Consumer Health Data Privacy Policy

This Consumer Health Data Privacy Policy ("Consumer Health Data Privacy Policy") describes how Nanu Beauty, Inc. d/b/a Mudface (collectively, "Mudface," "we," "us" or "our") processes consumer health data as applicable US state laws may define that term ("Consumer Health Data"), that we collect through our digital or online properties or services that link to this Consumer Health Data Privacy Policy (including as applicable, our website, mobile application, and social media pages) as well as our marketing activities, and other activities described in this Consumer Health Data Privacy Policy (collectively, the "Service"). This Consumer Health Data Privacy Policy applies to the extent required by applicable US state laws.

This Consumer Health Data Privacy Policy supplements our general Privacy Policy. In the event of a conflict between our Privacy Policy and the Consumer Health Data Privacy Policy, the Consumer Health Data Privacy Policy applies to the extent that it is consistent with applicable US state law.

Consumer Health Data we collect

Consumer Health Data you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
• Demographic data, such as your city, state, country of residence, postal code, age, date of birth, and gender.
• Account data, such as the username and password that you may set to establish an online account on the Service, date of birth, biographical details, photograph or pictures, links to your profiles on social networks, preferences, information about your participation in our promotions or surveys, and any other information that you add to your account profile.
• Skincare related data, such as past or current skin conditions and diagnoses, treatments, allergies, medications, images of your skin, and other skincare related information. This may include personal information that you provide directly to us when you complete surveys or upload photos.
• Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
• Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
• Payment data needed to complete transactions, including payment card information or bank account number.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• User-generated content data, such as photos, images, videos, comments, questions, messages, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
• Other data not specifically listed here, which we will use as described in this Consumer Health Data Privacy Policy or as otherwise disclosed at the time of collection.

Consumer Health Data we collect automatically

When you use our services, we collect some information through certain technical tracking technologies that may be considered Consumer Health Data. For example:

• Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Consumer Health Data we obtain from third-party sources

We also obtain the types of Consumer Health Data described above from third parties. These third-party sources may include, for example:

• Our enterprise customers, such as medical spas, skincare brands, and other entities that may provide us with your personal information.
• Co-branding/marketing partners. Partners with whom we offer co-branded services or engage in joint marketing activities.
• Service providers. Third parties that collect or provide Consumer Health Data in connection with work they do on our behalf.
• Public sources. Public sources of Consumer Health Data such as open government databases.

Consumer Health Data we may create, infer or generate

We may create, infer or generate Consumer Health Data from other data we collect, including using automated means to generate information about your likely preferences or other characteristics. We may create aggregated, de-identified, and/or anonymized information from Consumer Health Data by removing certain data components (such as your name, email address, or linkable tracking ID) that makes the data identifiable, or through aggregation, obfuscation or other means. For example, we may de-identify any information and data provided and/or generated in connection with your use of our Services (including without limitation your health-related data), in compliance with applicable law. Except as required or permitted by applicable law, we will not attempt to re-identify any data that has been aggregated, de-identified, and/or anonymized. Subject to applicable law, our use of such aggregated, de-identified, and/or anonymized information is not Consumer Health Data.

How we use your Consumer Health Data

We use Consumer Health Data for purposes described in this Consumer Health Data Privacy Policy or as otherwise disclosed to you. For example, we use Consumer Health Data for the following purposes:

Service delivery and operations

We may use your Consumer Health Data to provide, operate and improve the Service and our business, including:

• providing the Service and enabling security features
• establishing and maintaining your user profile on the Service
• communicating with you about the Service
• providing support for the Service and responding to your requests/questions/feedback

Service personalization

We may use your Consumer Health Data to understand your needs and interests, personalize your experience with the Service and our Service-related communications, and remember your selections and preferences as you navigate webpages.

Insights and development

We may use your Consumer Health Data for insights and development purposes, including to analyze and improve the Service and our business and to develop new products and services.

Direct marketing

We may use your Consumer Health Data to communicate with you about services, upcoming events, and other information.

Promotions and contests

We may use your Consumer Health Data to administer promotions and contests and to communicate with you about any such promotions or contests in which you participate.

Service improvement and analytics

We may use your Consumer Health Data to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and develop new products and services.

Compliance and protection

We may use your Consumer Health Data to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities; protect our, your or others' rights, privacy, safety or property; audit our internal processes for compliance with legal and contractual requirements or our internal policies; enforce the terms and conditions that govern the Service; and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events

We may share certain Consumer Health Data in the context of actual or prospective corporate events.

To create aggregated, de-identified and/or anonymized data

We may create aggregated, de-identified and/or anonymized data from your Consumer Health Data and other individuals whose Consumer Health Data we collect. We make Consumer Health Data into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

How we share your Consumer Health Data

We may "share" (as the applicable law may define that term) Consumer Health Data with your consent or as we determine necessary to complete your transactions, provide the Service to you, or as otherwise permitted or required by law. For example, we may share your Consumer Health Data to:

• Third parties designated by you. We may share your personal information with other third parties where you have instructed us or provided your consent to do so. For example, we may also share personal information, with your medical spa or preferred skincare brand.
• Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Shopify. Shopify may use your payment data in accordance with its privacy policy at https://www.shopify.com/legal/privacy/app-users.
• Legal and law enforcement. We will access, share, and preserve Consumer Health Data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies. We will also share Consumer Health Data if we believe it is necessary to protect our customers and/or the rights or property of ourselves or others.

For more information on how we may otherwise disclose your Consumer Health Data, please view the How we may share your personal information section in our Privacy Policy.

Your Consumer Health Data choices

You may have certain rights to your Consumer Health Data under applicable law. Any of the rights discussed below may be subject to certain limitations (for example, a monetary charge). If you wish to exercise these rights, please email us at hello@mudface.ai.

• Withdraw consent. To the extent we rely upon your consent for either our collection or sharing of your Consumer Health Data, you have the right to withdraw such consent from any future collection or sharing.
• Access and confirm. You have the right to ask us to confirm whether we have collected, shared or sold your Consumer Health Data. Further, you have the right to access (in other words, request a copy of) the Consumer Health Data that we have collected, shared or sold. You also have a right to access a list of all "third parties" (as applicable law may define that term) and affiliates with whom we have shared or sold your Consumer Health Data and receive certain corresponding information.
• Correction. You have the right to ask us to correct inaccuracies in your Consumer Health Data.
• Deletion. You have the right to ask us to delete your Consumer Health Data.
• Appeal. You have the right to appeal our denying a right you have attempted to exercise. We will provide details on how to appeal our denial in connection with such action.

To exercise your rights above and make a Consumer Health Data rights request, please email us at hello@mudface.ai. We may need to verify your identity in order to process your request. To confirm your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

Declining to provide information. We need to collect Consumer Health Data to provide certain services. If you do not provide the information we identify as required or mandatory or if you request that any required Consumer Health Data be deleted or withdraw your consent for future collection or sharing of any required Consumer Health Data, we may not be able to provide those services.

Changes to this Consumer Health Data Privacy Policy

We reserve the right to modify this Consumer Health Data Privacy Policy at any time. If we make material changes to this Consumer Health Data Privacy Policy, we will notify you by updating the date of this Consumer Health Data Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Consumer Health Data Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Consumer Health Data Privacy Policy indicates your acknowledging that the modified Consumer Health Data Privacy Policy applies to your interactions with the Service and our business.

How to contact us

If you have questions about our Consumer Health Data practices or if you would like to exercise any privacy-related right that may be available to you, please contact us via the method listed below.

• Email: hello@mudface.ai