FOOT MEDICINALS
WEBSITE PRIVACY NOTICE

General Information

Foot Medicinals and our subsidiaries and affiliates, including APGSM Marketplace, LLC (“Marketplace Facilitator”) (collectively, “Foot Medicinals”, “we”, “us”, and “our”) provides this website privacy notice (“Privacy Notice”) to describe the types of information that are identifiable to a particular person (“Personal Information”) that Foot Medicinals collects about you when you use or access our website (https://www.footmedicinals.com) (the “Site”). It also describes how we use that information, with whom we share it, the choices available regarding our use of the information, and how to contact us about our privacy practices.

We urge you to read this Privacy Notice to ensure you are informed. Your use of the Site constitutes your acceptance of and agreement to this Privacy Notice. If you do not agree to this Privacy Notice, do not use the Site.

California residents please see our “California Privacy Notice” below for additional, California-specific disclosures about our privacy practices.

If you are a patient, this Privacy Notice does not apply to your “protected health information” (PHI) as defined by HIPAA (the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations). Foot Medicinals processes PHI as a business associate providing services to your treating physician. If you are patient who would like information about how your PHI may be handled, please consult the Notice of Privacy Practices you received from your physician, or contact your physician directly.

What Personal Information Does Foot Medicinals Collect?

We may collect the following categories of information about you. In some cases, the information we collect may fall within more than one category.

• Account information and personal identifiers. Our Site enables patients, physicians, and physicians’ staff to create accounts on the Site.
  • Patients: When you create an account, we may collect your name, email address, phone number, billing address, mailing address, and payment information (such credit or debit card details or other payment credentials). We may also collect any further information you provide us in connection with using your account, such as passwords, account preferences, and any actions taken by you while logged into your account. You should also consult the Notice of Privacy Practices that you received from your treating physician for more information about PHI that may be in your accounts.
  • Physicians: When you create an account, we may collect your name, address, email address, phone number, the name of your practice, your NPI number, and state licensing information. We may also collect any further information you provide us in connection with using your account, such as passwords, account preferences, payment information (such as banking information and/or credit and debit card details) and any actions taken by you while logged into your account.
  • Staff: Your clinic may ask us to create an account for you. When they do, we receive your name, email address, National Provider Numbers, address of office, and credentials. We may also collect any further information you provide us in connection with using your account, such as passwords, account preferences, payment information (such as banking information and/or credit and debit card details), and any actions taken by you while logged into your account.
• Information collected automatically. For all users of the Site, when you use or interact with our Site, the Site automatically collects information about your device, usage, and activity, such as:
  • Device identifiers and browser information, such as technical information associated with the device or browser you use, such as the type and model, system language, browser type, operating system, and user or device identifiers like MAC address, IP address, or other online identifiers.
  • Online or network activity information, such as information regarding what you do on our Site and your interaction with our Site, information about all activity and information within your account, information about your browsing and search history on our Site (such as products viewed or searches for nearest clinics), and log file and interaction information which includes, but may not be limited to, your browser type, webpages you visit, how long you visit, what links you click on, how many times you visit a page, heatmaps and scrolls, and how long it takes for you to come back, and other electronic network information.
  • Cookies and similar technologies. We may use cookies, web beacons, and other similar technologies on our Site which may collect all the “Information collected automatically” described in this section. To learn more about cookies, please visit https://allaboutcookies.org/. We may also use site analytics providers which may set cookies in your browser. For example, we partner with Google Analytics, which uses Cookies to track your interactions with the Site. Google then collects that information and reports it back to us. This information helps us improve the Site so that we can better serve users like you. For information on how to opt out of Google Analytics tracking your online activity, visit https://support.google.com/analytics/answer/181881?hl=en. If you are concerned about cookies, you may exercise certain preferences through the cookie settings offered on the Site. In addition, most browsers permit individuals to decline cookies. In most cases, you may refuse or delete one or more cookies and still access Site, but the functionality of the Site may be impaired. After you finish using the Site, you may delete site cookies from your system if you wish. If you would like more information on how to opt out of cookies, please visit: https://optout.aboutads.info.
• Communications with us. If you communicate with us, such as through our Contact Us forms or customer service line, we collect all information you provide in connection with those communications.

How Does Foot Medicinals Collect This Information?

• Directly from you. We may collect Personal Information directly from you when you interact with our Site, including to contact us with a question, search for information on our Site, place an order, or create and use an account.
• From your device. When you interact with our Site, we may automatically collect information about your device, browser, and activity on our Site, as described above.
• Information collected from third parties. We may collect Personal Information from third parties, such as other companies or publicly-available sources.

How Does Foot Medicinals Use Your Information?

We or our service providers may use Personal Information that we collect to perform the following business functions:

• Operate our business and our Site, including by providing our products and services and information about our products and services, processing transactions, auditing transactions;
• To facilitate payments;
• Enable users to use our Site and its features;
• Process and respond to your requests, such as to complete transactions, or to send you other communications;
• Conduct analytics, perform statistical analyses, and research, including to improve our Site and develop and market our products and services;
• Comply with legal obligations, legal process, or industry rules or best practices;
• Comply with, make claims relating to, or enforce legal rights or obligations, legal process, our policies, government requests, or prudent security or business practices;
• Enforce any applicable agreement with you or others;
• Monitor for and protect against or prevent fraud or other unauthorized, illegal, or suspicious activity; and/or
• Protect the security and integrity of our organization, products and services, service providers, and the Site.
• Market and advertise to you about products and services tailored to your individual interests, such as by sending you newsletters, emails, or (as permitted by law) via text messages or digital advertisements on other sites or platforms. You may also see certain ads on other websites because we participate in advertising networks. Ad networks allow us to target our messaging to users through demographic, interest-based and contextual means. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs and web beacons. The networks use this information to show you advertisements that may be tailored to your individual interests. The information our ad networks may collect includes information about your visits to websites that participate in the relevant advertising networks, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our websites and on third- party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts. To opt-out of targeted advertising, you can use the opt-out tools provided by the Network Advertising Initiative and the Digital Advertising Alliance.

Please note that we may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from other third parties and other public records and use such combined information in accordance with this Privacy Notice.

Retention of Personal Information

Your Personal Information is processed for the period(s) reasonably necessary to achieve the purposes listed in this Privacy Notice, or for any longer periods permitted or required by applicable law. Please note that this means we may be required to retain Personal Information after the end of our direct relationship with you.

Does Foot Medicinals Share Your Information with Others?

Foot Medicinals may generally share and disclose your Personal Information with the following categories of third parties and in the following scenarios:

• With third parties who provide services to us or on our behalf, including service providers, vendors, or business partners that provide Site and application functionality, hosting, analytics, customer service, payment processing, advertising and marketing services;
• With our subsidiaries and affiliates;
• With the Marketplace Facilitator;
• With your healthcare provider, if you are a patient;
• To comply with law, a court order, or other legal process, or in connection with a legal investigation;
• To protect the rights and interests of Foot Medicinals, our affiliates, third party service providers, and our and their respective employees, clients, users, or any other person or entity;
• To enforce any applicable terms and conditions and/or other agreements;
• In connection with legal compliance or with claims relating to legal rights or obligations, legal process, our policies, government requests, or prudent security or business practices;
• In the event of a transfer of ownership of Foot Medicinals, merger or other similar transaction (including one in connection with any bankruptcy or similar proceedings); and/or
• In accordance with your consent.

If you are a physician or staff, Foot Medicinals may also share and disclose your Personal Information with:

• Business partners with which you have a relationship; and
• Third parties that may offer joint marketing or promotions.
• We may use third party advertising companies to serve ads to you on their websites or elsewhere. These advertising companies may use cookies and other technologies to collect information about your device and activities on their websites and on other websites you visit over time, and the advertisements you click on, in order to deliver advertisements that are targeted to you. To learn more about your ability to opt out of certain types of these technologies and for other information, you can visit the Digital Advertising Alliance and the Network Advertising Initiative.

What Choices Do I Have About My Personal Information?

If you have created an account with us, you can log into your account to review the Personal Information associated with your account.

Also, if you receive marketing communications from us and wish to unsubscribe, you may do so by clicking on the “unsubscribe” link provided any marketing email, or send a “STOP” text message in response to marketing texts. Please also note that unsubscribing from future marketing-related messages does not prevent Foot Medicinals from sending you administrative messages, as applicable.

To prevent the use of cookies, your browser may have a preferences or settings that let you prevent all websites, including our Site, from using cookies while you browse. Please understand, however, that certain areas within this Site may not function properly if the web browser does not accept cookies.

Notice of Monitoring

We and our service providers and third party partners may monitor any use of or activity on the Site and may capture and retain records reflecting your activity on our

Site for our business purposes. This may include records reflecting actions you take while using our Site (such as clicks on pages or links, items viewed, scrolling, time spent on pages, and other activities), records of parts or all of your sessions on our Site, information you submit on or via our Site, or communications or information sent through or using our Site. The cookies, pixels, and other tracking technologies described in this Privacy Notice may also collect the foregoing information reflecting your use of and activity on our Site, or may enable our third party partners to collect such information. This information may be collected, retained, captured, and/or monitored by us or by our service providers and third party partners. If you do not consent to the monitoring described here, you should not use our Site.

Third Party Websites

This Privacy Notice also does not apply to any third party websites and mobile applications that our Site may link to, or that may link to our Site. Our Site may contain links to other websites or platforms that we do not control. These websites operate independently from us, and their privacy practices are subject to their own privacy policies, which we strongly encourage you to review to understand their procedures for collecting, using, and disclosing Personal Information. We are not responsible for the content of the third party websites, any use of these third party sites, or the privacy practices of these third party sites.

Privacy of Minors

We do not knowingly collect Personal Information on our Site from persons under the age of 18. If you are under 18, you are not permitted to use our Site. Please have your parents contact us instead.

Contact Us

Foot Medicinals welcomes your questions and comments about this Privacy Notice or the use of your Personal Information. Please email us at contactus@footmedicinals.com, call our Privacy Hotline at (888) 410-0406 or visit our Contact Us page https://www.footmedicinals.com/contact with any questions or comments.

Foot Medicinals California Privacy Notice

This Foot Medicinals California Privacy Notice supplements our Privacy Notice and provides additional disclosures that apply to California residents accessing the Site.

Collection of Personal Information: The section above titled “What Personal Information does Foot Medicinals Collect?” describes the Personal Information we have collected within the preceding 12 months, and intend to collect. This includes the following categories of Personal Information under California law:

• Identifiers, such as name, postal address, unique personal identifier, online identifier, IP address, email address, account name, or telephone number.
• Personal information described in the California Customer Records Law, such as the identifiers described above, as well as any information you provide in connection with obtaining our products or services.
• Commercial information, such as products or services you reviewed, considered, or purchased;
• Sensitive personal information, such as account login credentials
• Internet or network activity information, including all “Information Collected Automatically” described above;
• Inferences drawn from the information listed above.

Sources of Personal Information. We collect Personal Information from the sources described in the “How Does Foot Medicinals Collect This Information?” above.

Uses of Personal Information. We collect and use Personal Information for the business purposes described in “How Does Foot Medicinals Use Your Information?” above.

Retention of Personal Information

Foot Medicinals retains your Personal Information as described in “Retention of Personal Information” section above.

Disclosure of Personal Information. We have disclosed all or substantially all categories of Personal Information we collect with the third parties listed in the above section titled “Does Foot Medicinals Share Your Information with Others?”

Sharing for Targeted Advertising & Opt-Out. We do not sell data for monetary consideration, but like many companies that operate online, we may engage in digital advertising. Under certain state laws this may result in us “sharing” your data for targeted advertising, which you can opt-out from. We may share identifiers, internet and other electronic activity information, and inferences with ad networks, social media providers, or advertising providers for this purpose. We do not knowingly sell or share Personal Information of individuals under 16 for targeted advertising. To opt-out of sharing of your data for targeted advertising facilitated by cookies or similar technologies on our Site, visit the Digital Advertising Alliance and the Network Advertising Initiative and submit opt-out requests using the mechanisms these organization provide.

Your CCPA Rights. Subject to any exceptions provided by law, California residents have certain rights related to Personal Information, including:

1. The right to know what Personal Information we have collected about you, including requesting the specific pieces of Personal Information we may hold about you.
2. The right to correct inaccurate Personal Information that we may have collected about you.
3. The right to delete Personal Information we collected from you.
4. If applicable, the right to opt out of the sharing of Personal Information (“Sharing Opt Out”), as described above.

You also have the right to be free from unlawful discriminatory treatment for exercising your rights under the California privacy statutes.

How to Exercise Your Rights. You may exercise your rights to Know, Correct, or Delete by:

• Submitting a request via contactus@footmedicinals.com
• Calling Privacy Hotline at (888) 410-0406; or
• Clicking Contact Us https://www.footmedicinals.com/contact and sending us a message describing the right you would like to exercise (Right to Know, Correct, or Delete).

As required under applicable law, we will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may limit our response to your exercise of the above rights as permitted under applicable law.

Under California law, you may designate an authorized agent to make a request on your behalf. You may make such a designation by providing the authorized agent with written permission to act on your behalf. We may require the authorized agent to provide proof of that written permission. To the extent permitted by law, we may require you to verify your own identity in response to a request, even if you choose to use an authorized agent. If you are an authorized agent submitting a request on behalf of a California consumer, please submit the request using the channels described in this section.