Welcome to the www.medtrum.com web site, owned and operated by Medtrum. Medtrum is the name we use to refer to our whole business, which includes any other companies that it controls, such as its subsidiaries and affiliates. Privacy is very important to us, and we also understand that privacy is very important to you. This Privacy Policy tells you how we protect and use information that we gather through this web site. This Privacy Policy also apply to the other web addresses accessible from such site, including but not limited to the Continuous Glucose Monitoring System, Insulin Pump System, EasySense, EasyPatch, EasyTouch, EasyFollow App and EasyView Website and Services. You may refer to this privacy policy page when you visit those web sites.

This Privacy Policy was last revised on the date listed below in the "Changes to Privacy Policy" paragraph. We may change this Privacy Policy at any time and for any reason. We encourage you to review this Privacy Policy each time you visit the web site.

By using this web site, you agree to the terms of the most recent version of this Privacy Policy. Please read our Terms of Use to understand the general rules about your use of this web site. Except as written in any other disclaimers, policies, terms of use, or other notices on this web site, this Privacy Policy and the Terms of Use are the complete agreement between you and Medtrum with respect to your use of this and related web sites. Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Introduction

The information we receive, and how we use it, depends on what you do and the data you provide when visiting our web site. We collect and use Non-personal Information differently than "Personal Information", as defined and explained in detail below.

What is Non-personal Information?

For purposes of this Privacy Policy, "Non-personal Information" is defined as information we collect through this web site that does not identify, and cannot be used to identify, you or any Patients as individuals. It may include information such as the following:

• the type of web browser software you use (for example, Safari, Chrome, or Internet Explorer)

• the name of the domain from which you access the Internet

• the Internet address of the web site from which you linked directly to our web site

• the date and time you access our web site

• which pages you have visited on our web site

• the search terms you use

• the links on which you click

• "Personal Information" (as defined below) of the web site user that has been made completely anonymous, and therefore cannot be used to identify, reveal, or reference any individual user

• Personal Information, medical data, and/or health data of Patients that has been completely de-identified and made anonymous, and therefore cannot be used to identify, reveal, or reference any individual Patient

If you visit our web site to read or download information, such as information about the web site application, our products or our therapies, we may collect certain Non-personal Information about you from your computer. This information is collected from your computer's web browser. If you only read or download information on our web site, we do not collect or learn your name, e-mail address, home address, or other Personal Information about you. We may place a text file called a cookie in the browser files of your computer when you visit. The cookie may be stored on your computer's hard drive. The information that we collect using cookies is Non-personal Information. You are always free to decline our cookies if your browser permits, but some parts of our web site may not work properly for you if you do so. We will not allow third parties other than those companies that we hire to perform services or functions on our behalf to place cookies on or though our web site.

What does Medtrum do with Non-personal Information?

Because Non-personal Information (as defined herein) cannot be used identify you or any Patients, Medtrum may use such Non-personal Information for acceptable and reasonable clinical or business reasons, which comply with applicable laws and regulations. For example, we are always looking for ways to better serve you and improve this web site. We may also use Non-personal Information for appropriate customer service, research, or business purposes, to find advancements or improvements in our products or therapies.

For example, we may use Non-personal Information to:

• create reports for internal use to develop programs, products, services or content

• customize the information or services that are of interest to you or patients generally

• share with other parties that may have common business or health care interests

• analyze, aggregate, report, share, and/or utilize for clinical or therapy related reasons

What is Personal Information?

For purposes of this Privacy Policy, "Personal Information" is defined as information we collect through this web site that can be used to specifically identify you or individual Patients, including the following data elements:

• name, date of birth

• home address, telephone number

• e-mail address

• medical or health data

When utilizing the Medtrum mobile application available on this web site, you may also provide or upload Personal Information about your Patients, consisting of their medical and/or health data as well as certain demographic information (for example, the name, address, date of birth, etc.).

Location services permission is required for Android users to allow for Bluetooth pairing to Medtrum Continuous Glucose Monitoring Device and Insulin Pump. This information will only be used for allowing Bluetooth access. This information will NOT be processed for any other intended purposes.

How does Medtrum keep and use Personal Information?

Medtrum may keep and use Personal Information about you or your Patients for appropriate purposes such as improving customer service, analysis, improving or advancing Medtrum products and therapies, studies or publications, and other reasonable and legitimate purposes that are in compliance with applicable laws. With respect to you as the web site user, your Personal Information may be kept and used to:

• Respond to your requests

• Personalize your access to our web site, for example, by telling you about new features that may be of interest to you

• Enforce this Privacy Policy and other rules about your use of this web site

• Protect our rights or property

• Protect someone's health, safety or welfare

• Comply with a law or regulation, court order or other legal process

The Personal Information you provide about Patients may be used:

• To develop records or reports of their personal, medical or health data, as appropriate for using the Medtrum EasyTouch application

• For analytical purposes, including to analyze, develop, and improve Medtrum programs, products, services, and content

• To remove all Personal Information and identifiers (name, address, date of birth, e-mail address, social security number, and any other element of individually identifiable information). Once we have completely removed all such information so that it is completely anonymous and cannot be used to indentify or reference any individual Patient, it is considered "Non-personal Information" as defined herein, and may be utilized as Non-personal Information (described above).

• To protect our rights or property

• To comply with a law or regulation, court order or other legal process

In order to provide you with more convenient, high-quality and personalized products and/or services and strive to improve your experience, we may collect and use your personal information in the following additional services provided to you. If you do not provide this information, it will not affect your basic service of using our products or services, but you may not be able to obtain the user experience that these additional services bring to you. These additional services include:

Additional services based on cameras: You can use this function to scan QR codes to pair the product after enabling the camera permissions

Additional services for photo/video access and uploading based on albums (photo library/video library): You can use this function to upload your photos/pictures/videos after enabling the album permission to change avatars, share or provide consultation.

With your understanding and consent, the above additional services may require you to enable access to your camera (camera), photo album (photo library) in your device in order to collect the information involved in these permissions and use. You can check the status of the above permissions item by item in your device settings, and decide whether to turn these permissions on or off at any time. Please note that if you enable any permission, you authorize us to collect and use relevant personal information to provide you with corresponding services. Once you disable any permission, it means that you cancel the authorization, and we will no longer continue to collect based on the corresponding permission. and the use of related personal information, it cannot provide you with the services corresponding to this permission. However, your decision to close the permission will not affect the previous collection and use of information based on your authorization.

Does Medtrum ever share Personal Information with third parties?

Medtrum will not share any Personal Information about you or any Patient collected from this web site with any unrelated third party without your express permission.

We may be legally compelled to release Personal Information in response to a court order, subpoena, search warrant, law or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting web site visitors who violate our rules or engage in behavior which is harmful to other visitors (or illegal).

We may disclose Personal Information to third parties if we feel such disclosure is necessary to:

• enforce this Privacy Policy and the other rules about your use of this web site

• protect our rights or property

• protect someone's health, safety or welfare

• comply with a law or regulation, court order or other legal process

Please note

In addition to the ways that we may keep, disclose, and use information described in this Privacy Policy, we also may keep, disclose, and use Personal Information that you give us through this web site in ways that we believe are consistent with applicable government guidance, directions, regulations, and laws.

What about web site security?

Security is very important to us. We also understand that security is important to you. We take reasonable steps to protect all Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, e-mail sent to or from this web site may not be secure (for example, when sending a message to our customer service office through this website site), and you should therefore take special care in deciding what information you send to us via e-mail and avoid including any Patient information.

How to contact Medtrum

If you have any questions, comments, or concerns about this Privacy Policy or the information practices of this site, please contact us as follows:

Changes to Privacy Policy

This Privacy Policy was last updated on May, 2022. If this Privacy Policy is revised, the most current policy will be posted on this site. Please check back periodically, and especially before you provide any personally identifiable information.