Carallel Privacy Policy

Carallel, Inc. (“Carallel”) cares about your data privacy. Our goal is to allow you to use our services with an understanding of our privacy practices. Please take the time to review this Privacy Policy and our Terms of Use for the Carallel Caregiver Application, Carallel.com website and other Carallel websites (“Terms of Use”).

This Privacy Policy governs your use of Carallel.com, the Carallel Caregiver Application (“Caregiver App”) and any other digital offerings that we provide (collectively, “Digital Tools”), the caregiver support services provided by our Care Advocates (“Caregiver Support Services”), and any other products or services that we provide, including all Content provided by us directly or through your employer, health plan or other third party sponsor on or through the Digital Tools or the Caregiver Support Services (collectively, the “Services”). By using our Digital Tools or any other Services, you are acknowledging that you have read, understood, and accept our Privacy Policy. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY NOT ACCESS OR USE THE DIGITAL TOOLS OR ANY OTHER SERVICES.

This Privacy Policy does not extend to anyone whose personal information is not under our control or management, including data that is collected by other websites that you may visit before or after the Digital Tools, and that are not governed by this Privacy Policy. We are not responsible for the data protection or privacy policies of any other websites, and accept no responsibility or liability for their practices or policies. Please carefully check the policies of other websites and services you use before you visit or submit personal information.

Our Digital Tools and other Services are directed only to United States residents.

I. Personal Information We Collect and Receive.

A. Personal Information We Collect and Receive. In order for you to access and use our Digital Tools and other Services, we may collect and process certain types of personal information as you interact with us. Depending on your activities on our Digital Tools and other Services this may include:

1. Personal information you provide to us directly or that others provide about you or the person for whom you are a caregiver (a “care recipient”), such as name, address, email address, phone number, username, password, date of birth, race, medical information, and health information;

2. Transaction information you provide to us or that others provide about you, such as information about the Services purchased, used, obtained, considered, or other consumer-related purchasing data;

3. Information about your activity when using our Digital Tools and other Services. This may include information we collect from the device you use, such as your IP address, the type of device or browser you use, information about your interaction with the Digital Tools and Services, including applications, widgets, and any marketing;

4. Information about your geolocation, such as physical location based on IP address, device data, or region;

5. Information related to the health plan or health insurance for you or the care recipient;

6. Professional or employment information you provide to us directly or that others provide about you;

7. Physical characteristics or descriptions. For example, if you upload a photograph of yourself or your ID; and

8. Inferences we draw from your personal information, such as a profile reflecting your preferences, characteristics, and behavior with our Digital Tools or Services.

Please note that personal information for the purposes of this Privacy Policy does not include aggregate information from which individual identities have been removed.

B. Personal Information from Children. Carallel does not knowingly solicit or collect any personal information from anyone under 13 years of age, and children under 13 are not permitted to register for or use our Digital Tools or other Services, including by subscribing to receive information from Carallel. If we become aware that a child under the age of 13 has provided us with their personal information, we will delete it.

II. How We Collect Personal Information.

Carallel collects personal information directly from you. In order to provide the Services, Carallel also frequently receives personal information about you from others, such as from your employer, health plan or other sponsor, or from individuals who are caring for you or are a care recipient, as further described below:

A. Personal Information You Provide Directly. We collect your personal information that you provide to us directly when you take actions such as filling out a form in our Digital Tools; registering for an account with us; contacting us by email, letter, phone, or chat; interacting with us on social media or in support groups, webinars or surveys; interacting with our Digital Tools or other Services; or engaging in a transaction with us.

B. Personal Information Provided About You. We also collect personal information about you provided to us by others in order to enable you to use or benefit from our Services. Please see some common examples below:

1. Insurers may partner with Carallel to provide access to our Services to their insureds. Your insurance company may authorize us to collect or provide us with your personal information to facilitate your use of our Services.

2. Employers may offer our Services as a benefit of employment. Your employer may authorize us to collect or provide us with your personal information to facilitate your use of our Services.

3. If you are a caregiver or a care recipient, other caregivers or family members may provide us with your personal information, including your health and medical information, in order to make use of the Services and/or care for you.

4. If you are a caregiver, other caregivers or family members may provide us with your personal information so that you can access the Services, stay informed about a care recipient, and/or provide care to a care recipient.

5. Care recipients themselves may also provide us with your personal information. For example, a care recipient may provide the personal information of one of their caregivers or family members to give them access to the Services so that they can stay informed and/or participate in providing care.

Please note that if you are sharing someone else’s personal information with Carallel, you must be legally authorized to share such information on their behalf.

C. Automatically Collected Personal Information – Cookies and Trackers. We or our partners may use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) across the Digital Tools, Services, and devices. Cookies are also used to enable certain website features and functionalities. For more information, please see our Cookie Policy.

III. How We Use Personal Information.

Carallel may use the personal information we collect for the following purposes:

A. To meet any contractual obligations with you;

B. To provide and deliver our Services and Digital Tools and related support;

C. To allow you to log into and access your account;

D. To process any purchases, transactions, or payments made through our Digital Tools;

E. To keep your information and our systems secure such as by detecting security incidents, and to be able to verify your identity and contact information;

F. To alert you about updates, special offers, and other news, services, and information from us, our partners, or others;

G. For testing, research, analysis, and product development, including to develop and improve our content, Digital Tools, and Services;

H. To ensure our content, Digital Tools, and Services are functional, efficient, and relevant to you and your interests;

I.To respond to your inquiries and requests;

J.To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations; and

K. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.

IV. How Personal Information May Be Disclosed.

Carallel does not sell or rent any of your personal information, and we do not share your personal information without ensuring it is protected with appropriate levels of security and confidentiality. We only disclose your personal information for the following business and operational purposes:

A. To caregivers and others with access to the Services on a care recipient’s behalf: We disclose and make available a care recipient’s personal information to those who use the Services to assist or stay informed about that care recipient.

B. To third parties in order to fulfill your requests: To provide you with the Services you request, we may disclose your personal information to third parties. For example, if you request us to identify assisted living options, we may disclose your personal information to third parties to gather information about those options for you. These third parties may communicate with you directly. If you do not wish to receive communications from these third parties, you must contact the third parties directly. Carallel does not control how these third parties use or disclose your personal information.

C. To insurers, employers or other sponsors that we partner with: We may disclose certain personal information to insurers or employers to verify eligibility for our Services, to track usage of our Services, or to help identify care recipient or caregiver needs, preferences, characteristics, demographics or contact information.

D. To our service providers: We rely on certain trusted third-party service providers to provide, process, improve, promote, or protect our Digital Tools and other Services. These service providers do things like help us store your data, process payments you may make to us, deliver the Digital Tools and/or other Services to you, improve our marketing, and secure our systems.

E. To other entities related to Carallel: We may disclose personal information to our related companies, such as affiliates, subsidiaries, or other companies under common control with us.

F. In the event of a change in control: We may disclose personal information to other companies for the purpose of evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.

G. As necessary or otherwise required by law: We also reserve the right to disclose personal information when it is reasonably necessary to conduct our business, protect Carallel’s legal rights and property, and to comply with the law.

V. Protection of Your Personal Information.

We take the security of your personal information seriously. Carallel has therefore put in place commercially reasonable physical, electronic, and managerial procedures to safeguard and secure the personal information that we collect.

Please remember, however, that the safety and security of your personal information also depend on you. Where you have chosen, or where we have given you, a user name and password for access to certain parts of the Digital Tools and Services, you are responsible for keeping the user name and password confidential and for using secure connections. No method of transmission over the internet or electronic storage is completely secure, so Carallel cannot guarantee its absolute security.

VI. Control over Your Personal Information.

You may access, correct, and delete much of the personal information we process about you within your account for the Digital Tools and/or Services. Please be aware that if personal information is deleted from the Services, you may lose access or functionality relating to the Services.

VII. Data Transfers.

BecauseCarallelis a US-based company, your personal information may be collected and processed in the United States.

VIII. Mobile and Email Notifications.

We try to give you the ability to opt-in/opt-out to any marketing communications we may send. . You may also elect to receive certain marketing communications in accordance with your preferences. We will provide you with an opportunity to opt-out and/or unsubscribe from such marketing communications.

Regardless of your marketing communication preferences, we may still contact you for transactional, operational, or informational purposes, such as for customer service, reminders, or information regarding the Services you are using.

Please note that if you wish to opt-out of communications with your third parties such as your employer, health plan or other Sponsor, or others whom Carallel has contacted on your behalf, you must contact them directly. Carallel does not have responsibility for or control over the communications practices of your employer, health plan or other Sponsor, or any third parties.

IX. Retention.

We will keep your personal information for as long as is necessary to perform the processing activity for that information, as long as is set out in any relevant contract you hold with us, or as required or allowed by law. The relevant retention period is determined on a case-by-case basis because it depends on things like the nature of the data, why it is collected, why it is processed, and any legal or operational retention needs. For example, we may retain your data for as long as you use our Services. Please be aware that forty-five (45) days after the relevant processing activity has been completed, we may destroy your data, or alternatively anonymize the data such that the data is not personally identifiable. We are not responsible to you for the deletion or destruction of your personal information after such forty-five (45) day period unless we have received your written request for an additional retention period after the initial forty-five (45) days, and we have agreed to such request. Otherwise, we do not have any obligation or liability to you or any other party with respect to personal information that is deleted.

X. Special Notice to Nevada Residents.

We do not sell, rent, or lease your personally identifiable information to third parties. However, if you are a resident of Nevada and would like to submit a request not to sell your personally identifiable information, you may do so by emailing us at legal@carallel.com.

XI. Questions, Comments, or Complaints.

If you have questions or comments about this Privacy Policy, we invite you to contact us at legal@carallel.com. If you have an applicable disability,you may also contact usat the above email addressto request access to this Privacy Policy in an alternative format.

XII. Updates and Changes to this Privacy Policy.

This Privacy Policy is effective as of February 12, 2025. We may update this Privacy Policy from time to time. Any updates to this Privacy Policy will not apply retroactively. By continuing to use our Digital Tools and/or other Services after a change, you are accepting the terms of this Privacy Policy.