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PRIVACY POLICY

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Welcome, and thank you for your interest in Trainer Rx, Inc. d/b/a RecoveryOne
(“RecoveryOne”, “we,” or “us”) and our Web site at app.recoveryone.com (the
“Site”), as well as all related web sites, networks, embeddable widgets,
downloadable software, mobile applications (including tablet applications), and
other services provided by us and on which a link to this Privacy Policy (this
“Policy”) is displayed (collectively, together with the Site, our “Service”).

This Policy describes the information that we gather from you on the Service,
how we use and disclose such information, and the steps we take to protect such
information. By using the Service, you consent to the privacy practices
described in this Policy.

RecoveryOne certifies that it adheres to the Privacy Shield Framework
established by the United States Department of Commerce and the European Union.
RecoveryOne complies with the EU-U.S. and Swiss –U.S. Privacy Shield Framework
as set forth by the U.S. Department of Commerce regarding the collection, use,
and retention of personal information transferred from the European Union to the
United States. RecoveryOne has certified to the Department of Commerce that it
adheres to the Privacy Shield Principles. If there is any conflict between the
terms in this privacy policy and the Privacy Shield Principles, the Privacy
Shield Principles shall govern. To learn more about the Privacy Shield program,
and to view our certification, please visit https://www.privacyshield.gov/.
RecoveryOne is subject to investigatory and enforcement oversight of the United
States Federal Trade Commission pursuant to the Privacy Shield Agreement between
the European Union and the United States for implementation of GDPR by domestic
United States companies.

RecoveryOne certifies that it adheres to the Privacy Shield Framework
established by the United States Department of Commerce and the European Union.

This Policy is incorporated into and is subject to the RecoveryOne Terms of Use.
Capitalized terms used but not defined in this Policy have the meaning given to
them in the RecoveryOne Terms of Use.

Questions or Complaints about RecoveryOne, its use, retention and disclosure of
Personal Data; or Requests to disclose, withdraw consent to use for any or all
purposes, or to receive copies of or remove Personal Data from RecoveryOne;
should be directed to: Privacy and Data Protection Officer, RecoveryOne, 1670
Riviera Ave. Suite #101, Walnut Creek, CA 94596; tel. 1-877-747-9411; email:
privacy@recoveryone.com.

Your Rights with respect to Personal Data are outlined in this Privacy
Policy here

The information we collect on the Service:

 * User-provided Information. When you use the Service, you may provide and we
   may collect what is generally called “personally identifiable” information,
   or “Personal Data,” which is information that specifically identifies an
   individual.
 * Personal Data. Personal Data is the term used by the European Union General
   Data Protection Regulation (“GDPR”) and is defined as “any information
   relating to an identified or identifiable natural person (known as a “Data
   Subject”); any identifiable natural person is one who can be identified
   directly or indirectly, in particular by reference to an identifier such as a
   name, an identification number, location data, an on-line identifier or to
   one or more factors specific to the physical, physiological, genetic, mental,
   economic, cultural, or social identity of that natural person. Personal Data
   shall include protected health information (“PHI”) as described below.

How we use your Protected Health Information. RecoveryOne is dedicated to
maintaining the privacy and integrity of your Personal Data including PHI. Under
the US Health Insurance Portability and Accountability Act (HIPAA), PHI is
information about you that may be used to identify you (such as your name,
social security number, or address), and that relates to (a) your past, present
or future physician or mental health or condition, (b) the provision of health
care to you, or (c) your past, present or future payment for the provision of
health care, In providing the Service, we will receive and create records
containing your PHI and may use it to remind you of workout sessions, develop
and conduct surveys with you to assist in providing you a better Service,
conduct our management and administrative activities, and otherwise as stated in
this Privacy Policy. You may also choose to grant access to your account to your
health care provider or communicate directly with your health care provider. We
may also use your de-identified PHI to run (or authorize third parties to run)
statistical research on individual or aggregate health or medical trends. Such
research would only use your PHI in an anonymous manner that cannot be tied
directly back to you. We are required by law to maintain the privacy and
confidentiality of your PHI, and we operate the Service consistent with
applicable federal and state laws governing health information privacy and
security.

 * Examples of Personal Data include name, email address, mailing address,
   mobile phone number, and credit card or other billing information. Personal
   Data also includes other information, such as date of birth, geographic area,
   or preferences, when any such information is linked to information that
   identifies a specific individual. You may also provide us medical data such
   as the identity and contact information of your health care provider(s) and
   part of your medical history and other information that you choose to share
   with us. You may provide us with Personal Data in various ways on the
   Service. For example, you provide us with Personal Data when you register for
   an account, use the Service, post User Content, interact with other users of
   the Service through communication or messaging features, or send us customer
   service-related requests.
 * “Cookies” Information. When you visit the Service, we may send one or more
   cookies (a small text file containing a string of alphanumeric characters) or
   similar code to your Devices. Some of this code may remain on your Devices
   and may be used by your browser or Devices on subsequent visits to the
   Service. This allows us to “remember” what you have done on the Service
   before and personalize the Service for you. Please look through your
   browser’s or device’s technical support resources to learn the correct way to
   remove or disable this code. Please note that disabling this code may prevent
   you from accessing some of the functionality and offerings available via the
   Service.
 * “Automatically Collected” Information. When you use the Service, we may
   automatically record certain information from your device by using various
   types of technology, including “clear gifs” or “web beacons.” This
   “automatically collected” information may include your IP address or other
   device address or ID, web browser and/or device type, the pages or other
   content you view or otherwise interact with on the Service, and the dates and
   times that you visit, access, or use the Service. We also may use these
   technologies to collect information regarding your interaction with email
   messages, such as whether you opened, clicked on, or forwarded a message.
   This information is gathered from all users.
 * Third Party Web Beacons and Third Party Buttons. We may also implement
   third-party content or advertising on the Service that may use clear gifs or
   other forms of web beacons, which allow the third-party content provider to
   read and write cookies to your browser in connection with your viewing of the
   third party content on the Service. Additionally, we may implement third
   party buttons (such as Facebook “like” or “share” buttons) that may allow
   third parties to collect information about you through such third parties’
   browser cookies, even when you do not interact with the button. Information
   collected through web beacons and buttons is collected directly by these
   third parties, and RecoveryOne does not participate in that data
   transmission. Information collected by a third party in this manner is
   subject to that third party’s own data collection, use, and disclosure
   policies.
 * Analytics. We may work with different companies who offer services that can
   assist us in better understanding how users of our Services interact with and
   use our Services. For example, we currently use and may continue to use a
   product called Google Analytics by permitting Google to use technologies such
   as web beacons and cookies to collect certain non-personally identifiable
   information that helps us understand your usage of our Service. We may permit
   Google and other third party analytics providers to combine information
   collected through our Service with information collected from third party
   services, and these analytics providers may use this information to help us
   better understand our users, and these analytics providers may also use this
   information to help their other customers better understand their users.
   Additionally, we currently use and may continue to use a version of Google
   Analytics called Google Analytics for Display Advertisers, which enables
   Google to collect, use, and disclose information in connection with certain
   advertising activities. You may opt-out of Google Analytics for Display
   Advertising and customize Google Display Network ads at
   https://www.google.com/settings/ads.
 * Integrated Services. You may be given the option to access or register for
   the Service through the use of your user-name and passwords for certain
   services provided by third parties (each, an “Integrated Service”), such as
   through the use of your Facebook credentials through Facebook Connect, or
   otherwise have the option to authorize an Integrated Service to provide
   Personal Data or other information to us. By authorizing us to connect with
   an Integrated Service, you authorize us to access and store your name, email
   address(es), date of birth, gender, current city, profile picture URL, and
   other information that the Integrated Service makes available to us, and to
   use and disclose it in accordance with this Policy. You should check your
   privacy settings on each Integrated Service to understand and change the
   information sent to us through each Integrated Service. Please review each
   Integrated Service’s terms of use and privacy policies carefully before using
   their services and connecting to our Service.
 * Information from Other Sources. We may obtain information, including Personal
   Data, from third parties and sources other than the Service, such as our
   partners, advertisers, and Integrated Services. If we combine or associate
   information from other sources with Personal Data that we collect through the
   Service, we will treat the combined information as Personal Data in
   accordance with this Policy.

How we use the information we collect. We use information we collect on the
Service in a variety of ways in providing the Service and operating our
business, including the following:

 * We use the information that we collect on the Service to operate, maintain,
   enhance and provide all features of the Service, to provide services and
   information that you request, to respond to comments and questions and
   otherwise to provide support to users, and to process and deliver entries and
   rewards in connection with promotions that may be offered from time to time
   on the Service.
 * We use the information that we collect on the Service to understand and
   analyze the usage trends and preferences of our users, to improve the
   Service, and to develop new products, services, feature, and functionality.
 * RecoveryOne will not contact you to ask unnecessary or irrelevant questions
   or to provide irrelevant information. Trainer RX may use your email address
   or other information we collect on the Service (i) to contact you for
   administrative purposes such as customer service, to address intellectual
   property infringement, right of privacy violations or defamation issues
   related to your User Content posted on the Service or (ii) to send
   communications, including updates on promotions and events, relating to
   products and services offered by us and by third parties we work with.
   Generally, after you have consented to the used of your Personal Data as
   provided herein, you have the ability to opt-out of receiving any promotional
   communications as described below under “Your Choices” at any time.
   RecoveryOne will only retain your Personal Data during the term of your
   Agreement to use the Service and as required by law.

This Privacy Policy describes how we protect your privacy as a general user of
the Service, not as a patient receiving care through the Service from your
health care provider. You understand that all information shared with your
health care provider is subject to your consent and to your health care
provider’s professional and legal duties of confidentiality and responsibility
which we do not control. If you are receiving care through the Service from a
health care provider, you have other rights with respect to the access, use and
disclosure of PHI. For a more complete description of a patient’s rights under
HIPAA, please refer to your health care provider’s Notice of Privacy Practices,
which provides important information to you about how your PHI may be used and
disclosed.

When we disclose information. Except as described in this Policy, we will not
disclose your information that we collect on the Service to third parties
without your consent. When we disclose your Personal Data, we will disclose the
amount necessary for the purpose of the disclosure. We may disclose information
to third parties if you consent to us doing so, as well as in the following
circumstances:

 * Any information that you voluntarily choose to include in a publicly
   accessible area of the Service, such as a public profile page, will be
   available to anyone who has access to that content, including other users.
 * We work with third party service providers to provide website, application
   development, hosting, maintenance, and other services for us. These third
   parties may have access to or process your information as part of providing
   those services for us. Generally, we limit the information provided to these
   service providers to that which is reasonably necessary for them to perform
   their functions, and we require them to agree to maintain the confidentiality
   of such information.
 * We may make certain automatically-collected, aggregated, or otherwise
   non-personally-identifiable information available to third parties for
   various purposes, including (i) compliance with various reporting
   obligations; (ii) for business or marketing purposes; or (iii) to assist such
   parties in understanding our users’ interests, habits, and usage patterns for
   certain programs, content, services, advertisements, promotions, and/or
   functionality available through the Service.
 * We may disclose your information if required to do so by law or in the
   good-faith belief that such action is necessary to comply with state and
   federal laws (such as U.S. copyright law), in response to a court order,
   judicial or other government subpoena or warrant, or to otherwise cooperate
   with law enforcement or other governmental agencies.
 * We comply with Privacy Shield principles for all onward transfers from the EU
   and Switzerland, including the onward transfer liability provisions.
 * We also reserve the right to disclose your information that we believe, in
   good faith, is appropriate or necessary to (i) take precautions against
   liability, (ii) protect ourselves or others from fraudulent, abusive, or
   unlawful uses or activity, (iii) investigate and defend ourselves against any
   third-party claims or allegations, (iv) protect the security or integrity of
   the Service and any facilities or equipment used to make the Service
   available, or (v) protect our property or other legal rights (including, but
   not limited to, enforcement of our agreements), or the rights, property, or
   safety of others.
 * Information about our users, including Personal Data, may be disclosed and
   otherwise transferred to an acquirer, or successor or assignee as part of any
   merger, acquisition, debt financing, sale of assets, or similar transaction,
   as well as in the event of an insolvency, bankruptcy, or receivership in
   which information is transferred to one or more third parties as one of our
   business assets.

 * RecoveryOne will not sell Personal Data or otherwise disclose it to third
   parties for profit.

Your Rights as a Data Subject

At any point while RecoveryOne is in possession of or processing your Personal
Data, you, the data subject, have the following rights:

 * Right of access – you have the right to request a copy of the information
   that we hold about you.
 * Right of rectification – you have a right to correct data that we hold about
   you that is inaccurate or incomplete.
 * Right to be forgotten – in certain circumstances you can ask for the data we
   hold about you to be erased from our records.
 * Right to restriction of processing – where certain conditions apply to have a
   right to restrict the processing.
 * Right of portability – you have the right to have the data we hold about you
   transferred to another organization.
 * Right to object – you have the right to object to certain types of processing
   such as direct marketing.
 * Right to object to automated processing, including profiling – you also have
   the right to opt out of automated processing or profiling.
 * Right to judicial review: in the event that RecoveryOne refuses your request
   under rights of access, we will provide you with a reason as to why. You have
   the right to complain as outlined below.

Complaints and Recourse

In the event that you wish to make complaint about how your personal data is
being processed by RecoveryOne, or how your complaint has been handled, you have
the right to lodge a complaint directly with the supervisory authority and
RecoveryOne’s Privacy/ Data Protection Officer.

The Contact Information for RecoveryOne’s Privacy/ Data Protection Officer:
Privacy and Data Protection Officer, RecoveryOne, 1670 Riviera Ave. Suite #101,
Walnut Creek, CA 94596; tel. 1-877-747-9411; email: privacy@recoveryone.com.

Recourse and Binding Arbitration

In the event you are not satisfied with the resolution of your complaint by the
RecoveryOne Privacy Officer, at RecoveryOne’s expense you may bring the matter
to an independent recourse mechanism through the International Centre for
Dispute Resolution-American Arbitration Association (ICDR-AAA). To contact
ICDR-AAA please visit http://go.adr.org/privacyshield.html. Additionally, under
certain conditions, more fully described on the Privacy Shield Website,
https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may
invoke binding arbitration when other dispute resolution procedures have been
exhausted.

Disputes may be sent to the following address as well:

International Centre for Dispute Resolution Case Filing Services

1101 Laurel Oak Road, Suite 100

Voorhees, NJ 08043

United States

Phone: +1.212.484.4181

Email box: casefiling@adr.org

Your Choices

You may, of course, decline to share certain Personal Data with us, in which
case we may not be able to provide to you some of the features and functionality
of the Service. If you wish to update, correct, or delete your account
information or any other Personal Data we hold about you, e, you may contact us
at privacy@recoveryone.com. Please note that while any changes you make will be
reflected in active user databases instantly or within a reasonable period of
time, we may retain all information you submit for backups, archiving,
prevention of fraud and abuse, analytics, satisfaction of legal obligations, or
where we otherwise reasonably believe that we have a legitimate reason to do so.

If you receive commercial email from us, you may unsubscribe at any time by
following the instructions contained within the email. You may also opt-out from
receiving commercial email from us, and any other promotional communications
that we may send to you from time to time, by sending your request to us by
email at privacy@recoveryone.com or by writing to us at the address given at the
end of this policy. We may allow you to view and modify settings relating to the
nature and frequency of promotional communications that you receive from us in
user account functionality on the Service.

Please be aware that if you opt-out of receiving commercial email from us or
otherwise modify the nature or frequency of promotional communications you
receive from us, it may take up to ten business days for us to process your
request, and you may receive promotional communications from us that you have
opted-out from during that period. Additionally, even after you opt-out from
receiving commercial messages from us, you will continue to receive
administrative messages from us regarding the Service.

Third-Party Services

The Service may contain features or links to Web sites and services provided by
third parties. Any information you provide on third-party sites or services is
provided directly to the operators of such services and is subject to those
operators’ policies, if any, governing privacy and security, even if accessed
through the Service. We are not responsible for the content or privacy and
security practices and policies of third-party sites or services to which links
or access are provided through the Service. We encourage you to learn about
third parties’ privacy and security policies before providing them with
information.

Children’s Privacy

Protecting the privacy of young children is especially important. Our Service is
not directed to children under the age of 13, and we do not knowingly collect
Personal Data from children under the age of 13. Children age 13 to 16 may use
RecoveryOne only with the consent of a legally responsible parent or guardian.
If you are under 13 years of age, then please do not use or access the Service
at any time or in any manner. If we learn that personally identifiable
information has been collected on the Service from persons under 13 years of age
and without verifiable parental consent, then we will take the appropriate steps
to delete this information. If you are a parent or guardian and discover that
your child under 13 years of age has obtained an account on the Service, then
you may alert us at privacy@recoveryone.com and request that we delete that
child’s personally identifiable information from our systems.

Data Security

We use certain physical, managerial, and technical safeguards consistent with
the GDPR and HIPAA requirements, that are designed to improve the integrity and
security of your personally identifiable information. We cannot, however, ensure
or warrant the security of any information you transmit to us or store on the
Service, and you do so at your own risk. We also cannot guarantee that such
information may not be accessed, disclosed, altered, or destroyed by breach of
any of our physical, technical, or managerial safeguards.

If we learn of a security systems breach, then we may attempt to notify you
electronically so that you can take appropriate protective steps. We may post a
notice through the Service if a security breach occurs. Depending on where you
live, you may have a legal right to receive notice of a security breach in
writing. To receive a free written notice of a security breach you should notify
us at privacy@recoveryone.com.

Privacy Settings

Although we may allow you to adjust your privacy settings to limit access to
certain Personal Data, please be aware that no security measures are perfect or
impenetrable. We are not responsible for circumvention of any privacy settings
or security measures on the Service. Additionally, we cannot control the actions
of other users with whom you may choose to share your information. Further, even
after information posted on the Service is removed, caching and archiving
services may have saved that information, and other users or third parties may
have copied or stored the information available on the Service. We cannot and do
not guarantee that information you post on or transmit to the Service will not
be viewed by unauthorized persons.

Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this
Policy, which we may update from time to time. If we modify the Policy, we will
make it available through the Service, and indicate the date of the latest
revision. In the event that the modifications materially alter your rights or
obligations hereunder, we will make reasonable efforts to notify you of the
change. For example, we may send a message to your email address, if we have one
on file, or generate a pop-up or similar notification when you access the
Service for the first time after such material changes are made. Your continued
use of the Service after the revised Policy has become effective indicates that
you have read, understood and agreed to the current version of the Policy.

Our Contact Information

Please contact us with any questions or comments about this Policy, your
Personal Data, our use and disclosure practices, or your consent choices by
email at privacy@recoveryone.com.

RecoveryOne

1670 Riviera Avenue, Suite 101

Walnut Creek, CA 94596