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PRIVACY STATEMENT


INTRODUCTION

Sword Health takes your privacy seriously. This Privacy Statement describes our
practices for collecting, storing, and processing the personal information of
users of our Services in the United States.

We offer wellness and physical therapy services by virtually connecting our
users to doctors of physical therapy or other professionals. We do this through
our websites, including, but not limited to, www.swordhealth.com,
www.hibloom.com, and their related sites, (the “Sites”), the Sword or Bloom
mobile applications, the Sword Health Digital TherapistⓇ, the Bloom Pod, SWORD
or Bloom motion sensors, biofeedback technology and exercise monitoring
equipment, and other electronic means such as video conferencing, chat, phone,
and online events (together, the “Services”). The Services are owned by Sword
Health, Inc. and its affiliates (“Sword”).

Sword provides the Services through which you can access telehealth,
musculoskeletal care, pelvic health care, and other wellness services provided
by a professional (“Clinical Services”). Sword Health, Inc. does not provide
Clinical Services. SWORD Health, Inc.' contracts with separate entities,
including but not limited to Sword Health Care Providers, P.A., Sword Health
Care Providers of NJ, P.C., Sword Health Care Physical Therapy Providers of CA,
P.C., other professional practices, companies and individuals (the “Sword
Professionals”) to engage independent doctors of physical therapy and other
professionals (each a “Professional” or together, the “Professionals”) to
provide Clinical Services to you.

Some of the information we collect relating to the Clinical Services may be
Protected Health Information (“PHI”) under the Health Insurance Portability and
Accountability Act of 1996 (“HIPAA”), such as your medical records that we
receive from your healthcare provider, your lab results, your initial
assessments, or device readings. PHI is covered by a separate policy called the
HIPAA Notice of Privacy Practices. The HIPAA Notice of Privacy Practices
describes how Sword uses and shares PHI and contains more information about your
rights under HIPAA. This Privacy Statement may provide additional detail on how
PHI is collected, processed, or stored, but if there is a conflict between this
Privacy Statement and the HIPAA Notice of Privacy Practices with respect to PHI,
the HIPAA Notice of Privacy Practices will solely apply.

We encourage you to read both the Privacy Statement and the HIPAA Notice of
Privacy Practices carefully. If you have any questions about this policy or our
practices, please send an email to privacy@swordhealth.com. Please note,
capitalized terms used in this Privacy Statement but not defined here have the
definition given to them in the Sword Terms and Conditions.

California Residents - See “Additional Information for California Residents”
below for additional information about your rights.

International Users - If you are accessing the Services from the United Kingdom
or European Union click here.

To help you read this Privacy Statement, we have organized it into the following
sections:

Personal Information We Collect - Information You Provide to Us - Information
Collected While Using Our Services - Information Collected from Other Sources

How We Use and Share Personal Information - Use of Personal Information -
Sharing Personal Information - Retention of Personal Information

How To Review, Modify, and Delete Personal Information - Right to Know/Access -
Right to Modify - Right to Request Deletion - How to Exercise Your Privacy
Rights

Additional Information for California Residents

How We Protect Personal Information

Tracking Technologies - Cookies and Other Tracking Technologies - Managing Your
Tracking Technology Preferences

Children’s Information External Websites Changes to This Privacy Statement
Contact Us


PERSONAL INFORMATION WE COLLECT

We may collect information that identifies, relates to, describes, is reasonably
capable of being associated with, or could be reasonably linked, directly or
indirectly, with a particular user or household (“Personal Information”) as
further described in the following categories below. We collect Personal
Information from you, from your use of the Services, when you visit the Sites,
and from certain third-party sources. By using the Services, and visiting the
Sites, you agree that we can collect and use your Personal Information as
described in this Privacy Statement.

INFORMATION YOU PROVIDE TO US

Sword collects information that you provide to us, including when you enroll,
give updates about your condition, respond to a survey, or contact us. Some
examples of this information include:

Contact or other Identifying Information, such as your name, address, email
address, telephone number, username and password; Professional or
employment-related information, such as the name of your employer, company, and
other professional or employment information you provide to us; Mental and
physical condition information, such as height, weight, general health, feelings
of pain and fatigue, exercise patterns, personal motivations, information about
pregnancies and childbirth, and feelings of anxiety or depression; Medical
information such as current or former injuries, medical diagnoses, and whether
you are cleared by a physician to exercise; and Communications with Sword,
including with the Professionals.

INFORMATION COLLECTED WHILE USING OUR SERVICES

Sword may also collect certain information when you access, browse, and use our
Services. This information is generated by the computer, tablet, mobile app, or
electronic sensors used in the Services. Some examples include:

Internet and other electronic activity data, such as the name of the domain and
host from which you access the internet; the browser software you use and your
operating system; the date and time you access the service; how often you access
the Services, and the internet address of the website from which you directly
linked to Sword; Log and Troubleshooting Information: We collect information
about how our Services are performing when you use them, like service related
diagnostic and performance information. This information includes log files,
timestamps, diagnostic or crash data, website/app performance logs and error
messages or reports. Identifiers or Geolocation data, such as Internet Protocol
(IP) address; Sensor data, the type and order of exercises, number of
repetitions, duration, manner, and individual performance including range of
motion, movement errors, and compliance with the assignment movement; and Data
from Tracking Technologies, such as information from cookies, web beacons, tags
or other tracking technologies, as further described below.

**Sword will not record video or audio of your sessions without explicit consent
from you prior to each recording. Any recording will be handled in accordance
with this Privacy Statement and Sword's HIPAA Notice of Privacy Practices.

INFORMATION COLLECTED FROM OTHER SOURCES

In connection with your use of the Services, we may combine or compare data we
have collected from you with information collected from a third party. Some
examples of information we may receive from a third party include:

Eligibility Information: If you are participating in a program sponsored by your
employer, insurance provider, or healthcare provider, information contained in
an eligibility file such as whether you are enrolled in the plan, your name,
email, and some related health information; Information We Obtain From Your
Health Care Providers and Other Sources: In connection with your treatment, we
may collect medical records from your past, current, and future health care
providers. This may include past or present diagnoses, previous treatments,
general health, test results and reports, any family history of illness, and
records of communications related to your health; and Information Collected From
Third Parties: We may collect information available about you from third party
service providers to improve the Services, such as identifying health factors
related to your treatment to better tailor the Services to you.


HOW WE USE AND SHARE PERSONAL INFORMATION

USE OF PERSONAL INFORMATION

We may use the Personal Information we collect for one or more of the following
business purposes:

 * To provide, personalize, improve, update, and expand our Services, including:
   - For product testing and development, data analysis, and survey purposes;
   and, - For scientific, statistical, and historical research;
 * To communicate with you about the Services, including: - To respond to your
   inquiries and concerns; - Provide you with information or request action in
   response to technical, security and other operational issues; or - To
   follow-up with you regarding your enrollment process. - To create
   de-identified information (for example, aggregated statistics) related to the
   use of the Services or for scientific research;
 * To comply with laws and regulations, including to respond to law enforcement
   or a government request(s) as required by applicable law, court order, or
   governmental regulations and to monitor our compliance with those
   obligations;
 * To protect the integrity and maintain the security of our Services;
 * To enforce our Terms and Conditions; and
 * For any other purpose for which you may provide consent or as disclosed to
   you when you provide information to us.

When we use the term “de-identified information,” we mean information that is
neither used, nor intended to be used, to identify an individual. We may use
de-identified information without restriction and may share it with unaffiliated
third parties.

SHARING PERSONAL INFORMATION

Sword does not share your Personal Information with third parties except as
described in this Privacy Statement, the HIPAA Notice of Privacy Practices, or
with your additional consent (if required).

Sword may share Personal Information with the following categories of third
parties for the following purposes:

Service Providers: We may share your Personal Information with service
providers, such as contractors and other third parties we use to support our
organization and provide us with services. These companies are subject to
contractual obligations governing privacy, data security, and confidentiality
consistent with applicable laws. These companies include our cloud services
infrastructure providers, vendors that assist us in marketing and consumer
research analytics, fraud prevention, security, communications infrastructure
providers, vendors that help us provide some support functions, like phone
support or survey tools, and third party partners for analytics and advertising
purposes; Corporate Affiliates: We may share your Personal Information with our
subsidiaries, affiliates, and associated organizations; Research Partners: We
may share your Personal Information with research partners if you provide us
with your express consent or if otherwise permitted by law. Research partners
include commercial or non-profit organizations that conduct or support
scientific research, the development of therapeutics, medical devices or related
material to treat, diagnose, or predict health conditions. In some
circumstances, a research partner or SWORD may have a financial interest in the
research arrangement. Health Care Providers, Health Plans, and Similar
Organizations: Personal Information that we create or obtain about you may be
shared with health care providers, health plans, or other similar health care
organizations as permitted by law or pursuant to your consent. Law Enforcement,
Government Agencies or Other Third Parties: From time to time, we may be
required to provide Personal Information to a third party in order to comply
with a subpoena, court order, government investigation, or other similar legal
process. If we disclose your Personal Information in this way, we will
reasonably attempt to provide you with advance notice, unless we are prohibited
from doing so. We may share your Personal Information if we believe it is
reasonably necessary to: - Comply with valid legal process (e.g., subpoenas,
warrants); - Respond to a government request; - Enforce or apply the Sword Terms
and Conditions; - Investigate fraud; - Protect the security or integrity of the
Services; - Protect the rights, property, or safety of Sword, our employees,
members, or users; or - At your direction or with your permission.

Corporate Transaction: If we are involved in a bankruptcy, merger, acquisition,
reorganization, or sale of all or a portion of our assets, we may share or
transfer your Personal Information as part of such corporate transaction.

Sword will not disclose/share any information obtained through the short code
program to third parties for their own marketing purposes.

RETENTION OF PERSONAL INFORMATION

Sword will retain the Personal Information you provide while creating your
account and your profile until such time as you delete your account or you
request deletion provided you are entitled to request deletion under applicable
law. Any clinical records created as a result of your use of the Services will
be securely maintained by Sword for a period that is no less than the minimum
number of years such records are required to be maintained under applicable law,
which is typically at least six years. Sword may also retain certain information
as reasonably necessary to comply with our legal obligations (including law
enforcement requests), resolve disputes, maintain security, prevent fraud and
abuse, as well as to comply with tax, securities, and regulatory compliance
requirements.


HOW TO REVIEW, MODIFY, AND DELETE PERSONAL INFORMATION

Some applicable laws provide individuals with specific privacy rights and you
may have certain privacy rights with respect to the Personal Information we
collect and maintain about you, such as the following:

RIGHT TO KNOW/ACCESS

You may have a right to request access to your Personal Information and to be
provided with a copy of certain information in a readily useable format,
including:

 * The categories of Personal Information we collected about you;
 * The categories of sources from which we have collected your Personal
   Information;
 * Our business or commercial purpose for collecting or selling that Personal
   Information;
 * The categories of your Personal Information that we have shared with third
   parties;
 * The categories of third parties with whom we share your Personal Information;
   or,
 * The specific pieces of Personal Information we collected about you.

RIGHT TO MODIFY

You may have the right to request that we modify the Personal Information we
have collected and maintain about you. To request to modify your Personal
Information, email us at help@swordhealth.com. We may request additional
information from you in order to verify your identity and update your Personal
Information per your request.

RIGHT TO REQUEST DELETION

You may have the right to request that we delete the Personal Information that
we have collected and maintain about you subject to applicable law. We may deny
your request under certain circumstances, such as if we need your Personal
Information to respond to your inquiries. If we deny your request for deletion,
we will let you know the reason why. There may be some latency in deleting your
Personal Information from our backup systems after it has been deleted from our
primary production and development systems.

HOW TO EXERCISE YOUR PRIVACY RIGHTS

If applicable, you may exercise your right to know/access and your right to
request deletion twice a year free of charge. To exercise your rights to
know/access and request deletion, please contact us at help@swordhealth.com. We
will take steps to verify your identity before processing your request. We will
not fulfill your request unless you have provided sufficient information for us
to reasonably verify that you are the individual about whom we collected
Personal Information. When submitting your request, please provide us with your
name and contact information for purposes of enabling us to begin verifying your
identity. We may request additional information about you if needed to verify
your identity. Unless you have previously provided us your Personal Information
for another purpose, we will only use the Personal Information provided in the
verification process to verify your identity or authority to make a request, and
to track and document your request to meet our obligations. We do not
discriminate against individuals for exercising any of the above privacy rights.
These rights may not be available to you and certain exceptions and exemptions
may apply that will limit your ability to exercise these rights.

Authorized Agents: If required under applicable law, you may use an authorized
agent to submit a request to know/access or a request to delete on your behalf.
Even if you use an authorized agent, you will still need to communicate directly
with Sword to verify your identity and address. We require that your agent be
registered to do business with the appropriate Secretary of State and/or that
your agent provide us with a signed document from you that authorizes your agent
to make the request on your behalf. To protect your Personal Information, we
reserve the right to contact you directly if we have any questions or concerns
about the request from your agent.


ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, California law provides you with additional
rights regarding our collection, use and disclosure of your Personal Information
under the California Consumer Privacy Act, as amended (“CCPA”), the Shine the
Light law, and the Do Not Track law. The CCPA does not cover PHI collected by a
covered entity or business associate that is governed by HIPAA. For information
on how Sword uses and shares your PHI please refer to our HIPAA Notice of
Privacy Practices. Additionally, under certain circumstances the CCPA will not
apply to Sword.

Within the preceding 12 months:

 * We have collected the categories of Personal Information described above in
   “Personal Information We Collect” from the sources described therein for the
   purposes described in “How We Use and Share Your Personal Information.”
 * We have shared categories of Personal Information to Service Providers,
   Corporate Affiliates, and Other Third Parties (as described further in “How
   We Use and Share Your Personal Information”).
 * We have not sold your Personal Information.


HOW WE PROTECT PERSONAL INFORMATION

We take great care to protect the Personal Information we maintain about you.
Sword has a broad information security program designed to protect your Personal
Information using administrative, physical, and technical safeguards. We have
measures in place to protect against inappropriate access, loss, misuse, or
alteration of Personal Information under our control. For example, Personal
Information is stored on encrypted servers. While we strive to protect your
Personal Information, we cannot guarantee the security of information you
provide to us. This is especially true for information you transmit to us via
email because email may not have the security features that are commonly built
into websites. To the fullest extent permitted by applicable law, we do not
accept liability for unintentional disclosure of your Personal Information.
Additionally, please be aware that we have no control over the information
collected by your internet service provider or information that you disclose
over a public network. We are not responsible for any information collected by
third parties not within our control or how such information is used or
maintained.


TRACKING TECHNOLOGIES

We may use technologies such as cookies, web beacons or pixels, tags, scripts,
and other storage technologies (collectively “Tracking Technologies”) to collect
or receive information on the Sites. These Tracking Technologies may help us
save your preferences, understand how you navigate through the Sites, and
improve your experience.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Cookies are small data files that we transfer to your device to collect
information about your use of the Sites. Cookies can be recognized by the
website that downloaded them or other websites that use the same cookies. This
helps websites know if your browsing device has visited them before. We may use
both first-party and third-party cookies on the Sites for the following
purposes: to make the Sites function properly, to improve the Sites, to track
your interaction with the Sites, to enhance your experience with the Sites, to
remember information you have already provided, to collect information about
your activities over time and across third party websites or other online
services in order to deliver content tailored to your interests; and to provide
a secure browsing experience during your use of the Sites. The length of time a
cookie will stay on your browsing device depends on whether the cookie is a
“persistent” or “session” cookie. Session cookies will only stay on your device
until you stop browsing. Persistent cookies stay on your browsing device until
they expire or are deleted. The following types of cookies may be used on the
Sites:

 * Strictly Necessary Cookies. These cookies are essential because they enable
   you to use the Sites. For example, strictly necessary cookies allow you to
   access secure areas of the Sites and for us to provide the Sites. These
   cookies do not gather information about you for marketing purposes. This
   category of cookies would be essential for the Sites to work and they cannot
   be disabled.
 * Functional or Preference Cookies. We may use functional cookies to remember
   your choices so we can tailor the Sites to provide you with enhanced features
   and personalized content. For example, these cookies can be used to remember
   your name or preferences on the Sites. We would not use functional cookies to
   target you with online marketing. While these cookies can be disabled, this
   may result in less functionality during your use of the Sites.
 * Performance or Analytic Cookies. These cookies collect passive information
   about how you use the Sites, including webpages you visit and links you
   click. We would use the information collected by such cookies to improve and
   optimize the Sites. We would not use these cookies to target you with online
   marketing. You would be able to disable these cookies.
 * Targeting or Advertising Cookies. These cookies are used to drive online
   advertising that is relevant to you by building up a picture of what you are
   interested in from your use of the internet. The cookies can limit the number
   of times you see an advert and help to measure the effectiveness of any
   advertising. They remember that you have visited a website and this
   information may be shared with other organizations or advertisers. We may use
   these cookies in limited circumstances associated with our public-facing
   sites.

We may also use tracking technologies to collect “clickstream” data, such as the
domain name of the service providing you with Internet access, your device type,
IP address used to connect your computer to the Internet, your browser type and
version, operating system and platform, the average time spent on the Sites, web
pages viewed, content searched for, access times and other relevant statistics,
and assign unique identifiers to the device or other credentials you use to
access the Sites for the same purposes. Pages of the Sites and our emails may
contain small electronic files known as web beacons (also referred to as clear
gifs, pixel tags and single-pixel gifs) that permit us, for example, to count
users who have visited those pages or opened an email and for other related
website statistics (for example, recording the popularity of certain website
content and verifying system and server integrity).

MANAGING YOUR TRACKING TECHNOLOGY PREFERENCES

When viewing the Sites, you can accept or reject the use of cookies. In
addition, many browsers allow you to manage your cookie preferences at the
individual browser level. You can set your browser to reject and/or delete some
or all cookies. If you reject or delete cookies, please be aware that you may
not be able to use some or all portions or functionalities of the Sites.

Do Not Track. Some Internet browsers (e.g. Internet Explorer, Mozilla Firefox,
and Safari) include the ability to transmit “Do Not Track” or “DNT” signals.
Since uniform standards for “DNT” signals have not been adopted, the Sites
currently do not process or respond to “DNT” signals.

Location Information. You may be able to adjust the settings of your device so
that information about your physical location is not sent to us or third parties
by: (a) disabling location services within the device settings; or (b) denying
certain websites or mobile applications permission to access location
information by changing the relevant preferences and permissions in your mobile
device or browser settings. Please note that your location may be derived from
your WiFi, Bluetooth, and other device settings. Please see your device settings
for more information.

Analytics Tools. We may use tools such as Google Analytics, Facebook, and
LinkedIn to help analyze how individuals use the Sites. Such third parties may
use cookies, APIs, and SDKs on our Sites to enable them to collect and analyze
user and device related data and information on our behalf. These tools use
cookies to collect information such as how often users visit the Sites, what
pages they visit, and what other websites they used prior to coming to the
Sites. We use the information we get to improve our Sites and to tailor the
Sites to you.

 * We may use Google Analytics to obtain information about your visits to the
   Sites. Google’s ability to use and share information collected by Google
   Analytics about your visits to the Sites is restricted by Google Analytics
   Terms of Service and the Google Privacy Policy. You may prevent your data
   from being used by Google Analytics by downloading and installing the Google
   Analytics Opt-out Browser Add-on .
 * Our Sites may utilize the Conversion Tracking Pixel service of Meta
   Platforms. This tool allows us to follow the actions of users after they
   click on a Facebook advertisement and allows us to record the efficacy of
   Facebook advertisements for statistical and market research purposes. The
   collected data remains deidentified which means we cannot see the personal
   data of any individual user. However, the collected data is saved and
   processed by Facebook and Facebook may be able to connect the data with your
   Facebook account and use the data for their own advertising purposes in
   accordance with Facebook’s Data Use Policy. Facebook Conversion Tracking also
   allows Facebook, and its partners, to show you advertisements on and outside
   Facebook. You can manage your preferences regarding how Facebook uses your
   data through your Facebook account settings.

REGARDING TARGETED ADVERTISING

For more information about the collection and use of your information for online
behavioral advertising generally, and how you can opt-out of having your data
used for certain online behavioral advertising, please visit the Digital
Advertising Alliance’s opt-out tool available at https://youradchoices.com/ and
the Network Advertising Initiative’s Opt-Out Tool available at:
https://networkadvertising.org/choices/.


CHILDREN’S INFORMATION

As we are committed to protecting the privacy of children, we do not collect
Personal Information directly from anyone who is, to our knowledge, under the
age of 13. If you are under the age of 13, please do not provide any Personal
Information to us through the Sites or Services. If you become aware that an
individual under age 13 has provided Personal Information directly to us, please
contact us as described in the “Contact Us” section, so that we can delete the
information.

A parent or guardian of children aged 13 to 18 years may create an account on
behalf of their child, provided that the parent assumes full responsibility for
the account and for the interpretation and use of any information provided
through the Services. Further, the parent or guardian agrees to supervise their
child’s use of the Services. Once a child reaches the age of 18, their Personal
Information becomes theirs to control and the parent or guardian no longer has
the ability to control the account.


EXTERNAL WEBSITES

The Sites may contain links to other websites, including, but not limited to,
investor relations sites, job applicant information gathering, assessment, and
testing sites. These third party sites have their own privacy practices and
measures to secure and protect your information. This Privacy Statement does not
apply to any third party sites. We encourage you to review the privacy statement
of any other third party website you may visit.


CHANGES TO THIS PRIVACY STATEMENT

This Privacy Statement is effective as of the date stated at the bottom of this
Privacy Statement. We may change this Privacy Statement from time to time.
Please be aware that, to the extent permitted by applicable law, our use of your
information is governed by the Privacy Statement in effect at the time we
collect the information. If you visit the Sites or use the Services after a
change to this Privacy Statement is posted on the Sites, you will be bound by
such change.


CONTACT US

If you have any questions or comments regarding this Privacy Statement, please
contact us at:

Sword Health, Inc. ATTN: Privacy Office 13937 Sprague Lane, Suite 100 Draper, UT
84020 385-308-8034 privacy@swordhealth.com

Last updated on and effective on: April 11, 2024

© 2024 Sword Health, Inc. All Rights Reserved


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For more information on how Google processes your data, visit the following
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