Privacy Policy

1. Salveo Therapeutics

Salveo Therapeutics Pvt Ltd ("we") are committed to protecting and respecting your privacy. We are registered in Singapore and India, and have in place a comprehensive Company data protection policy and code of practice. This Privacy Policy ("Policy") (together with our Terms and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and how you can get access to this information. Please review it carefully.

2. Purpose of this Policy

Salveo provides you (the "User") with access to the My Sickle Care mobile application (the "App"). To use the App, you may be required to create or update an account (“Account”) and will be asked to provide certain personal information, which may include your name, gender, birth date, and e-mail address.If you are under 16, your parent or guardian must review and accept the terms of this Agreement, and by using the App, you confirm that your parent or guardian has so reviewed and accepted this Agreement. We may collect and process information provided by filling in forms on the App, including information provided during completion of surveys and other online tools, posting of comments in the Community or requesting further services, and when you report a problem with our App. If you contact us, we may also keep a record of that correspondence. My Sickle Care app also collects and processes data with activity trackers (which track your steps and sleep) in the smartphone. Throughout your use of the app we may collect and process information such as: personal information (name, date of birth, address, email, phone number, height, weight, sleep); lifestyle (body mass index, activity, water intake status, sleep, pain etc); other health profile information and details of your visits to the App and the resources that you access (including, but not limited to, traffic data, location data, weblogs, other communication data, and the resources that you access). Your data (steps per day and weight) may also be collected via Google Fit upon installing Android app. This consent will be explained and obtained from you within the app and you may revoke this access at any point within your phone's operating app settings. Your data (name, weight, email, phone number) may also be provided to us by your hospital or centre in order to refer you to the App, e.g. provided through your sickle cell clinic or local clinic. If this is the case, this consent will be explained and obtained from you separately. The information described in this Policy that is collected through either the App, Google Fit, or your patient record is known as "personal data". But don't worry, we are required by law to maintain the privacy of your personal data and to provide you with this notice of our legal duties and privacy practices with respect to your personal data.

3. Acceptance of terms

Please read this Agreement carefully. By creating an account or accessing or using the App, you acknowledge that you accept and agree to be bound by the terms of this Agreement. If you do not agree to these terms, you may not access or use the app.We may modify this Agreement from time to time. We will notify you by email, through the App, or by presenting you with a new version of the Agreement for you to accept if we make modifications that materially change your rights. Your continued use of the App after the effective date of an updated version of the Agreement will indicate your acceptance of the Agreement as modified.

4. Medical services disclaimer

The company is not a licensed medical care provider and the app is not intended to replace professional medical advice or diagnose, treat or manage any illness or medical condition, sickle cell disease treatment or complications arising out of sickle cell disease. Please consult with a licensed physician or other qualified healthcare provider before making any decisions or taking any actions that may affect your health and safety or that of your family members or fetus. Never disregard professional medical advice or delay in seeking it because of something you have read in connection with the app. Always consult with your healthcare professional if you have any questions or concerns about your health or condition or experience any changes in your condition or health status. if you think you have a medical emergency, go to the nearest open hospital , clinic or emergency room immediately. Wedisclaim liability for any errors or omissions, or for unintended technical inaccuracies, or typographical errors in the provided materials, as well as violation of any ethical or moral standards applicable in your community to education and related materials.

5. The Use and Disclosure of Personal Data

My Sickle Care is dedicated to maintaining the privacy and integrity of your personal data. As such, we have policies and procedures and other safeguards to help protect your personal data from improper use and disclosure. The lawful basis for which My Sickle Care processes personal data is consent. We follow a Minimum Necessary Access Policy so any required disclosure of your identifiable information is minimized. The following categories describe different ways that we use your personal data within My Sickle Care and disclose your personal data to persons and entities outside of My Sickle Care. We have not listed every use or disclosure within the categories below, but all permitted uses and disclosures will fall within one of the following categories. In addition, there are some uses and disclosures that may require your specific authorization. How much personal data is used or disclosed without your written permission will vary depending, for example, on the intended purpose of the use or disclosure. • Disclosure at your request: We may disclose information relating to your use of the App when requested by you. This disclosure at your request may require written authorization by you. • Operations: We may use and disclose your personal data for our internal operations, which include administration, planning and various activities that assess and improve the quality. Examples are using information about you to improve quality of the app, satisfaction surveys, de-identifying personal data, and internal training. • Reminders and notifications: We may use and disclose your personal data to contact you as a reminder to interact with, or complete tasks relating to your use of the App. • Threat to health or safety: We may use and disclose your personal data when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat. • As required by law: Certain laws permit or require certain uses and disclosures of personal data for example, for public health activities, health oversight activities and law enforcement. In these instances, My Sickle Care will only use or disclose your personal data to the extent the law requires. • For research and publicity purposes: We may use personal data for internal and external research and publicity purposes. This may include publishing aggregate, anonymous information about our users in the context of providing public information and conducting academic research. • Transfer of business assets: If My Sickle Care or substantially all of its assets are acquired by a third party, personal data held by it about its customers will be one of the transferred assets.

6. Where we store your personal data

All information and data you provide to us is stored on secure servers with trusted 3rd party suppliers. All passwords are stored in encrypted form and all traffic is transmitted securely via SSL by default. However, it may be possible that your anonymised data is transferred to, and stored at, a destination outside the EEA – such as Google Analytics. By submitting your personal data, you agree to this transfer, storing or processing. Unfortunately, despite these measures, the transmission of information via the internet is never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the App, and any transmission is at your own risk. Once we have received your personal data, we will use strict procedures to try to prevent unauthorized access in accordance with our Company data protection policy and code of practice, and responsibilities as a registered Data Controller in India.

7. Your rights regarding your personal data

You have certain rights with respect to your personal data. If we do not agree to a request by you with respect to your personal data, please consult the My Sickle Care Privacy and Security Officer whose contact information is below. If we do not comply with any of the below, you have the right to complain to the ICO and to a judicial remedy without undue delay and at the latest within one month. • Restrictions: You have the right to request in writing that we do not disclose certain information about you. To request a restriction, please contact the Privacy and Security Officer whose contact information is below. • Confidential Communications: You have the right to request in writing that we restrict the way in which we communicate information regarding your health and health care services, such as ceasing to send email or SMS messages to notify or remind you about aspects of the App or your progress through the My Sickle Care program. We will make every effort to accommodate your request. • Access: You have the right to inspect and copy your personal data maintained by us. Normally, we will provide you with access within one month of your request. To request your data: • Please download a subject access request form here, fill it in and return it to us using the contact details on the form, along with copies of information that confirms your identity (if applicable). Please do not send in any original copies of documents. More details of acceptable types of identification documents are included in the application form. • You can email your completed form and electronic copies of your identification documents to: info@salveo-therapeutics.com • Deletion: You have the right to ask that we delete all information that the App has collected on you via email to the My Sickle Care privacy and Security whose contact information is below. • Amendment: You have the right to request that we amend your written personal data. For instance, you can request that we correct an incorrect date of birth in your records. We will amend your personal data within one month of your request, and will notify you when we have amended your personal data. We can deny your request in certain circumstances, such as when we believe that your personal data is accurate and complete. • Accounting: You have the right to request an accounting from us of certain disclosures made by us. We will provide you with your accounting within one month of your request. In addition, we will notify you as required by law if there has been a breach of the security of your personal data. • Data Portability: You have the right to obtain and reuse your personal data from My Sickle Care for your own purposes across different services. This can be freely downloaded in .csv format within the settings page of your My Sickle Care account. • Objection: You have the right to object to processing based on legitimate interests or the performance of a task in the public interest, to direct marketing, and to processing for the purposes of scientific research & statistics. To request an objection, please contact the Privacy and Security Officer whose contact information is below. • Automated Decision Making & Profiling: You have the right not to be subject to a decision based on automated processing and it produces a legal effect or a similarly significant effect on you. To request an opt-out of automated decision making & profiling, please contact the Privacy and Security Officer whose contact information is below.

8. Data Retention

As per the ICO's 'Principle 5', we retain personal data no longer than is necessary for the purpose we obtained it for. With the context that your personal data may be used for research purposes (as covered in section 3), My Sickle Care will retain any information held on an individual for up to 10 years after that individual has ceased use of the App. At that point, the individual's information will be deleted. As covered in section 5, you may request that we delete your data at any time.

9. Data Breach

My Sickle Care information apps are highly protected, encrypted, and secure - but no app is completely impenetrable. My Sickle Care has procedures and tools in place to detect, report, and investigate a data breach. When a breach may result in a high risk to your rights and freedoms, we will notify you.

10. Amending this Policy

We reserve the right to revise this Policy and to make the revised Policy effective for all personal information that we created or received prior to the effective date of the revised Policy. If you are a registered user, we will notify you of changes by the email address we have for you on file. Effective Date: This Policy is effective as of November 1st 2020. Terms and Conditions, including Disclaimers This document (the "Agreement") is a legally binding agreement between you and Salveo Therapeutics Pvt Ltd, a company registered in India My Sickle Care) that governs your use of the mobile services associated with My Sickle Care (app). For ease of reference, all the features and functionality of the App with all its content (whether accessible wirelessly, electronically or downloadable for printing), shall be referred to herein as the "App". Various components of the Appare the self-help lifestyle improvement programs with associated expert content, tools, healthcare tracking technology, and online community (the " My Sickle Care"). The terms "we", "us", "our" and "ours" when used in these terms mean My Sickle Care, which includes any parent company, subsidiaries, branches or affiliates under common ownership or control of My Sickle Care. The terms "you", "your" and "yours" when used in these terms mean any user of the App.

11. Contract Information

By using the App you confirm that any registration information that you submit to My Sickle Care is true, accurate and complete, that you will update such information in order to keep it current, that you have read and agree to the terms and conditions contained in this Agreement, our Privacy Policy and our Posting Policy (both of which are hereby incorporated into this Agreement) and that you shall be legally bound by such terms subject to all applicable laws and regulations.

12. Understanding My Sickle Care

You acknowledge and agree that the My Sickle Care Service is a personalized self-help app designed to help you improve your own wellbeing and that if you choose to access the My Sickle Care Service you are solely responsible for deciding which of the suggested techniques you put into practice and how to apply those techniques. You also acknowledge and agree that My Sickle Care is not a medical organisation and that the My Sickle Care service is not intended to diagnose, treat or otherwise address any medical problem. The material on the App, whether posted by SalveoTherapeutics Pte Ltd employees, or other users, is provided for your information and not as medical advice and should not be seen as a replacement for consultation with a doctor or other qualified care professional.

13. Changes to the Agreement

My Sickle Care reserves the right to vary this Agreement from time to time by amending this page. Registered user's will be notified of changes by the email address we have for you on file. Any material amendments intending to bind an existing user of the App shall become effective 7 days after the email.

14. Your health and My Sickle Care

This programme is intended as a lifestyle change guide and is therefore not classified as a medical device, meaning the programme should not replace any existing recommendations that have been given by a health care professional. The content is not intended to be a substitute for professional medical advice, support, diagnosis, or treatment. Care has been taken to confirm that the information presented by authors is accurate and describes generally accepted practices. If we find, or are alerted to, a mistake, we will correct it as quickly as possible. However, to the fullest extent permitted by applicable laws, the authors, editors and publishers are not responsible for errors or omissions, or for any consequences arising from application of the information on the App, and make no warranty, express or implied, with respect to the contents, completeness or accuracy of the material published.

15. Privacy

We process information about you in accordance with our Privacy Policy. By using the App, you consent to such processing and you warrant that all data provided by you is accurate. To access the My Sickle Care, you may be required to register personal information and establish unique usernames and passwords. You are responsible for maintaining the confidentiality of any passwords, and are fully responsible and or liable for all activities that occur under your password and username, whether by you or by anyone else using your identity. Should your password be compromised by breaches of security such as, but not limited to, loss, theft and unauthorized disclosure, it is your responsibility to immediately notify us of the need to change or deactivate the password. Until we are so notified you will remain liable for any unauthorized use of your account. The App contains functionality that allows you to upload content in a public area (including, but not limited to, your online group). By submitting such content, you agree that such submission is non-confidential for all purposes. Additionally you automatically grant us, or warrant that the owner of such content or intellectual property has expressly granted us, a royalty free, perpetual, irrevocable, world-wide nonexclusive license to use, reproduce, create derivative works from, modify, publish, edit, translate, distribute and display the content in any media or medium, in any form, format or forum now known or hereafter developed. If you wish to keep any such information private, do not submit them to a public area or email us as soon as possible. You are solely responsible for any content you submit to a public area, the consequences of posting such content, and your reliance on any other content found in your online group.

16. Community posts

Community posts is a special feature of the App that allows users to communicate with each other on a set of different topics related to Sickle Cell Disease and wellbeing. All user comments in the community posts are posted anonymously. If you delete your account, your comments will remain visible to other users of community . As a user of community posts, you shall not: • Leave rude, harassing, insulting, provocative, discriminating, non-tolerant, religious, racist, political, homophobic, or offensive comments and statements; • Post abusive, offensive, obscene, pornographic, infringing, sexually explicit images or any other materials (including links to such materials) prohibited under applicable law or regulations or that otherwise may be in conflict with this Agreement; • Provide any medical advice or claim to be a healthcare professional; • Advertise any product or service; At our sole discretion, we reserve our right to: • Delete any inappropriate or irrelevant comments or materials; • Delete or modify comments containing personal data, such as name, address, or email; • Restrict or ban your access to community posts at any time and without notice if we determine that the content or use of community posts is in violation of this Agreement; • Use, copy, modify, reshuffle, move, change, publicly display, publicly conduct and distribute discussions, comments, and materials; • Block your comments for any reasons or moderate them as we deem appropriate; • Disable community posts at any time without prior notification. Any information posted in community posts shall not be considered as advice, drug prescription, or treatment suggestion. If in doubt about your health, consult a licensed healthcare professional. Please bear in mind that our users are not healthcare professionals and their recommendations may not only be inaccurate, but also harmful to your health and well-being.

17. Intellectual Property Rights

The layout, design, content and graphics on the My Sickle Care App are protected by Indian and Singapore copyright laws. Unless expressly permitted in writing and other than printing a small proportion of content or displaying this on your screen or both, (strictly for your personal non-commercial use), no part of the App may be reproduced or stored in any medium, including but not limited to a retrieval app, or transmitted, in any form or by any means (electronic, mechanical, photocopying, recording, broadcasting), nor shown in public. You may not create any derivative work or make any other adaptation, without our prior written consent. You must not modify the copies you have displayed or printed in any way and you may not use any illustrations, photographs, videos or audio sequences or any graphics separately from any accompanying text. If you print off or download any material from the App in breach of these terms of use, your right to use the App will cease immediately and you must at our option return or destroy any copies of the materials you have made. All rights not expressly granted in these terms or any express written license, are reserved. For all other uses of our content or images you must contact us and obtain our prior written permission.

18. Prohibited uses

You agree that you will not use the App to: • Upload, post, email or otherwise transmit any content or materials that are unlawful, harmful, threatening, abusive, harassing, tortious, defamatory, vulgar, obscene, libellous, invasive of another's privacy, hateful, or racially, ethnically or otherwise objectionable, at our sole and absolute discretion; • Harm minors in any way, or solicit or otherwise attempt to gain any information from a minor; • Impersonate any person or entity, including, but not limited to, any user of this App, a director, officer, employee, shareholder, agent or representative of My Sickle Care or our affiliates, or any other person or entity, or falsely state or otherwise misrepresent your affiliation with My Sickle Care , our affiliates or any other person or entity • Forge headers or otherwise manipulate identifiers in order to disguise the origin of any Postings or other materials transmitted to or through the App • Upload, post, email or otherwise transmit any materials that are not your own, or that you do not have a right to upload, post, email or otherwise transmit under any law or under contractual or fiduciary relationships (such as insider information, proprietary and confidential information learned or disclosed as part of employment relationships or under nondisclosure agreements) • Upload, post, email or otherwise transmit any content or other materials that infringe upon any patent, trademark, trade secret, copyright, right of privacy or publicity or other proprietary rights of any party • Upload, post, email or otherwise transmit any unsolicited or unauthorized advertising, promotional materials, "junk mail," "spam," "chain letters," "pyramid schemes," or any other form of commercial solicitation except in the areas, if any that are specifically designated for such purpose • Upload, post, email or otherwise transmit any content or other materials that contain software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment • Disrupt the normal flow of dialog, cause a screen to "scroll" faster than other users of the App are able to type, or otherwise act in a manner that negatively affects or otherwise diminishes the quality of another user's experience of this App • Interfere with or disrupt the App or servers or networks connected to the App, or disobey any requirements, procedures, policies or regulations of networks connected to the App • Intentionally or unintentionally violate any applicable laws and/or regulations • "Stalk" or otherwise harass another user of the App and/or any employee of My Sickle Care • Solicit, collect or post personal data or attempt to solicit, collect or post personal data about other users of the Website from the Website (including user names or passwords) or about any other third party, and/or: o Access or attempt to access another user's account without his or her consent. o Knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware. You also agree not to: • Reproduce, duplicate, copy or re-sell any part of the App in contravention of the provisions of this Agreement. • Frame the App or any part of it. • Copy any material obtained from the App to peer to peer networks or other web sites or web services. • Access without authority, interfere with, damage or disrupt any part of the App; any equipment or network on which the App is stored; any software used in the provision of the App; or any equipment or network or software owned or used by any third party.

19. Breach of the Agreement

We will determine, in our absolute discretion, whether there has been a breach of this Agreement through your use of the App. When a breach of this Agreement has occurred, we may take such action as we deem appropriate, which may include all or any of the following actions: • Immediate, temporary or permanent withdrawal of your right to use the App and/or the My Sickle Care Service. • Immediate, temporary or permanent removal of any posting or material uploaded by you to the App and/or the My Sickle Care Service. • Issue a warning notice to you to immediately cease and/or remedy such breach and following receipt such action should be taken immediately. • Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach. • Any further legal action against you. • Disclosure of such information to law enforcement authorities as we reasonably feel is necessary. We exclude liability for actions taken in response to breaches of this Agreement. The possible actions we may take on breach of this Agreement are not limited to those described here, and we may take any other action we reasonably deem appropriate.

20. No warranty

The use of the App (including but not limited to their content and features) is at your own risk. The App is provided on an "as is" and "as available" basis. To the extent permitted by applicable law, My Sickle Care gives no warranty, express or implied, as to the quality, content and availability or fitness for a specific purpose of the App or the My Sickle Care or to the accuracy of the information contained in any of the materials on the App. My Sickle Care shall not be liable to any person for any loss or damage of any kind, which may arise, directly or indirectly from the use of or inability to use any of the information contained in any of the materials on the App. There is no guarantee of availability of information on the App at any time, nor that it is up to date or error-free. As with any purchase of a product or service through any medium or in any environment, you should use your judgment and exercise caution where appropriate. No advice or information whether oral or in writing obtained by you from My Sickle Care shall create any warranty on behalf of My Sickle Care in this regard. Certain jurisdictions do not allow the exclusion or disclaimer of certain warranties. Accordingly, some of the above disclaimers may not apply to you. Your statutory rights as a consumer, if any, are not affected hereby.

21. Limitation of liability

To the fullest extent applicable permitted by applicable laws, My Sickle Care, its affiliates, officers, directors, employees, licensors or any third parties exclude liability for any direct, indirect, incidental, special or consequential damages (including but not limited to any loss of data, service interruption, computer failure or pecuniary loss, loss of income or revenue, loss of business, loss of profits or contracts, loss of anticipated savings, loss of data, loss of goodwill, wasted management or office time and for any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable) arising out of the use of or inability to use the App, even if you have advised My Sickle Care about the possibility of such loss, and including any damages resulting therefrom. Commentary and other materials posted on the App by other users are not intended to amount to advice on which reliance should be placed. We therefore, to the fullest extent permitted by applicable laws, disclaim all liability and responsibility arising from any reliance placed on such materials by any visitor to the App, or by anyone who may be informed of any of its contents. Any claims arising out of or in connection with your use of the App must be brought within one year of the date of the event giving rise to such action occurred. Nothing in this provision affects our or our contractors' liability for death or personal injury arising from our (or their) negligence nor our (or their) liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter nor any other liability which cannot be excluded or limited under an applicable law.

22. Technology limitations and modifications

My Sickle Care will make reasonable efforts to keep the App operational. However, certain technical difficulties, maintenance, or any other cause beyond our reasonable control (including (but not limited to) failure of the internet, natural disaster, labour shortage or dispute, or governmental act) may, from time to time, result in interruptions. My Sickle Care reserves the right at any time and from time to time to modify or discontinue, temporarily or permanently, functions and features of the App with or without notice. You agree not to hold us liable for any such failure or delay in performance and we agree to make all reasonable efforts to restore the App (or any part thereof) as soon as practicable.

23. Third parties

Certain hypertext links in this site may lead to other third party websites, which are not under the control of My Sickle Care . When you activate any of these you will leave the App and My Sickle Care has no control over, and will accept no responsibility or liability, for the material on any website which is not under the control of My Sickle Care . My Sickle Care does not make any representations or give any guarantee or warranties of any kind, expressed, implied or otherwise about the content of on any external website link.

24. Indemnity

You agree to indemnify and hold My Sickle Care and its officers, directors, employees and licensors harmless from any claim or demand (including but not limited to reasonable legal fees) made by a third party due to or arising out of or related to your violation of the terms and conditions of this Agreement or your violation of the App (and all related materials) or any applicable laws, regulations or third party rights.

25. Assignment by My Sickle Care

My Sickle Care may assign (or otherwise transfer) this Agreement or any part of it without restrictions. You may not assign (or otherwise transfer) this Agreement or any part of it to any third party.

26. Entire agreement

This Agreement (incorporating these terms and the Privacy Policy and the Posting Policy as may be updated from time to time) constitutes all the terms and conditions agreed upon between you and My Sickle Care and supersede any prior agreements in relation to the subject matter of this Agreement, whether written or oral. Any additional or different terms or conditions in relation to the subject matter of this Agreement in any written or oral communication from you to My Sickle Care are void. You agree and accept that you have not accepted the terms and conditions of this Agreement in reliance of or to any oral or written representations made by My Sickle Care not contained in this Agreement.

27. Term and termination

This Agreement is between you and us only and will become effective when you start using the App and will remain effective until terminated by you or My Sickle Care. My Sickle Care reserves the right to terminate this Agreement or suspend your My Sickle Care account at any time in case of unauthorized, or suspected unauthorized use of the App whether in contravention of this Agreement or otherwise. If My Sickle Care terminates this Agreement, or suspends your My Sickle Care account, for any of the reasons set out in this section, My Sickle Care shall have no liability or responsibility to you whatsoever.

28. Governing law and disputes

The App is controlled by My Sickle Care from its office in Mumbai. Access to, or use of, the App, including the My Sickle Care Service and any related information and materials, may be prohibited by law in certain jurisdictions. You are responsible for compliance with all applicable laws of the jurisdiction from which you are accessing the App. We make no representation that the information contained herein is appropriate or available for use in other locations. This Agreement and any contract between us, whether for use of the App or other purpose, and any non-contractual obligations (if any) arising out of or about these terms and conditions or any such contract will be governed by Indian law.

29. Contact

You can contact us via the following details: • Email: info@salveo-therapeutics.com Please note that we are unable to answer any enquiries requesting medical advice. Such enquiries should be addressed to an appropriate, qualified health practitioner. Effective Date: This document is effective as of November1st2020.