Return 2 Life Safely (R2LS) Privacy Policy

1.     Introduction

1.1   We are committed to safeguarding the privacy of our web site and application (Managed Response) users.

1.2   This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3   We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of Managed Response services, we will ask you to consent to our use of cookies when you first visit our website.

1.4   In this policy, “we”, “us” and “our,” refer to R2LS LLC, a wholly-owned subsidiary of InnoVet LLC. For more information about us, see Section 14.

2.     Credit

2.1   This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).

3.     The personal data that we collect

3.1   In this Section 3 we have set out the general categories of personal data that we process.

3.2   We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, email address, telephone number, postal address, and work location. The source of the contact data is you through the Managed Response App and/or your employer through the web portal.

3.3   We may process your user account data (“account data”). The account data may include your account identifier, name, email address, work location, work scheduling status and preferences. The primary source of the account data is you through the Managed Response app.

3.4   We may process your user health assessment data (“health assessment data”). This health assessment data are the answers to your initial and daily health status questions that are set up by your employer in their portal. The primary source of this data is you, entered through the Managed Response app. The app saves your answers, including daily temperature readings input by you on your device. However, the app converts your answers to a graded ‘assessment’ that is the only data sent outside of your personal device. This grading is also set by your employer through a process determined by them and communicated to you. This will indicate a status of ‘ready to work’ or ‘no ready to work.’

3.6 We may process data about the work locations you have scanned (“usage data”). The usage data may include the time of the scan, the tag of the scan, the status of tag attime of the scan. The source of the usage data is the Managed Response application.

4.     Purposes of processing and legal bases

4.1   In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.

4.2   Operations – We may process personal data for the purposes of providing sanitation status of areas you scan to you, providing activity/presence of employees at tags for cleaning/managing purposes, providing your work status to your management to assist them in effectively scheduling your return to work, and to enable your identification, location, and status in an emergency situation. The legal basis for this processing is our legitimate interests, namely assisting your employer in minimizing risk of infection in the workplace, assisting your employer and you in an emergency situation within your work facility, and providing you with insight into building status.

4.3   Relationships and communications – We may process contact data, account data, health assessment data and/or usage data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services, application, and business.

4.4   Research and analysis – We may process usage data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving, and securing our website, services, and business generally.

4.5   Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to run our business properly and efficiently in accordance with this policy.

4.6   Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

4.7   Insurance and risk management – We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

4.10 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.

4.11 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

5.     Providing your personal data to others

5.1   We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.

5.2   Your personal data (noting that the Health Assessment data only at the overall assessment level) will be stored on the servers of our hosting services providers (AWS Servers)

5.3   We may disclose personal data (noting that the Health Assessment data only at the overall assessment level) to your employer insofar as reasonably necessary for providing the overall services.

5.5 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6.     International transfers of your personal data

6.1   In this Section 6, we provide information about the circumstances in which your personal data may be transferred to countries outside of your primary work location.

6.2   The hosting facilities for our website are situated on Amazon Web Services. The competent data protection authorities have made an “adequacy decision” with respect to the application data protection laws. If your employer operates across national boundaries, your personal data may reside in different locations. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which you can obtain from R2LS LLC or your employer.

6.3   You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

7.     Retaining and deleting personal data

7.1   This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

7.2   Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

7.3   We will retain your personal data as follows:

(a)   All personal data will be retained for a minimum period of 30 days following the date of the most recent contact between you and us, and for a maximum period of one year following that date.

7.4   Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

8.     Your rights

8.1   In this Section 8, we have listed the rights that you have under data protection law.

8.2   Your principal rights under data protection law are:

(a)   the right to access – you can ask for copies of your personal data;

(b)   the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)    the right to erasure – you can ask us to erase your personal data;

(d)   the right to restrict processing – you can ask us to restrict the processing of your personal data;

(e)   the right to object to processing – you can object to the processing of your personal data;

(f)    the right to data portability – you can ask that we transfer your personal data to another organisation or to you;

(g)   the right to complain to a supervisory authority – you can complain about our processing of your personal data; and

(h)   the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

8.3   These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for- organisations/guide-to-data-protection/guide-to-the-general-data-protection- regulation-gdpr/individual-rights/.

8.4   You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below].

9.     About cookies

9.1   A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2   Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3   Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

10.  Cookies that we use

10.1 We use cookies for the following purposes:

(a)   authentication – we use cookies to identify you when you visit our website and as you navigate our website.

(b)     status – we use cookies to help us to determine if you are logged into our website.

(c)     personalization – we use cookies to store information about your preferences and to personalize the website for you.

(d)     security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally

(e)     analysis – we use cookies [to help us to analyze the use and performance of our website and services; and

(f)      cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally

11.  Cookies used by our service providers

11.1 We do not share any of your personal data with external service providers either through structured data exchange or through cookies.

12.  Managing cookies

12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)   https://support.google.com/chrome/answer/95647 (Chrome);

(b)   https://support.mozilla.org/en-US/kb/enable-and-disable-cookies- website-preferences (Firefox);

(c)    https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d)   https://support.microsoft.com/en-gb/help/17442/windows-internet- explorer-delete-manage-cookies (Internet Explorer);

(e)   https://support.apple.com/en-gb/guide/safari/manage-cookies-and- website-data-sfri11471/mac (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and- privacy (Edge).

12.2 Blocking all cookies will have a negative impact upon the usability of many websites.

12.3 If you block cookies, you will not be able to use all the features on our website.

13.  Amendments

13.1 We may update this policy from time to time by publishing a new version on our website.

13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

13.3 We will notify you of significant changes to this policy when using the Managed Response app.

14.  Our details

14.1 This website, Managed Response App, and back-end data stores are owned and operated by R2LS LLC, a wholly owned subsidiary of InnoVet LLC.

14.2 We are registered in the United States with our registered office at 3500 S. Dupont Hwy, Dover, DE 19901, USA.

14.3 Our principal place of business is at 3500 S. Dupont Hwy, Dover, DE 19901, USA.

14.4 You can contact us:

(a)   directly through the Managed Response app, ‘Contact Us’ form; or

(b)   by email, using the email address published on our website.

15.  Data protection officer

15.1 Our data protection officer’s contact details are: James A. White, jwhite@innovetusa.com