APP PRIVACY POLICY

Last Updated: January 13, 2019.

Your privacy is important to VG Technology, Inc. d/b/a Veda Grace, Inc. (“VG Technology,” “we,” “our”) and our healthcare affiliate Veda Grace Clinic, P.C. (“Veda Grace Clinic”). VG Technology provides a Service to give our users the ability to access healthcare from medical providers at Veda Grace Clinic online. One of the Services we provide to our users is our mobile application Veda Grace (“Veda Grace App”), you may use our mobile application without being a registered user of VG Technology.

This document is Privacy Policy for use of our mobile application (“App Privacy Policy”). We encourage you to read it to inform you of our practices and assure you of your privacy rights and how we use your personal information. How your information is handled depends on whether or not you are a registered user at VG Technology.

The Veda Grace allows you to 1) Capture 3D model of your face and immediately view it on your face on your phone; 2.) Capture standard photographs of your face and have them processed with our algorithm. Registered users of VG Technology may save their 3D face model to their existing VG Technology user account, where it can be accessed by healthcare providers at Veda Grace Clinic. The standard facial photo cannot be submitted to you VG Technology user account.

Registered users of VG Technology who upload their 3D face model to their VG Technology account remain bound to both the Terms of Use and Privacy Policy of VG Technology, as well as this App Privacy Policy. The VG Technology Terms of Use can be accessed at www.myvedagrace.com/terms-of-use and VG Technology Privacy Policy can be accessed at www.myvedagrace.com/privacy. All other users are bound solely by this App Privacy Policy.

The Veda Grace App is not a medical product or service. The Veda Grace App is neither intended to nor capable of providing medical advice or medical treatment. If you are a registered user of VG Technology and save your 3D face model to your VG Technology user account, your 3D face model is used by healthcare providers at Veda Grace Clinic. Your 3D face model is not considered medical imaging and is solely a 3D image of your face. Your 3D face model is used in a similar fashion as a picture of your face with the additional benefit of being 3D. The 3D model is neither intended to nor capable of providing medical advice or treatment. Any medical advice would come from our affiliated healthcare providers of Veda Grace Clinic.

To store your 3D face model in your VG Technology user account, we use your phone number to validate your identity and located the correct user account at VG Technology in which to store your 3D face model. Your user account at VG Technology is based on the phone number you used to originally registered at VG Technology. We use our cloud service to store your 3D face model in your VG Technology user account. The information in your VG Technology account is made available to the clinicians at Veda Grace Clinic for the purpose of rendering their clinical services.

If you do not have a registered user account with us and attempt to submit your 3D face model to VG Technology or if you choose not to submit your 3D face model, your Personal Information or User Data will not be stored in either our cloud service or within in the Veda Grace App after your session has completed.

1. Information Collected
There are two types of information that are collected: Personal Information and User Data. There are two ways in which information is collected: Information that is provided directly by you and information is automatically provided when you use our product. No information is stored in the mobile application itself.

Personal Information: Personal Information is defined as any information that can be used to identify you such as your name, address, email address, phone number, picture and any other information that is not otherwise publicly available. The Veda Grace and VG Technology only captures a minimum amount of Personal Information from you to provide you with the services of our software. The Personal Information that you may provide and that we may collect through the Veda Grace App include your phone number, standard facial photograph and 3D face model.

User Data: We define User Data all data collected that cannot be used to identify you. User Data may include settings, preferences and usage statistics.

a) Information you provide us: As part of using the Veda Grace App you acquire standard and 3D images of your face. If you are a registered VG Technology user, we offer you the ability to store your Personal Information and User Data in your user account at VG Technology using our cloud service. If you do not have a registered user account with Veda Grace and attempt to submit your 3D face model to VG Technology or if you choose not to submit your 3D face model, your Personal Information will not be stored in either our cloud service or permanently in the Veda Grace App.

b) Information automatically provided: In order to improve your overall experience and to improve our own internal diagnostics, we may use information that is automatically provided to us such as information provided through the use of your device on internet; your mobile device model, operating system, app version, usage statistics and internet connection details. We collect User Data on all users in order to improve our mobile application.

2. Authorized Third Parties
If you do not have a registered user account at VG Technology, your Personal Information is not available to us and is not shared with any third parties. Your User Data is collected but not shared with any third parties.

If you are a registered user of VG Technology and choose to submit 3D face model to your VG Technology user account, your Personal Information and User data to your information is shared with health care providers at Veda Grace Clinic for the purpose of providing you with medical services and other third parties listed in the VG Technology Privacy Policy, which is accessible at www.myvedagrace.com/privacy.

3. Data Security
We use the latest security measures to protect your details when you use the Veda Grace App. When registered users of VG Technology submit their Personal Information, it is saved in an encrypted cloud storage database. The Veda Grace App is only capable of submitting data to our cloud service. The Veda Grace App does not have the ability to download Personal Information to the mobile application. You can only access this information if you log into your user account on the VG Technology website www.myvedagrace.com. If you are a registered user of VG Technology, your data may be secured in other manners discussed in the VG Technology Privacy Policy, which is accessible at www.myvedagrace.com/privacy.

Unfortunately, the transmission and storage of information via the internet is not completely secure. Although we will do our best to protect your Personal Information and User Data, we cannot guarantee the security of your data transmitted between the Veda Grace App, our backend cloud service, and your user account at VG Technology; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

4. Use of Information
If you are not a registered user of VG Technology or you do not submit your 3D face model, your Personal Information is not available to us and is not utilized in any manner. Your User Data is collected and is used to improve your overall experience and to improve our own internal diagnostics.

If you are a registered user of VG Technology, we verify and use your phone number to save your Personal Information in your VG Technology account. Your user account at VG Technology is based on the phone number you used to originally registered at VG Technology. We use our cloud service to store your Personal Information and User Data in your VG Technology user account. Your information is made available to the clinicians at Veda Grace Clinic as part of your clinical assessment. If you are a registered user of VG Technology, your information may be utilized in other manners discussed in the VG Technology Privacy Policy, which is accessible at www.myvedagrace.com/privacy.

In the unlikely event that we or substantially all of our assets are acquired or enter a court proceeding, you acknowledge that such transfers may occur and that your Personal Information and User Data can continue to be used as set forth in this privacy policy.

5. Where We Store Your Personal Information
If you are not a registered user of VG Technology or you do not submit your 3D face model, your Personal Information is not stored. If you are a registered user of VG Technology and submit your 3D face model, you consent to have your Personal Information and User Data transferred to and store to our encrypted database servers hosted on Amazon Web Services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

6. Data Retention and Destruction
If you are not a registered user of VG Technology or you do not submit your 3D face model, your Personal Information is not stored and is not available for deletion. If you are a registered user of VG Technology and submit your 3D face model, we store your Personal Information as long as it is necessary to provide services to you and as long as we are legally required to do so. When we no longer need your Personal Information and User Data, we securely delete and destroy them.

7. Children’s Information
The Veda Grace App is not intended for unsupervised children, and we will not knowingly collect personally identifiable information from children. If we become aware that an account is registered by a user under the age of 18, we will remove their Personal Information and User Data information from our files. It is highly recommended that minors under the age of 18 use accounts that are created and supervised by their parents when using the Veda Grace App.

8. Access to Your Account Information and Preferences
When using the Veda Grace App, you have the right save your Personal Information to your VG Technology user account. You may log into your user account on the VG Technology website to access, modify and delete your account information. There is no Personal Information or User Data saved in the Veda Grace App.

9. Third Party Sites
If you are not a registered user of VG Technology or you do not submit your 3D face model, your Personal Information is not stored. If you are a registered user of VG Technology and submit your 3D face model, we share your Personal Information with Veda Grace Clinic for the purpose of rendering their clinical services to you.

10. Your California Privacy Rights
California Civil Code Section 1798.83, also known as S.B. 27, allows individual customers who have provided their personal information to us to request information about our disclosure of certain categories of personal information to third parties. Such requests must be submitted to us in one of the following ways: send a letter to Legal, VG Technology, Inc. 1452 South 53rd Street, Chicago, IL 60615 or through the various ways of contact described in the Contact Us page of any of our products or website. Within thirty days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties if any during the immediately preceding year, along with the names and addresses of those third parties. This request may be made no more than once per calendar year. We reserve the right not to respond to requests submitted in ways other than those specified above.

11. Class Action Waiver
Any dispute resolution proceedings, whether in arbitration or court, will be conducted only on an individual basis and not in a class or representative action or as a named or unnamed member in a class, consolidated, representative or private attorney general legal action. Your access and continued use of any of our mobile application signifies your explicit consent to this waiver.

12. Questions and Suggestions
If you have questions about the App Privacy Policy or the VG Technology Privacy Policy, you can contact us at info@vedagraceclinic.com.