Admin Console Privacy Policy

Effective as of September 15, 2022

This privacy policy (the “Privacy Policy”) applies to the Shield web dashboard (the “Website”), owned and operated by Concentrix Catalyst PTY LTD (“Catalyst,” “we,” “us,” or “our”). We have created this Privacy Policy to tell you what information the Website collects from those who use the Shield mobile application (the “App”) and what information we collect from your use of the Website. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. Capitalized terms not defined in this Privacy Policy will have the meaning set forth in our Terms of Use. By visiting and/or using our Website, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use. We encourage you to read the Privacy Policy, and to use the information it contains to help you make informed decisions.

1. Information You Receive or That We Collect.

In the course of operating the Website, you will be able to access and/or receive the following types of information of users of the App. Catalyst will also collect and/or receive the following types of information. You authorize us to collect and/or receive such information.

(a) Personal Information. You only receive or collect information from the App through the Website in an anonymized and aggregate form. While you are using the Website, we only receive or collect information that identifies you personally if you choose to provide such personally identifiable information to us via email or other means. When you become a user of the Website or contact us, you will be required to provide us with personal information about yourself (collectively, the “Personal Information”). Such Personal Information may include your name, e-mail address, physical address, and phone number. We do not collect any Personal Information from you when you use the Website unless you provide us with the Personal Information voluntarily.
(b) Wellness Data. Identifiable wellness data is not captured by Catalyst. Users of the App, by using the App in conjunction with the Apple Watch, will have wellness data captured, such as resting heart rate, heart rate variability, skin temperature, blood oxygen saturation level and acceleration; metadata on workouts and sleep; the type of physical activity the App user engages in and the duration of the activity; general health, personal, and professional behavior data that the App user may choose to submit, such as mood rating scales and working hours; data reflecting strain and recovery; physiological profile, including birthday, gender identity, weight, height, fitness/athlete level (e.g., professional or recreational); and details the App user chooses to submit about diet, medications, and female health tracking. You will receive this information anonymized and in aggregate form from the users of the App.
(c) Geolocational Information. Certain features and functionalities of the Website are based on your location. In order to provide these features and functionalities while you are using your mobile device, we may, with your consent, automatically collect geolocational information from your mobile device or wireless carrier and/or certain third-party service providers (collectively, “Geolocational Information”). Collection of such Geolocational Information occurs only when the Website is running on your device. You may decline to allow us to collect such Geolocational Information, in which case we will not be able to provide certain features or functionalities to you.
(d) Other Information. In addition to the Personal Information and Geolocational Information, we may automatically collect or receive additional information regarding you and your use of the Website; and information regarding your computer and mobile devices used to access the Website (collectively, the “Other Information”). Such Other Information may include:
- (i) From You. Additional information about yourself that you voluntarily provide to us.
- (ii) From Your Activity. We may collect or receive information regarding:
  - (A) IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device;
  - (B) browser type and language;
  - (C) referring and exit pages and URLs;
  - (D) date and time; and
  - (E) details regarding your activity on the Website, such as search queries and other performance and usage data.
- (iii) About Your Mobile Device. We may collect or receive information regarding:
  - (A) type of mobile device;
  - (B) advertising Identifier (“IDFA” or “AdID”);
  - (C) operating system and version;
  - (D) carrier; and
  - (E) network type (WiFi, 3G, 4G, LTE).
- (iiii) From Cookies. We may use both session cookies, which expire once you close the Website, and persistent cookies, which stay on your mobile device until you delete them and other technologies to help us collect data and to enhance your experience with the Website. Cookies are small text files an Website can use to recognize a repeat visitor to the Website. We may use cookies for various purposes, including to:
  - (A) type of mobile device;
  - (B) personalize your experience; and
  - (C) analyze which portions of the Website are visited and used most frequently;
  If you do not want us to deploy cookies in the Website, you can opt out by setting your device to reject cookies. You can still use the Website if you choose to disable cookies, although your ability to use some of the features may be affected.

2. How Information is Used and Shared.

(a) We do not sell your Information (defined below) to third parties.
(b) You authorize us to use the Personal Information, Geolocational Information, and the Other Information (collectively, the “Information”) to:
- (i) provide and improve our Website;
- (ii) provide our services;
- (iii) solicit your feedback; and
- (iiii) inform you about our products and services.
(c) In an ongoing effort to better understand our users, the Website, and our products and services, we may analyze certain Information in anonymized and aggregate form to operate, maintain, manage, and improve the Website and/or such products and services. This aggregate information does not identify you personally. We may share and/or license this aggregate data to our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe the Website and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.
(d) We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.
(e) As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
(f) To the extent permitted by law, we may also disclose the Information:
- (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or
- (ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.

3. Accessing and Modifying Information and Communication Preferences.

If you have provided us any Personal Information, you may access, remove, review, and/or make changes to the same by contacting us as set forth below. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our databases. You cannot opt out of receiving transactional e-mails related to the Website (e.g., requests for support).

4. How We Protect Your Information.

We have appropriate security measures in place to prevent your Personal Information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

5. Important Notices to Non-U.S. Residents.

The Website and its servers may be operated in the United States. If you are located outside of the United States, please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the Website, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

6. Children.

We do not knowingly collect or solicit Personal Data from anyone under the age of 13.

7. Changes to This Privacy Policy.

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted on the Website. By accessing the Website after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

8. How to Contact Us.

If you have questions about this Privacy Policy, please e-mail us at DPO@Concentrix.com with “Privacy Policy” in the subject line or mail us at the following address: 39899 Balentine Dr. Ste 235, Newark, CA 94560

9. Transferring Your Personal Information Out of the European Economic Area.

Applicable only if you reside within the European Economic Area: To deliver services to you, it is sometimes necessary for us to share your Personal Information and Geolocational Information outside the European Economic Area (EEA), e.g.:

With our offices outside the EEA;
With service providers located outside the EEA; or
If you are based outside the EEA.

These transfers are subject to special rules under European and UK data protection law.

These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.

If you would like further information, please contact us (see “How To Contact Us” above).

10. Your Rights Under the GDPR.

For further information on each of your rights, including the circumstances in which they apply, including filing a complaint, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation, or by contacting the Concentrix Data Protection Office at DPO@Concentrix.com.

11. Your Rights Under the CCPA.

If you are a California resident, you may ask businesses to disclose what personal information they have about you and what they do with that information. You also have the right to be notified, before or at the point businesses collect your personal information, of the types of personal information they are collecting and what they may do with that information. Generally, businesses cannot discriminate against you for exercising your rights under the CCPA. Businesses cannot make you waive these rights, and any contract provision that says you waive these rights is unenforceable. Please contact the Concentrix Data Protection Office for any questions, complaints or request pertaining to your rights at DPO@Concentrix.com.