PRIVACY NOTICE AND DATA PROTECTION POLICY

This privacy notice and data protection policy for Training Twin, Inc, its subsidiaries, and/or affiliates (“Training Twin”) describes how and why it collects, stores, uses, and/or shares (“Process”) customer information when a customer uses Training Twin’s website https://trainingtwin.com/ (“Website”).

1. WHAT INFORMATION DO WE COLLECT?

Training Twin may retain customer information disclosed to it during account creation (and other correspondence from the customer) for purposes of billing, providing services, and communications with the customer.

In providing healthcare related simulation services, Training Twin’s policy is that it will accept only de-identified data that does not contain protected health information, nonpublic personal information, or other personally identifying information.

In providing fitness and wellness tracking, aggregation, and simulation services, Training Twin’s policy is that, for customers that opt-in for these services, it will collect and store data uploaded from wearable electronic devices through Internet websites and other computer and electronic communication networks. This data is maintained on a cloud-based server as de-identified data that can only be matched with a specific customer using a unique account-specific identifier.

Training Twin does not collect customer Website usage data via its Website other than general analytic data concerning Website traffic and general correspondence submitted via the “Contact Us” page of the Website.

Training Twin does not collect data from customers less than 18 years of age.

2. HOW DO WE USE YOUR INFORMATION?

Training Twin will use any de-identified data or other customer information received from customer to provide services as described in Section1. Location data is used only to (i) display current customer activity location, (ii) determine effect of location on customer’s physiological simulation (i.e., altitude), and (iii) de-identified aggregation of customer location data for internal business purposes. Training Twin will not use any information for direct marketing purposes unless customers opt-in for such use. Training Twin will not sell your information to third parties.

3. HOW DO WE PROCESS YOUR INFORMATION?

Any de-identified data will be Processed as agreed by Training Twin and customer for the specific services chosen by customer. Any Training Twin services provided for the customer, including model tuning, simulation, evaluation, analysis, aggregation, and/or prediction, will be performed on Amazon Web Services, Inc. (AWS) cloud based servers. Data provided will be used: (i) to create simulation scripts, (ii) to create comparators to evaluate and tune the simulation for the customer, and (iii) to display the data to the customer.

4. HOW IS YOUR INFORMATION STORED?

Any customer information and/or de-identified data received by Training Twin will be stored on Amazon Web Services, Inc. (AWS) cloud based servers.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

Training Twin will retain customer data for as long as customer maintains a Training Twin account through the Website. After a customer’s account is cancelled, expired, or otherwise terminated, all customer data for that account will be deleted within 30 days.

6. NOTIFICATION IN EVENT OF DATA SECURITY BREACH

In the event of a data security breach, Training Twin will provide customers with the notification required by applicable law.

7. UPDATES TO THIS POLICY

Training Twin may update this privacy notice and data protection policy from time to time. The updated version will be provided to all current customers and will be effective as soon as it is received by the customer.