Privacy Notice

1. Introduction

CLYNE HEALTH™ LLC ("We," "CLYNE HEALTH™," or the "Company") takes the privacy of all individuals very seriously. The privacy and security of your Personal Information is important to us, and this Notice is intended to clearly explain how we collect, use, share, and safeguard your information.

When you submit information to us via our website, clynehealth.com (or the "Site"), that information is managed and processed in accordance with this Privacy Notice ("Privacy Notice") and the CLYNE HEALTH™ Terms of Use.

This Notice explains:

• The information we collect about our customers through the Site;
• How we collect, use, store, and share such information;
• Your rights concerning your information; and
• The obligation of all CLYNE HEALTH™ personnel to protect Personal Information.

This Notice does not apply to information collected through other means such as by telephone, via online services that do not link to this Notice, or in person, although that information may be protected by other privacy notices or policies.

2. Definitions

3. Binding Agreement

Please read this Notice carefully. By accessing or using the Site or the Services, you agree to us Processing your Personal Information as described in this Notice. This Notice may change from time to time. Your continued use of the Site or the Services after we make changes is deemed to be acceptance of those changes, so please check this Notice periodically for updates.

4. Personal Information We May Collect

We may collect Personal Information and Sensitive Personal Information, including Consumer Health Data, about individuals. Any Consumer Health Data we collect about you may also be subject to additional protections under your state's laws. We will only use, process and disclose that information, and will instruct any third-party who processes that information on our behalf, to use such Consumer Health Data in accordance with applicable laws and regulations in your state of residence.

Personal Information and Sensitive Personal Information Directly Collected from You

You may provide us Personal Information in the following ways:

• When you request Services through the Site.
• When you use the Site to communicate with us.
• When you report a problem with our Site.
• When you respond to a survey on our Site.

You may also provide Personal Information and Sensitive Personal Information through the third party Portal available to access on the Site.

If you contact us by e-mail or via a contact form, we save and process your inquiry including all the Personal Information derived from it (e.g., name, inquiry) for the purpose of processing your request. We may pass this data on to third parties if this is necessary for the fulfillment of your inquiry. We store the Personal Information you send us with your contact inquiry until you request its erasure, it is no longer needed, or you otherwise exercise your data protection rights. Mandatory legal provisions — especially statutory retention periods — remain unaffected.

Personal Information Collected Automatically

We may also collect Personal Information, Sensitive Personal Information, and Consumer Health Data automatically as you interact with our Site. This may be done through automatic data collection technologies to collect information about your equipment, browsing actions, and usage patterns.

The information we collect automatically may be associated with Personal Information we collect in other ways or receive from third parties. This can help us improve our Site and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Site according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Site.

Personal Information We Collect from Third Parties

We use information from third parties to supplement or update the information you provide to us or that we collect from you automatically. Examples of other Personal Information we may receive from third parties are:

• Your name, email address, and phone number;
• Profile information, comments, and similar information provided to or on social networks and other forums that connect to us;
• Interests, demographic data and purchasing behavior; and
• Personal Information collected from you offline or through other channels, such as information you provide to us over the phone.

Personal Information Collected Automatically Through Social Media Sites

Meta Platforms: Facebook / Instagram. If you interact with Meta platforms or services such as Facebook or Instagram through our Site, Meta may process your Personal Information when you use those sites. When a user uses Meta products — including visiting our Facebook or Instagram pages — Meta processes Personal Information even from users who do not use any Meta platforms or services.

You can find out what Personal Information is processed, for what purposes and on what legal basis in Meta's Privacy Center, which applies to all Meta products. For more information on Meta's use of Personal Information across its platforms and services, see their posted privacy policies, available at https://www.facebook.com/about/privacy.

Personal Information We Do Not Collect

We do not collect biometric information or sensory data on the Site. We do not collect non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99)).

Collection of Non-Identifiable Information

We also collect Non-Identifiable Information, such as your preferred language, zip code, area code, referrer URL, and the time zone where the Site is accessed. We use this information to better understand user behavior and improve our Services.

Your Responsibilities With Regard to Personal Information We Collect

If you provide us any Personal Information about another individual, you are responsible for making sure that you have the authority to do so and to allow us to use their Personal Information in accordance with this Notice.

You are responsible for ensuring the accuracy of Personal Information you provide to us. Inaccurate information may affect your use of the Services as well as our ability to contact you. You are not required to provide Personal Information to us, but if you chose not to do so, we may not be able to provide you with our Services or respond to questions you may have.

5. How We Use Your Personal Information and Sensitive Personal Information (including Consumer Health Data)

Consistent with applicable law and the choices and controls that you select, we may use your Personal Information and Sensitive Personal Information as described in this Notice. Your Personal Information also may be used as disclosed in our business partner's Privacy Policy, found at MD Integrations Privacy Policy.

Some examples of how we may use your information, including Personal Information, are:

• Presenting our Site to you;
• Providing you with the Services you request, view, or engage with;
• Allowing you participate in interactive features on our Site;
• Allowing you access the Portal, including connecting with Health Care Professionals through the Portal;
• Allowing you to connect with our Pharmacy Network;
• Providing you with updates about CLYNE HEALTH™'s latest happenings and upcoming events;
• Providing you with information about CLYNE HEALTH™, our Services and our business activities;
• Sending you our newsletters;
• For customer service and customer support purposes;
• Sending you information or requesting feedback about features on our Site or about changes to our policies or Site;
• Sending you offers and promotions for our products and services or third-party products and services;
• Personalizing content and experiences presented to you;
• Operating, understanding, optimizing, developing, or improving our Site, products, services and operations;
• Detecting, investigating and preventing activities that may violate our policies, pose safety issues, or are fraudulent or illegal;
• Testing, research, analysis, and product development;
• Fulfilling our obligations or enforcing our rights arising from any contracts entered into between you and us;
• To prevent transactional fraud;
• Responding to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• Evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CLYNE HEALTH™;
• Maintaining and improving the safety, security, and integrity of our Site and Services;
• Supporting our general business operations;
• For any other purpose with your consent; and
• For any other lawful purpose that is our legitimate interest and not overridden by your data privacy rights.

Categories of Personal Information We Collect and Share

Your Personal Information May Be Shared With:

• Service Providers — Vendors working on behalf of CLYNE HEALTH™ to support business operations, such as payment processors, customer support tools, analytics providers, cloud storage providers, fraud prevention services, and website hosting platforms.
• Advertising & Marketing Partners — Third-party advertising networks and platforms (e.g., social media platforms, email marketing providers, and analytics tools) used for targeted advertising and audience segmentation, with consent where required.
• Affiliates and Business Partners — Entities within the CLYNE HEALTH™ corporate family or trusted business partners engaged in joint marketing, research, or product development.
• Regulatory and Legal Entities — Government agencies, law enforcement, or regulatory bodies where required for compliance with legal obligations or public safety concerns.
• Corporate Transactions — In the event of a merger, acquisition, or sale of company assets, data may be disclosed as part of due diligence and business transition processes.

Sensitive Personal Information Shared with Third Parties

We collaborate with Health Care Professionals and our Pharmacy Network to facilitate the delivery of telehealth services. You must provide affirmative consent prior to the input and any subsequent sharing of Sensitive Personal Information/Consumer Health Data with third parties. In connection with our provision of the Services, your Personal Information and Sensitive Personal Information may be shared with Health Care Professionals and our Pharmacy Network.

Personal Information Shared with our Payment Processor

Our Site processes payments through Stripe, a PCI-DSS Level 1 certified payment processor. Card data is collected and stored by Stripe directly and is never seen or stored by CLYNE HEALTH, LLC. For more information about Stripe's privacy practices, see https://stripe.com/privacy.

6. Sharing or Selling Your Personal Information and Targeted Advertising

CLYNE HEALTH™ strives to collect, process and share only the Personal Information we need for our business operations. We may share or sell your Personal Information. We also engage in targeted advertising, either directly or indirectly.

Some privacy laws define the sale of data to include sharing Personal Information for a business purpose. Where this may be the case, we enter into contracts requiring those third parties to keep your Personal Information confidential and to use your Personal Information only for the permitted purpose.

Sharing Personal Information

We may share your Personal Information in the following situations:

• To fulfill the purpose for which you provided it;
• To allow you access to the Portal, Health Care Professionals, and the Pharmacy Network;
• To our affiliates (such as other companies that own us, that we own, or that share common ownership with us);
• When you elect to allow us to share your Personal Information with selected companies so they can send you offers and promotions;
• When you direct us to share your Personal Information with another company to fulfill your request;
• When we cooperate with other businesses to offer co-branded products or services to you;
• When companies perform services on our behalf, like marketing and advertising, and customer service;
• When requested by law enforcement agencies, regulators, and courts in response to a court order, subpoena, or regulatory requirement;
• To combat fraud or criminal activity, and to protect our rights, users, and business partners;
• When we share your Personal Information with third parties as part of selling the business;
• When it is necessary to respond to a public health emergency, or in an emergency, to protect the safety of your health and property;
• For any other purpose we disclosed when collecting the information; and
• With your consent.

Personal Information Shared With Third Parties

This Site may contain content from third parties. This always requires that the parties offering this content have access to the user's IP address. Without the IP address, they cannot provide the contents to the browser of the individual user. CLYNE HEALTH™ makes every effort to ensure it only uses content from providers who use the IP address exclusively to provide the content. However, we have no control over whether the third-party provider saves the IP address, e.g. for statistical purposes.

Please be aware that we are not responsible for the content or privacy practices of other third party websites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects Personal Information.

Conversion Measurement with Meta Pixel

We use the Meta Pixel with your consent. It enables us to track users' actions across numerous websites after they have seen or clicked a Meta ad. In this way, we can assess the effectiveness of Meta ads for statistical and market-research purposes. The data is anonymous for us, so we do not see the Personal Information of individual users. However, data is also stored and processed by Meta. Meta can link this data to your Facebook or Instagram account or its other platforms and services and use it for its own advertising purposes.

Aggregated or Non-Identifying Information

We may disclose Aggregated Information or Non-Identifying Information, for any reason without restriction.

7. Your Personal Information / Your Choices

You have the ability to exercise certain controls and choices regarding our collection, use and sharing of your Personal Information. In accordance with the laws that may apply to you, your controls and choices may include:

The Right to Know / Right to Access

You have the right to know what Personal Information we collect about you. Upon receipt of your request, and confirmation of your identity, we will disclose to you:

• The categories and specific pieces of Personal Information that we have collected about you in the past 12 months,
• The sources from which we have collected that information,
• Our business or commercial purpose for collecting such information,
• The categories and specific pieces of Personal Information that we have disclosed to third parties for a business purpose during the past twelve months,
• The categories and specific pieces of Personal Information that we have sold to third parties during the past twelve months, and
• The third parties to whom we have disclosed or sold such Personal Information.

In most cases, you may request this information up to two times each year.

The Right to Data Portability

You have the right to request a copy of the Personal Information we have about you. We will provide it in a format that we select, that you can reasonably transfer to a third-party.

The Right to Correct / Right to Rectification

You have the right to request that we correct any inaccurate Personal Information that we may maintain about you, subject to applicable legal exceptions.

The Right to Delete / Right to Erasure

You have the right to request that we delete your Personal Information, subject to applicable legal exceptions. If you submit this request, we will review it and attempt to confirm your identity. Once we confirm your identity, and assuming no exception applies that requires or allows us to retain your Personal Information, we will delete it and direct our service providers to do the same.

We may deny your deletion request, for example, if retaining the Personal Information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with any international, national, federal, state, or local laws, rules or regulations.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation or other lawful uses.

Right to Opt-Out of Promotional Offers

If you do not wish to have your email address or other contact information used by CLYNE HEALTH™ to promote our products or services, you can opt-out of non-essential email or text communication by contacting us. If we have sent you a promotional email or text, you may send us a return email or text asking to be omitted from future distributions.

Right to Opt Out of Targeted Advertising and Profiling

CLYNE HEALTH™ allows third parties to receive information such as cookies, IP address, device identifiers, hashed contact information, browsing behavior, and/or other activity to enable the delivery of targeted advertising to you. These activities may qualify as the "sale" of personal information or "sharing" or processing of personal information for targeted advertising, as defined in applicable law.

Right to Opt Out of Sale or Sharing of Personal Information

You may have the right to "opt out" of the "sale" or "sharing" of your Personal Information to or with "third parties" (as those terms are defined by applicable law). You may also use an authorized agent to submit a request to opt out on your behalf if you provide the authorized agent signed written permission to do so.

To opt-out of the sale or sharing of your Personal Information, you or your authorized representative can contact us or enable online, where available, a universal tool that automatically communicates your opt-out preferences, such as the Global Privacy Control ("GPC"). We will process the GPC signal as a request to opt out.

Right to Limit Use of Your Sensitive Personal Information

You may have the right to direct that we limit the use of your Sensitive Personal Information to uses that are necessary for us to perform the services or provide the goods you request from us or necessary for our business purposes.

8. Exercising Your Rights

To exercise any of your data protection rights, you may submit a request by:

When submitting a request, you must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of such individual.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

9. Verification of Requests

Only you, or someone legally authorized to act on your behalf, may make a request regarding your Personal Information. A parent or guardian with legal custody may make a request on behalf of a minor child. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with applicable law. Before completing requests from authorized agents, we may contact you directly to confirm you have given your permission and/or to verify your identity.

We cannot, and will not, respond to your request or provide you with Personal Information if we cannot verify your identity or your authority to make the request and confirm the Personal Information relates to you.

You are not required to submit a request through your account with us, but we do consider requests through your password protected account to be verified, without further requirements, as long as the request is for information associated with that account.

We will not use Personal Information provided in the request for any purpose other than to verify the requestor's identity or authority to make the request.

Verifying an Authorized Agent

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where you provide sufficient evidence that the requestor is an authorized agent with written permission to act on your behalf and you successfully verify your own identity with us.

• For requests to know and delete by an Authorized Agent: (1) providing a valid power of attorney under the laws of the subject individual's state of residence; or (2) providing sufficient evidence to show that the subject individual has (i) provided the Authorized Agent signed permission to act on their behalf, (ii) verified their own identity directly with us, and (iii) directly confirmed with us that they have provided the Authorized Agent permission to submit the request on their behalf; and
• For requests to opt-out: submitting a signed permission demonstrating that the Authorized Agent has been authorized by the subject consumer to act on their behalf.

10. Responding to Your Request

We endeavor to confirm receipt of all requests within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email help@clynehealth.com to ensure we received your request.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

The information in our response will cover the 12-month period preceding our receipt of your request. If we cannot comply with your request or any portion of your request, our response will explain the reasons we cannot comply. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

11. Appeal Process

If we refuse to take action upon your request to exercise any of your data privacy rights, you may appeal our decision within a reasonable period after you receive notice of our decision. To initiate an appeal, please contact us and inform us that you would like to appeal our decision. Within forty-five (45) days after we receive your appeal, we will inform you of any action taken or not taken in response to your appeal, and we will provide you with a written explanation of the reasons in support of our response.

If your appeal is denied, we will also provide you with an online mechanism, if available, or other method through which you may contact your state attorney general to submit a complaint, should you wish to do so.

12. Non-Discrimination for Exercising Your Rights

We will not discriminate against you for exercising any of your data protection rights, and specifically we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer certain financial incentives permitted by applicable data protection laws that can result in different prices, rates, or quality levels. Any permitted financial incentive we offer will reasonably relate to your Personal Information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Please be aware that if you do not allow us to collect Personal Information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences.

13. Surveys

From time-to-time our Site may request Personal Information via surveys. Participation in these surveys is completely voluntary, and you may choose whether to participate and therefore disclose this information. Personal Information requested may include contact information (such as name and address), and demographic information (such as zip code, age level). Survey information will be used for purposes of monitoring or improving the use and satisfaction of this Site.

14. Children's Privacy Notice and Practices

Our Site is not intended for individuals under 18 years of age. No one under age 18 may provide any Personal Information to or on the Site. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on this Site, or through any of its features, use any of the interactive or public comment features of this Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use.

If we learn we have collected or received Personal Information from an individual under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about an individual under 16, please contact us at help@clynehealth.com.

15. Data Security, Retention Policies and Practices

The security, integrity, and confidentiality of your Personal Information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect guest Personal Information from unauthorized access, disclosure, use, and modification. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.

The safety and security of your Personal Information also depends on you. If you maintain an account with CLYNE HEALTH™, you are responsible for keeping your username and password confidential. We ask you not to share your password with anyone.

We will retain your Personal Information for the length of time needed to fulfill the purposes outlined in this Notice unless a longer retention period is required or permitted by law.

16. Cookie Notice (Online Tracking Technologies)

We may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Site. These technologies allow us to understand who has interacted with us and also help us to operate our Site and Services more efficiently.

Types of Cookies

Categories of Cookies

What Cookies Do We Use?

Like many websites, we use cookies on our Site. CLYNE HEALTH™ uses First Party, Third Party, Strictly Necessary, and Analytics/Performance cookies, which may include all of the "Types of Cookies" outlined above.

For specific cookie categories and toggles, see our cookie consent banner (first-visit) or the cookie-preferences section of this Privacy Policy above. You can change your cookie preferences at any time by clearing your browser cookies for clynehealth.com and reloading the site.

We value your privacy and the information you consent to share in relation to our SMS marketing service. We use this information to send you text notifications (for your order, including abandoned checkout reminders), text marketing offers, and transactional texts, including requests for reviews from us. Opt-in data and consent for text messaging will not be shared with any third parties except for messaging partners, for the purpose of enabling and operating our text messaging program.

Why Do We Use Cookies?

We use cookies to learn how you interact with our Site and to power and improve our Site and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services. We may also permit third parties and services providers to use cookies on our Site to better tailor the services, products and advertising on our Site and other websites.

How Can You Control Cookies?

Our website recognizes the Global Privacy Control ("GPC") signal, which enables you to opt-out of certain uses or disclosures of your information. If you notify us of your preference through GPC, we will treat such signal as a valid request to opt out of sharing/targeted advertising for the associated browser or device. To learn more about Global Privacy Control, visit https://globalprivacycontrol.org/.

Most browsers automatically accept cookies by default, but you can choose to set your browser to remove or reject cookies through your browser controls. You can also manually delete individual or all of the cookies on your computer by following your browser's help file directions. Please keep in mind that removing or blocking cookies can negatively impact your user experience and may cause some of the Services to work incorrectly or no longer be available.

Users can visit Google Analytics Opt-out Browser Add-on for information on how to opt-out of Google Analytics.

You may also visit https://allaboutcookies.org/ or https://www.aboutcookies.org/ for details on how to delete, reject, or block cookies and for further information on cookies generally.

Some web browsers may transmit "do-not-track" signals to Sites with which the user communicates. These are different from Global Privacy Controls. The Site does not monitor or identify "do not track signals," and such signals will not impact the operation of this Site.

We do not control third parties' collection or use of your Personal Information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your Personal Information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on NAI's website.

17. Jurisdictional Privacy Rights

United States

California (CCPA / CPRA)

California residents have the following rights, in addition to those set out in the "Your Personal Information / Your Choices" section. These rights are governed by the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), which took effect January 1, 2023.

Shine the Light Act. If you are a California resident, California Civil Code § 1798.83 permits you to request information regarding the disclosure of your Personal Information by CLYNE HEALTH, LLC to third parties for the third parties' direct marketing purposes. Pursuant to California Civil Code Section 1798.83(c)(2), we do not share your Personal Information with third parties for those parties' direct marketing use, unless you elect that we do so.

Sensitive Personal Information (CPRA). The CPRA created a new category of "Sensitive Personal Information" that includes health information. California residents have the right to limit our use and disclosure of Sensitive Personal Information to purposes reasonably necessary to provide the services you requested. To exercise this right, contact us as described in the "Exercising Your Rights" section.

Nevada

Nevada provides its residents with a limited right to opt-out of certain Personal Information sales. Residents who wish to exercise this sale opt-out rights may do so as provided in the "Exercising Your Rights" section. However, please know we do not currently sell data triggering that statute's opt-out requirements.

Other U.S. State Data Privacy Laws

The following states have passed and/or enacted data privacy laws that currently allow or will allow the rights discussed in "Your Personal Information / Your Choices": California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. This list does not purport to be all-inclusive, as the laws in the area of data privacy are constantly evolving.

18. Business Associate Agreements (HIPAA)

CLYNE HEALTH, LLC maintains Business Associate Agreements (BAAs) with all third-party service providers who access Protected Health Information (PHI) on our behalf, as required by the Health Insurance Portability and Accountability Act (HIPAA) and its implementing regulations. These BAAs contractually require our partners — including our telehealth platform, e-prescribing vendors, pharmacy partners, cloud infrastructure providers, and communication tooling — to safeguard PHI to at least the same standards we apply ourselves.

We use HIPAA-compliant infrastructure, encrypt PHI in transit and at rest, and limit access to authorized personnel on a minimum-necessary basis. PHI is never used to train AI models and is never sold to third parties for any purpose.

19. Updates to this Privacy Notice

From time to time, we may change this Notice to accommodate new technologies, business or industry practices, regulatory requirements or for other purposes. Any changes to this Notice will be posted to this Site page. The date the Notice was last revised is identified at the top of the page.

20. Contact Us & Privacy Officer

If you have a comment, question, or formal privacy request regarding this Notice or our handling of your information, please contact our Privacy Officer at: