PRIVACY POLICY – BODIOMETER

LAST UPDATED: AUGUST 11, 2020

At AnimationLeader Technology Inc. ("Bodiometer") we are committed to maintaining the privacy, confidentiality and security of your personal information. This policy (“Privacy Policy”) describes the personal information that Bodiometer, the bodiometer websites, the bodiometer desktop applications, and the bodiometer mobile applications (the “Bodiometer App”) collect from or about you, why we collect personal information, how we use the information and to whom we disclose that information when you use the Bodiometer App. This Privacy Policy applies to the identifiable information of all organizations and individuals using the BodiometerApp (and its related services).

BY USING THE BODIOMETER APP (AND ITS RELATED SERVICES), YOU ARE CONSENTING TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY AND, WHERE YOUR INTERACT WITH THE PERSONAL INFORMATION OF OTHERS IN THE BODIOMETER APP (SUCH AS THE PERSONAL INFORMATION OF A FAMILY MEMBER OR PATIENT), YOU REPRESENT THAT YOU HAVE THEIR CONSENT TO DO SO. IF YOU DO NOT CONSENT OR DO NOT HAVE SUCH CONSENT, PLEASE DO NOT USE THE BODIOMETER APP (OR ANY OF ITS RELATED SERVICES).

What is Personal Information?

For the purposes of this Privacy Policy, personal information is any information about an identifiable individual, other than the person's business title or business contact information when used or disclosed for the purpose of business communications.

What Personal Information do we collect?

We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:

❏ personal contact and identification information, such as your name, address, telephone number, date of birth, gender, e-mail address, and unique lifetime identifier number (ULI);

❏ business contact and identification information, including name, address, telephone number, e-mail address, and unique professional and/or organizational identifier;

❏ information concerning the use, operation and development of the Bodiometer App (and any of its related services) such as your photo and biomechanics measurements; and

❏ relationship information, including information related to your agreements, consents, preferences, feed-back and information requested by or provided to you.

As a general rule, Bodiometer collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).

From time to time, we may utilize the services of third parties in our business and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.

Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.

Why do we collect Personal Information?

Bodiometer collects personal information to enable us to manage, maintain, and develop our business and operations, including:

❏ to operate the Bodiometer App (or any of its related services), including the support, maintenance and development of same;

❏ to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the products and services that havebeen requested;

❏ to be able to review the products and services that we provide to you so that we may understand your requirements for our products and services and so that we may work to improve our products and services;

❏ to be able to review the products and services that we obtain from you so that we may work with you and so that you may understand our requirements for such products and services;

❏ to be able to comply with your requests (for example, if you prefer to becontacted at a business or personal email address or telephone number and advise us of your preference, we will use this information to contact you through those means);

❏ to protect us against error, fraud, and inappropriate access;

❏ to enable us to comply with applicable law or regulatory requirements; and

❏ any other reasonable purpose to which you consent.

How does Bodiometer App use Personal Information?

You may use the Bodiometer App (or any of its related services) to exchange your data with your practitioner (including, their office or clinic), other practitioners or your patient. You are responsible for and control who you authorize to access the personal information managed by you. Bodiometer is not a health care provider.

The Bodiometer App (and its related services) enables secure data transfer between patients and their practitioners and other practitioners. These practitioners are regulated and licensed by various public or regulatory bodies. Should you have any questions about your practitioner please direct such questions directly to them or the applicable regulatory body. For example, the relationship between you and your chiropractor is a practitioner-patient relationship. Bodiometer is not a party to that relationship. Each practitioner is independent of Bodiometer and is solely responsible for any services they provide to you.

A practitioner may establish a Bodiometer account for their office or clinic; this account may be accessible by such practitioner, the other practitioners who are part of such office or clinic, and their staff. When you communicate with such an account, you are consenting to your information being accessible by each of them.

We use the information that we collect in a variety of ways in order to provide better service and operate our business, including improving Smart Features/Artificial Intelligence. When reviewing your case, practitioners have the opportunity to utilize algorithms powered by artificial intelligence to support their clinical decisions for an enhanced level of care. In order for Bodiometer App’s algorithms to become “smarter” over time to fulfill this mission of improved care, they must be continuously trained. To support this intrinsic need, every time a practitioner uses one of our artificial intelligence-powered algorithms, the Bodiometer App has the opportunity to “learn” and become better for you and other patients around the world. Any images and data used for these algorithms have been de-identified, which means that all identifiable information such as name, date of birth and email have been removed. You acknowledge and agree that Bodiometer owns access to use your de-identified information to enhance Bodiometer App’s features such as smart features that may be used by practitioners.

You acknowledge and agree that Bodiometer owns access to use your de-identified information to enhance Bodiometer App’s features such as smart features that may be used by practitioners.You acknowledge and agree that access to and use of the Bodiometer App (and any of its related services) is provided via the Internet. Information stored in the Bodiometer App is stored in Canada but may be accessible in other jurisdictions.

Our systems may record certain information related to your use of the Bodiometer App, by using various types of technology, including cookies, “clear gifs” or “web beacons.” This information may include the IP address or other device address or ID, web browser and/or device type, your photo and biomechanics measurements entered into the Bodiometer App, the web pages or sites visited just before or just after using the Bodiometer App, the pages or other content you view or interact with on the Bodiometer App, the dates and times of the visit, access, or use of the Bodiometer App and what country you are from. You may limit the collection of certain information by the Bodiometer App, for instance by disabling the cookies using your browser options. Please be aware that by doing so it may prevent you from using specific features on the Bodiometer App, such as maintaining an online account. We use the collected information on the Bodiometer App through cookies and similar technologies to: (i) monitor our system performance (such as number of visits, average time spent, screen usage), to enable us to operate and manage our systems and services (ii) personalize the Bodiometer App, such as remembering your information so that you will not have to re-enter it during a visit or on subsequent visits; (iii) better understand our user community so that we can work to continually upgrade our systems and services (iv) provide customized advertisements, content, and information; (v) monitor and analyze the effectiveness of the Bodiometer App and third party marketing activities; (vi) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (vii) track your entries, submissions, and status in any promotions or other activities on the Bodiometer App (or any of its related services).

THERE ARE RESTRICTIONS ON THE SERVICES THAT CAN BE PROVIDED THROUGH THE BODIOMETER APP. YOU MUST NOT USE THE BODIOMETER APP FOR EMERGENCY MEDICAL NEEDS. IF YOU BELIEVE THAT YOU ARE DEALING WITH A MEDICAL EMERGENCY, CALL 911 (OR YOUR LOCAL EMERGENCY NUMBER) IMMEDIATELY OR ATTEND YOUR NEAREST EMERGENCY ROOM.

Your use of the Bodiometer App (or any of its related services) is governed by the Terms of Use applicable to same. Please see our Terms of Use for further details.

How do we Use and Disclose your Personal Information?

We may use and disclose your personal information:

❏ for the purposes described in this Privacy Policy; or

❏ for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.

We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.

We may use de-identified information created by us from your personal information without restriction.

When do we disclose your Personal Information?

We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including: third parties that provide services to us or on our behalf; third parties that assist Bodiometer in the provision of services to you; and third parties whose services we use to conduct our business.

In addition, personal information may be disclosed or transferred to another party during the course of, or completion of, a change in ownership of or the grant of a security interest in, allor a part of Bodiometer through, for example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

Further, your personal information may be disclosed:

❏ as permitted or required by applicable law or regulatory requirements;

❏ to comply with valid legal processes such as search warrants, subpoenas or court orders;

❏ to protect the rights and property of Bodiometer;

❏ during emergency situations or where necessary to protect the safety of a person or group of persons;

❏ where the personal information is publicly available; or

❏ with your consent.

Your Consent is Important to Us

It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can begiven orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.

Typically, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

You may change or withdraw your consent at any time, subject to legal or contractual obligations and reasonable notice, by contacting our Privacy Officer using the contact information set out below. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.

How is Your Personal Information Protected?

Bodiometer endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.

The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.

Updating Your Personal Information

It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes.

In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.

Access to Your Personal Information

You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as wellas to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact the office of our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

Inquiries or Concerns?

If you have any questions about this Privacy Policy or concerns about how we manage your personal information, please contact our Privacy Officer, in writing or by e-mail. We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are dissatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner in your jurisdiction.

Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

Bodiometer Privacy Officer
AnimationLeader Technology Inc.
info@bodiometer.com

Revisions to this Privacy Policy

From time to time, we may make changes to this Privacy Policy to reflect changes in its legal orregulatory obligations or in the manner in which we deal with your personal information. Wewill post any revised version of this Privacy Policy on our website www.bodiometer.com and we encourage you to refer back to it on a regular basis. This Privacy Policy was last updated on Aug 11, 2020.

Interpretation of this Privacy Policy

Any interpretation associated with this Privacy Policy will be made by our Privacy Officer. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word 'including' is used, it shall mean 'including without limitation'.

This Privacy Policy does not create or confer upon any individual any rights, or impose upon Bodiometer any obligations outside of, or in addition to, any rights or obligations imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada's federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.

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