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EMPOURA PRIVACY POLICY

INTRODUCTION

This Privacy Policy (the “Policy”) describes the type of information that
Empoura Inc. (the “Company,” “we” or “us”) gathers from visitors to the Empoura
Website (the “Site”) and users of the service that is offered through the Site
(the “Service”).  The Site exists both to provide a platform to access the
Service, and to provide information about the Service and the Company.    



COLLECTION, USE, AND SHARING OF PERSONAL INFORMATION

“Personal Information” means information that can be associated with a
particular user.  The two charts below detail – separately with respect to the
Service and the Site – what Personal Information we collect, how and why we
collect such Personal Information, and how – if at all – such Personal
Information is shared.

 

Collection, Use, and Sharing With Respect to the Site and the Service

What Personal Information We Collect

Name, email address, phone number, state of residence.

Name, email address, phone number, nursing license type, state of residence,
desired company name, business purpose, company business address, EIN.

Data collected by cookies from Google Analytics and HubSpot.

How We Collect the Personal Information

The Contact Us feature available on the website permits users to contact us with
questions directly.

We request this information in the event that you utilize the Service’s
assistance in registering and running a business.

Cookies to which a user may agree as part of using the site automatically
collect certain analytics data

Why We Collect the Personal Information

We use this information to answer inquiries submitted through the “Contact Us”
feature.

We require this information in order to populate required registrations and
filings, as well as to create an account that allows you to utilize the Service.

We use this information in order to improve the Site and the Service.

We do not share this information, except as explained below under “Third-Party
Contractors,” “Business Transitions,” and “Compliance with Law and Prevention of
Harm.”



Third-Party Contractors – We may use contractors (“Service Providers”) to
perform limited services on our behalf, such as hosting websites and providing
email services.  Service Providers are required to obtain only the Personal
Information they need to deliver the Service, to maintain the confidentiality of
Personal Information, and not to use Personal Information for any purpose other
than provision of the Service.



Business Transitions – We may share information with businesses that are legally
part of the same group as the Company, or that become part of that group.  We
reserve the right – in the event of a business transition such as a merger – to
transfer Personal Information to a new business owner, on the condition that
such Personal Information must be treated in accordance with this Policy. 



Compliance with Law and Prevention of Harm – We may disclose your Personal
Information or any information submitted via the Site or Service if we have a
good faith belief that disclosure of such information is helpful or reasonably
necessary to: (i) comply with any applicable law, regulation, legal process or
governmental request; (ii) enforce any applicable terms of service, including
investigations of potential violations thereof; (iii) detect, prevent, or
otherwise address fraud or security issues; or (iv) protect against harm to the
rights, property or safety of the Company, our users, yourself or the public. 
We may be required to disclose Personal Information in response to a lawful
request by public authorities, including to meet national security or law
enforcement requirements.



Aggregated and De-identified Data – As noted above, this Policy addresses the
collection and sharing of Personal Information, that is, information that can
reasonably be connected with a particular user.  We may occasionally de-identify
and/or aggregate Personal Information – to the extent permitted by law – to the
point that it can no longer be associated with a particular user.  When that
occurs, such information is no longer Personal Information.

Sale of Personal Information – We do not sell Personal Information.

 

USERS’ RIGHTS REGARDING PERSONAL INFORMATION

Users of both the Site and the Service have the right to request information
about our collection, use, and disclosure of their information (a “Request to
Know”), including:



 * the categories and specific pieces of Personal Information we have collected
   about the user;

 * the categories of sources from which we have collected the user’s Personal
   Information;

 * the business or commercial purpose for collecting or selling the user’s
   Personal Information;

 * the categories of Personal Information we have sold about the user; and

 * the categories of Third Parties with whom we have shared, disclosed for a
   business purpose, or sold the user’s Personal Information, and which
   categories of Personal Information we have sold to which categories of Third
   Parties.

 

Users of both the Site and Service also have the right to request that we delete
their Personal Information (a “Request to Delete”).

 

Requests to Know

Users may submit a Request to Know by completing the form provided at
www.myempoura.com or by emailing us at robert.teduits@myempoura.com.

 

Users may submit two types of Requests to Know: (1) A request for the specific
pieces of Personal Information that we have collected about you in the past
twelve months; or (2) a request for the categories of Personal Information that
we have collected about you in the past twelve months, and we have used and
disclosed that Personal Information. 

 

When you submit a Request to Know, we may ask you to provide certain pieces of
information in order to verify your identity, such as your name, email address,
and phone number.  If you submit a Request to Know for the specific pieces of
information that we have collected about you, we may also require you to submit
a signed declaration under the penalty of perjury stating that you are the
consumer whose Personal Information is the subject of the Request to Know. 

 

If we are able to verify your identity, we will respond to your Request to Know
by: (a) providing the requested information; or (b) explaining why we are not
required to provide the requested information.  If we are unable to verify your
identity, we will respond by explaining why we cannot verify your identity.  We
will confirm receipt of your Request to Know within 10 days and will respond to
your Request to Know within 45 days. If a response requires additional time, we
will notify you of the basis for the delay and may extend our response period up
to an additional 45 days. 

 

If we provide the information requested, we will provide the information free of
charge and in a readily useable portable format.  We have no obligation to
provide Personal Information to you more than twice in a 12-month period.  If a
Request to Know or series of Requests to Know are manifestly unfounded or
excessive, we may charge a reasonable fee for processing the Request(s) to Know,
or may refuse to process the Request(s) to Know.

 

Requests to Delete

Users may submit a Request to Delete by completing the form provided at
www.myempoura.com or by emailing us at robert.teduits@myempoura.com.  When you
submit a Request to Delete, we may ask you to provide certain pieces of
information in order to verify your identity, such as your name, email address,
and phone number.  If we are able to verify your identity, we will respond to
your Request to Delete by (a) deleting your Personal Information and, if
applicable, directing any of our Service Providers to delete your Personal
Information; or (b) explaining why we are not required to delete your Personal
Information.  We may choose to delete Personal Information by de-identifying,
aggregating, or completely erasing the Personal Information.  We will specify
the manner in which we delete your Personal Information. 

 

If a Request to Delete or series of Requests to Delete are manifestly unfounded
or excessive, we may charge a reasonable fee for processing the Request(s) to
Delete, or may refuse to process the Request(s) to Delete.

 

PROTECTION AND RETENTION OF PERSONAL INFORMATION

We follow generally accepted industry standards, including the use of
appropriate administrative, physical and technical safeguards, to protect
Personal Information.  The appropriate administrative, physical, and technical
safeguards employed by us may vary depending on the nature of Personal
Information collected, with more stringent measures applied to information of a
sensitive nature.



However, no method of transmission over the Internet, or method of electronic
storage, is entirely secure.  Therefore, while we strive to use commercially
reasonable means to protect Personal Information, we cannot guarantee its
absolute security or confidentiality.  Please be aware that certain Personal
Information and other information provided by you in connection with your use of
the Site may be stored on your device (even if that information is not collected
by us).  You are solely responsible for maintaining the security of your device
from unauthorized access.



Personal Information will be retained for as long as is reasonably necessary to
achieve the purposes set forth in this Policy, and to comply with all applicable
laws.



OTHER PROVISIONS

Accessibility and Language – Any person that is unable to access this Policy
through the Site may request this Policy in an alternative format or language by
contacting us at robert.teduits@myempoura.com. 



International Users – The Company and its servers are located in the United
States and are subject to applicable local, state, and federal laws.  Users who
choose to access the Site do so on their own initiative and at their own risk,
and are responsible for complying with all applicable laws, rules and
regulations.  Users who choose to access the Site consent to the use and
disclosure of information in accordance with this Policy and subject to such
laws.  We may limit the Site’s availability, in whole or in part, to any person,
geographic area or jurisdiction we choose, at any time and in our sole
discretion.  We do not represent or warrant that the Site, or any part thereof,
is appropriate or available for use in any other jurisdiction.



As to residents of the EU, this means that, if you choose to use the Sites
and/or to communicate with us through the Sites, information about you –
including Personal Information – will be transmitted outside of the EU to the
United States.  The European Commission has the authority, pursuant to Article
45 of the GDPR, to determine that the laws of states outside of the EU provide
residents of the EU with an adequate level of data protection similar to that of
the GDPR.  Please note that, to date, the European Commission has not determined
that the federal and state laws of the United States provide EU residents with
an adequate level of data protection.



Children’s Privacy – The Site is neither directed to nor structured to attract
Users under the age of 18.  If you are under the age of 18, you are not
permitted to use the Site.  The Company does not knowingly collect Personal
Information from users under the age of 18.  If you are a parent with concerns
about children’s privacy issues in conjunction with the use of the Site, please
contact the Company at www.myempoura.com.



Do Not Track Signals and Collection of Information for Third-Party Advertising –
The Company is required to disclose how it responds to “Do Not Track Signals”
and whether third parties collect personally identifiable information about
users when they use online services.  The Company honors "do not track" signals
and does not track, use cookies, or use advertising when a “do not track”
mechanism is in place.  The Company does not authorize the collection of
personally identifiable information from our users for third-party use through
advertising technologies.



Amendments – We may modify or amend this Privacy Policy from time to time.  If
we make any material changes, as determined by us, to this Privacy Policy,
including in the way in which Personal Information is collected, used or
transferred, we will notify you by e-mail to the address specified in your
profile or by means of a notice on the Site prior to the change becoming
effective.



CONTACT INFORMATION

If you have questions about this Policy, please contact
robert.teduits@myempoura.com



EFFECTIVE DATE

The effective date of this Policy is 11-15-2021.

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