Effective Date: 16 August 2021

vTail is a company registered in England and Wales (Company No. 12646131) with its registered office at 264 Banbury Road, Summertown, Oxford OX2 7DY, United Kingdom.

vTail has created this Privacy Notice to explain our privacy practices with respect to how we collect, use, disclose and otherwise process personal information in connection with operating our business well as the choices available to individuals regarding such personal information. Our services are not intended for personal or household use. Accordingly, we treat all personal information covered by this Privacy Notice, including information about any visitors to our website, as pertaining to individuals acting as business representatives, rather than in their personal capacity.

If you are using our services on behalf of one of our enterprise customers, vTail’s processing of personal information is governed by our customer agreements. In the event of any conflict between this Privacy Notice and a customer agreement, the customer agreement will control to the extent permitted by applicable law.

We provide important information for individuals located in the, European Economic Area, United Kingdom, and Switzerland below in the “Notice to European users” section below.

Information We Collect

Information you provide to us when you use our services. This may include personal information that you provide when you:

• Register for an account or create a user profile (such as first and last name, email address, telephone number(s), employer name, department and job title, device ID, and profile picture);

• Upload content to the services;

• Grant vTail access to your contacts;

• Participate in a chat when using the services;

• Provide feedback for our product;

• Comment on our blog;

• Participate in a competition, promotion, or survey;

• Contact customer support or otherwise correspond with us by phone, email, or other means.

Information provided to us by other users of our services. Other users of our services may provide certain information, including contact information, about you and other users to facilitate connections and communications with them.

Third parties or publicly available sources. We may receive personal information about you—such as identity and contact information—from various third parties and public sources, including analytics providers and search information providers.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with our website or mobile app, our communications and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.

• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our service, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

Cookies and similar technologies. Like many online services, we use the following technologies:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.

• Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from personal information but is not considered personal information by law, as it does not directly or indirectly reveal a person’s identity. For example, we may aggregate a platform user’s usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with personal information so that it can directly or indirectly identify a specific person, we treat the combined data as personal information which will be used in accordance with this Privacy Notice.

How We Use Information

We use your personal information for the following purposes and as otherwise described in this Privacy Notice or at the time of collection:

• To offer and operate our services;

• To enable users to access and use our services;

• To enable users to communicate and collaborate with other vTail users and their contacts;

• To provide information about our services, such as important updates or changes to the services and security alerts;

• To customize the user experience, such as personalizing content and features to better match interests and preferences;

• To market our products and services to you;

• To improve our services and develop new products and services;

• To respond to inquiries, complaints, and requests for customer support.

We may also use personal information as we believe necessary or appropriate to (a) comply with applicable law; (b) enforce the terms and conditions that govern the service; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share Information

We share the information we collect:

• With vTail customers, to the extent the information pertains to the customer’s end users;

• With third party service providers that help us manage and improve the services;

• With vTail subsidiaries and corporate affiliates.

You may also direct us to share certain information with other users of the services related to some of the features we offer. Please keep in mind that whenever you make your personal information available for viewing by third parties or the public on or through our service, that information can be seen, collected and used by others. We are not responsible for any use of such information by others.

We may also share personal information with government, law enforcement officials or private parties as required by law, when we believe such disclosure is necessary or appropriate to (a) comply with applicable law; (b) enforce the terms and conditions that govern the services; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

We may sell, transfer or otherwise share some or all of vTail’s business or assets, including personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Your Choices

You have the following choices with respect to your personal information. European users may have additional choices as outlined in the “Notice to Individuals in Europe” section below.

Cookies. Most browser settings let you delete and reject cookies placed by websites. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, you may not be able to use all functionality of the service and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

Local storage. You may be able to limit use of HTML5 cookies in your browser settings. Unlike other cookies, Flash-based local storage cannot be removed or rejected via your browser settings, but you can adjust the settings of your Flash player to block it. Blocking Flash storage may impede the functionality of Flash applications, including those employed by the service. For more information on Flash local storage visit https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.

Marketing. You can ask us to stop sending marketing messages at any time by contacting us or by clicking the “unsubscribe” link at the bottom of the communication. If you opt out of receiving these marketing messages, we might still send you some important communications, like responding to you if you send us a request or comment.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Security

We employ reasonable technical and organisational measures to keep personal information safe and to prevent loss, misuse and unauthorised access. These measures include encryption, firewalls and password protection. It is, however, your responsibility to ensure that any device which you and your staff use is adequately secured and protected. Please note, that no security measures are failsafe and we cannot guarantee the security of your personal information.

Children

Our services are not intended for use by those under 16 years of age. If we learn that we have collected personal information through the services from a child without the consent of the child’s parent or guardian as required by law, we will delete it.

Cross Border Data Transfer

We are headquartered in the United Kingdom and may use service providers that operate in other countries. Your personal information may be transferred to the United Kingdom or other locations where privacy laws may not be as protective as those in your state, province, or country.

Links to Other Websites

Our services may contain links to third party websites, plug-ins and applications. This Privacy Notice applies to the vTail platform and does not cover any other websites or services that we link to. If you go to another website from our services, please read their privacy policy. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Changes to this Privacy Notice

We reserve the right to modify this Privacy Notice at any time. If we make material changes to this Privacy Notice, we will notify you by updating the date of this Privacy Notice and posting it on our services. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through our services. Any modifications to this Privacy Notice will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of our services after the effective date of any modified Privacy Notice indicates your acceptance of the modified Privacy Notice.

How to Contact Us

If you want to request any further details about this Privacy Notice, please contact us at: contact@vTail.co. Or you can write to us at Privacy Officer, vTail Healthcare Telecommunications Limited, 264 Banbury Road, Summertown, Oxford OX2 9HZ, United Kingdom.