respond to your inquiries/requests.

• For our internal business purposes, such as for data analysis, to identify usage trends, to enhance the Applications and for audits.

• To permit you to send communications to your contacts through the Applications (by providing us with third party contact details you agree that you have that person’s consent to share these details).

• To provide services related to your medical and other healthcare appointments, e.g., to send your appointment reminders; to communicate with you and your healthcare providers. regarding your appointments, and to facilitate payments for the products and services they provide to you.

• As we believe is necessary or appropriate: (a) as required or permitted under applicable law. (b) to respond to requests from public or government authorities; (c) to enforce our Terms and Conditions; and (d) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others.

We may disclose your Personal Data:

To healthcare professionals, as you direct, to assist them in providing healthcare services to you. To identify you to contacts to whom you send messages through the Applications. In the event of any reorganization, merger, sale or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding), to relevant third parties as necessary and with appropriate confidentiality safeguards. As we believe is necessary or appropriate: (a) as required or permitted under applicable law. (b) to respond to requests from public or government authorities; (c) to enforce our Terms and Conditions; and (d) to protect our rights, privacy, safety, or property, or that of our affiliates, you, or others. In addition, it may be possible for you to disclose Personal Data through the Applications on message boards, forums, profile pages and blogs. Please note that any information and materials that you post or disclose through these services may be publicly available. We recommend that you consider carefully whether you wish to share your Health Information or any other Personal Data when you use the Applications. We do not share your Personally Identifiable Information (PII) with third parties. We are not liable for the security and privacy of any information that you choose to print or email from our application. Your personal data is retained as long as your account is active. You may close your account, or the account of a minor, if you are a parent or legal guardian by sending an email to Myicareplus@IPCRx.com with the login email address. We will contact you to verify your identity and subsequently close the account and delete all of the personal data associated with the account. We will notify you by email and by posting on our website at http://www.myicareplus.com prior to making our app inoperable if our application is banned by the distributor (iOS/Google Play), the government, or recalled by us.

NON-PERSONAL INFORMATION WE MAY COLLECT AND HOW WE MAY USE OR DISCLOSE IT

“Non-Personal Data” is data that does not reveal your identity, for example:

• Server log files.
• Information collected through cookies and other technologies.

• Demographic information.

• Health Information and other Personal Data that has been de-identified and can no longer identify you; and

• Browser information.

We may collect Non-Personal Data in several ways, for example:

• Through the device you use to access the Applications: e.g., your operating system name and version, device manufacturer, device model and identifier etc. We may use this data to analyze how the Applications are being used.

• Using cookies: Cookies are small text files which are placed on the device on which you are using the Applications. We use cookies to better serve you with more tailored information and facilitate your ongoing access to and use of the Applications, as well as for online tracking purposes. You can disable cookies via your browser settings, however, this may mean that some of the features of the Applications are no longer available to you. To learn more about cookies, please visit https://allaboutcookies.org/.

Through server log files: An Internet Protocol address (“IP Address”) is a numerical labelassigned to the device that you are using by your Internet Service Provider. Your IP Address is identified and logged in our server log files whenever you use the Applications, along with the time of the use. We use IP Addresses for purposes such as helping to calculate usage levels of the Applications.

• Using web beacons: Web beacons may be used in connection with the Applications to track the actions of users, and to measure the success of our marketing campaigns.
• From you: We may collect information from you which you volunteer e.g., your location. Unless combined with Personal Data, this information does not personally identify you.

Location data: We may establish the physical location of your device, for example, using satellite, cell phone tower or Wi-Fi signals. We may use your device’s physical location to provide you with location-based services and content tailored to you. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content. You may deny us establishing the physical location of your device, however, if you choose to do so, we and/or our marketing partners may not be able to provide you with personalized services and content. We may use and disclose Non-Personal Data for any purpose. In some instances, we may combine Non-Personal Data with Health Information or other Personal Data. If we combine any non-Personal Data with Health Information or other Personal Data, the combined information will be treated by us as Health Information or Personal Data, as long as it is so combined.

HEALTH INFORMATION WE MAY COLLECT AND HOW WE MAY USE IT

“Health Information” is data that relates to your physical or mental health history or conditions, to treatment you have received for those conditions, or to payments for those conditions. We treat Health Information as Personal Data, subject to some special rules, that are described above under the heading “Personal Information We May Collect and How We May Use or Disclose It”.

WHERE WE STORE YOUR INFORMATION

The Personal Data and Non-Personal Data we collect from you is stored in the United States. It may be processed by our employees or by one of our carefully selected, third-party service providers. By using the Applications, you agree to this. We take all reasonable steps to ensure that your Personal Data and Non-Personal Data is processed securely.

ADVERTISERS AND MARKETING

Third parties may display advertisements on the Applications. These third parties may also place a cookie on your device in the course of you viewing their advertisements. If you would like more information about this practice, please click here.

We will not share your Health Information with advertisers or other third parties. We will use your Health Information for marketing purposes only if you have opted-in to receive marketing communications. If you opt-in, you may opt-out at any time by sending us an e-mail at myicareplus@ipcrx.com

JURISDICTION

The Applications are controlled by us from the United States. This Privacy Policy, and our collection and subsequent processing of your Personal Data is governed. by U.S. law (not by the laws of any country, territory, or jurisdiction other than the United States). We do not represent or warrant that the Applications, or any functionality or feature thereof are appropriate or available for use in any particular jurisdiction. Those who choose to access or use the Applications do so on their own initiative and at their own risk. You are responsible for complying with all local laws, rules, and regulations. By using the Applications and submitting any Health Information or other Personal Data, users from outside the United States acknowledge that the Applications are subject to U.S. law and consent to the transfer of Health Information or other Personal Data to the United States, which may provide a different level of data security than in their country of residence. You hereby waive any claims that may arise under your own national laws, other than US law.

GENERAL

The Applications are not directed to individuals under the age of eighteen (18). If you are under the age of 18 you are not permitted to use the Applications. If any provision of this Privacy Policy is found to be void or unenforceable, such provision shall be severed from this Policy and all other provisions shall remain in force. We may change this Privacy Policy at any time. Please take a look at the “Effective Date” at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we make the revised Privacy Policy available through the Applications. Your use of the Applications or the submission of any information in connection with the Applications following such changes means that you accept the revised Privacy Policy. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding the disclosure of Personal Data to third parties for direct marketing purposes. To make such a request, please write to us at myicareplus@ipcrx.com.

If you have any questions in relation to this Privacy Policy, please contact IPC DIGITAL HEALTH at myicareplus@ipcrx.com

If you have any questions, please contact us at myicareplus@ipcrx.com.