Last updated: April 4, 2023

Simini Technologies Inc. Privacy Policy

The Simini Technologies Inc. (“Simini”) websites (including our online store(s)), www.simini.com, www.surgerysam.com, www.ordersimini.com, www.getyourclinicapp.com, and our software applications (including our mobile apps such as Simini Review and Surgery Sam and white label versions of Surgery Sam for individual veterinary clinics) and any other websites and apps which may be added from time to time (the “Digital Assets”), are owned and operated by Simini.

Simini takes the issue of privacy seriously. At Simini, we value your privacy and are committed to protecting your information in compliance with all applicable privacy and data protection laws globally, including without limitation the California Consumer Privacy Act (“CCPA”) and the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This privacy policy describes the personal information protected under applicable privacy and data protection law, which we collect or process about you or that could identify you when you use our Digital Assets, and how and why we collect or process it.

Please note that any third-party sites, applications or other items linked on or within our Digital Assets are governed by those third-parties’ terms of use and privacy policy, which we encourage you to review. We are not responsible for the information practices of any of those websites, applications or other items.

PURPOSE

The purpose of this privacy policy (this "Privacy Policy") is to inform users of our Digital Assets of the following:

1. What personal data we will collect;
2. How we use collected data;
3. Who has access to the data collected;
4. The rights of Digital Assets users; and
5. The Digital Assets' cookie policy.

This Privacy Policy applies in addition to the Terms and Conditions of Use of our Digital Assets.

THE TYPES OF PERSONAL INFORMATION WE COLLECT

We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

Data Collected in a Non-Automatic Way

When you perform certain functions, such as open an account or place an order on one or more of our Digital Assets, we will ask you to provide the following data:

• First and last name;
• Email address;
• Phone number;
• Address;
• Payment information (where relevant); and
• Auto fill data
• Pet’s name
• Pet’s photo
• Pet’s surgeon, referring vet, and their clinic

The apps may also allow Users to send pet updates to their surgeon. These updates are completely voluntary. These data can be shared with your surgeons, their surgery clinic, or individuals your surgeon selects to review these data.

These data may become part of the veterinary records at your surgeon’s and referring veterinarians practice.

These data may be anonymized and used to improve care of pets following clinical procedures.

NON-PERSONAL IDENTIFICATION INFORMATION

We may collect non-personal identification information about Users whenever they interact with our Digital Assets. Non-personal identification information may include the browser name, and the type of computer and technical information users use to access our Digital Assets such as the operating system and the Internet service providers utilized and other similar information.

HOW WE USE PERSONAL DATA

Personal Data collected on our Digital Assets will only be used for the purposes specified in this Privacy Policy or indicated on the relevant pages of our Digital Assets. We will not use your personal data beyond what we disclose in this Privacy Policy.

We may need to hold, process, and transfer your Personal Information but will do so solely for legitimate business purposes in accordance with applicable laws, regulations, and guidelines. We will only disclose your Personal Information on a need-to-know basis to those who are authorized to use it for these purposes.

The personal data we collect when the user performs certain functions may be used for the following purposes:

• To set up a user account;
• Completion of orders;
• Communication.
• To tailor your experience when accessing or using our websites;
• To operate and manage our business (including developing, maintaining and supporting our Digital Assets);
• To provide you marketing and information about our Digital Assets that we think may interest you (if you have not opted out of receiving marketing or, where an affirmative opt-in is required under applicable to law, you have affirmatively opted in to receive marketing);
• To provide supplemental information to veterinary healthcare teams to support the care of your pet
• To comply with applicable law;
• To establish, exercise or defend our legal claims and rights; and,
• For any other purpose(s) set forth in any consent you provide

HOW LONG WE STORE PERSONAL DATA

User personal data will only be stored until the purpose the data was collected for has been achieved. You will be notified if your data is kept for longer than this period.

WHO WE SHARE PERSONAL DATA WITH

Employees: We may disclose user personal data to any member of our organization who reasonably needs access to user personal data to achieve the purposes set out in this Privacy Policy.

Third-Party Service Providers: Where necessary to provide our services, we may disclose user personal data to a third-party service provider who reasonably needs access to user personal data to achieve the purposes set out in this Privacy Policy. For instance, our apps are hosted by either SiteGround or Google. Please refer to these sites for further information on how they manage personal data. https://world.siteground.com/privacy.htm, https://policies.google.com/privacy.

OTHER DISCLOSURES

We will never sell your data to third parties. We will not share your data with third parties who are not our service providers as set out above, except in the following cases:

1. If the law requires it;
2. If it is required for any legal proceeding; and
3. To prove or protect our legal rights.

If you follow hyperlinks from our Digital Assets to another website or app, please note that we are not responsible for and have no control over their privacy policies and practices. We strongly recommend that you review all privacy policies for any website or app you use that is not our Digital Assets.

CHILDREN

We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our Privacy Officer at the address listed in this Privacy Policy.

HOW WE MANAGE AND PROTECT PERSONAL INFORMATION

We will never sell, rent or trade your personal information. We protect all the personal information we collect. While we take all reasonable precautions to ensure that user personal data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of user data beyond what is reasonably practical.

COOKIES

When we provide services, we want to make them easy, useful and reliable. Where services are delivered on the internet, this sometimes involves placing small amounts of information on your device, for example, your computer or mobile phone. These include small files known as cookies. They cannot be used to identify you personally.

These pieces of information are used to improve services for you, such as analyzing anonymized data to help us understand how people interact with our services so we can make them better. A cookie often includes a randomly generated number which is stored on your device. Many cookies are automatically deleted after you finish using the Digital Assets.

Users may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Digital Assets may not function properly.

DO NOT TRACK NOTICE

Do Not Track ("DNT") is a privacy preference that you can set in certain web browsers. We do not currently have the technical capability to implement DNT preferences in our systems, and therefore do not respond to browser-initiated DNT signals.

ACCEPTANCE

By using our Digital Assets, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Digital Assets. Your continued use of the Digital Assets following the posting of changes to this policy will be deemed your acceptance of those changes. You can withdraw your consent by Contacting the Privacy Officer, as set out below. When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.

MODIFICATIONS

This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we do, we will revise the updated date at the top of this page. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications. If necessary, we may notify users by email of changes to this Privacy Policy.

ACCURACY

You are responsible for the accuracy of the information that you provide to Simini Technologies Inc. through our Digital Assets or otherwise.

GDPR

For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the "GDPR"). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018. We have not appointed a Data Protection Officer as we do not fall within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.

LEGAL BASIS FOR PROCESSING

We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR. We rely on the following legal bases to collect and process the personal data of users in the EU:

1. Users have provided their consent to the processing of their data for one or more specific purposes;
2. Processing of user personal data is necessary for us or a third party to pursue a legitimate interest. Our legitimate interest is not overridden by the interests or fundamental rights and freedoms of users. Our legitimate interest(s) are set out above in: HOW WE USE PERSONAL DATA.

YOUR RIGHTS AS A USER

Under the GDPR, you have the following rights:

1. Right to be informed;
2. Right of access;
3. Right to rectification;
4. Right to erasure;
5. Right to restrict processing;
6. Right to data portability; and
7. Right to object.

HOW TO ACCESS, MODIFY, DELETE, OR CHALLENGE THE DATA COLLECTED

If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to whom we disclosed your personal data, if you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under the GDPR, please contact our Privacy Officer here:

HOW TO OPT-OUT OF DATA COLLECTION, USE OR DISCLOSURE

In addition to the method(s) described in the section above, we provide the following specific opt-out methods for the forms of collection, use, or disclosure of your personal data specified below:

1. You can opt-out of the use of your personal data for marketing emails;
2. You can opt-out by clicking "unsubscribe" on the bottom of any marketing email; or
3. You can opt-out by updating your email preferences under "Your Account".

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with certain information about how we handle their personal information. This section does not address or apply to our handling of any personal information subject to an exemption under CCPA Section 1798.145(c) – (f). Please read this Privacy Policy to learn how we handle information covered by these laws.

Simini collects personal information categories including identifiers, inferences, and usage data. Simini collects this information when you visit our website to operate, manage, and promote our business, including developing, maintaining and supporting our Digital Assets, and to tailor your experience when accessing or using our websites.

California residents have the right to make the following requests, up to twice every 12 months:

• The right to request the specific pieces of personal information Simini has collected about You.
• The right to request that Simini disclose what personal information we collect, use, disclose, or sell.
• The right to request that Simini delete personal information that Simini has collected about You (subject to certain exceptions).
• The right to opt out of the sale of Your personal information.

You may exercise your rights to access and delete data by emailing us at cd@simini.com.

Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to the value of your information.

CONTACT

Please contact our Privacy Officer if you have any questions or complaints about Simini’s compliance with this privacy policy. You can contact us by email at: cd@simini.com.