PRIVACY POLICY

Data Controller As the Data Controller, Spinex IO (“Company”) ensures compliance with applicable US data privacy laws, including the California Consumer Privacy Act (CCPA) and the Health Insurance Portability and Accountability Act (HIPAA), where relevant. The Company is committed to processing personal data responsibly, ensuring security, and respecting your privacy rights.

Health Service Provider The Turp Health & Home Care services are provided by Omega Care LTD, with software developed and owned by Spinex IO.

Categories of Personal Data Collected

The Company may collect the following types of personal data:

1. Identity Information: Name, date of birth, Social Security Number (where applicable).
2. Contact Information: Email address, phone number, mailing address.
3. Professional Information: Job title, professional licenses, areas of specialization.
4. Health Information: Data related to physical activity, heart rate, blood pressure, glucose levels, oxygen saturation, and other health metrics obtained through the application or connected devices.
5. Technical Data: IP addresses, device IDs, log files, and usage statistics.
6. Financial Information: Payment details, transaction records.

Purpose of Collecting and Using Personal Data

The data collected may be used for the following purposes:

• To provide and improve the Turp Health & Home Care services.
• To facilitate communication between users and healthcare professionals.
• To monitor health metrics for personalized healthcare solutions.
• To comply with legal obligations, including reporting requirements to regulatory bodies.
• To process payments and manage billing.
• To authenticate users and ensure the security of accounts.

Legal Basis for Data Processing

In the United States, the processing of personal data aligns with the following legal and operational bases:

1. Contractual Necessity: Data is processed to fulfill service agreements with users.
2. Legal Obligations: Compliance with applicable healthcare and consumer protection laws, including HIPAA and CCPA.
3. Legitimate Interests: Processing is necessary to improve service functionality, enhance security, and provide user support.

For processing health-related data, explicit consent will be obtained as required by HIPAA and other relevant regulations.

User Rights Under US Laws

As a data subject, you have the following rights under US data privacy laws:

1. Right to Access: Request access to the personal data collected about you.
2. Right to Delete: Request the deletion of your personal data unless retention is required by law.
3. Right to Know: Be informed about the categories of data collected, the purpose of collection, and any data sharing practices.
4. Right to Opt-Out: Decline the sale or sharing of personal data (if applicable).
5. Right to Correct: Request correction of inaccurate or incomplete personal data.
6. Right to Data Portability: Receive your data in a portable format.

To exercise these rights, you can contact us via [email].

Medical Disclaimer

The Turp Health & Home Care application is not a substitute for professional medical advice, diagnosis, or treatment. All content is for informational purposes only. Users are solely responsible for the proper use of the application and its associated devices.

Data Collection Methods

Personal data may be collected through the following channels:

• User registration on https://turp.app and the mobile application.
• Data entered or uploaded by users, including health metrics from connected devices.
• Usage logs from the application and associated hardware.
• Forms submitted on the website or app for inquiries or service use.

Sharing Personal Data

Your personal data may be shared in the following circumstances:

1. With Healthcare Providers: To facilitate services requested by users.
2. With Public Authorities: To comply with legal reporting obligations.
3. With Service Providers: To enable payment processing, communication, and IT support, under strict data protection agreements.

Personal data will never be sold for marketing or commercial purposes without your explicit consent.

Data Security Measures

The Company employs industry-standard security measures to protect your personal data, including:

• Secure Socket Layer (SSL) encryption for data transmission.
• Two-factor authentication for account access.
• Data anonymization and pseudonymization where appropriate.
• End-to-end encryption for sensitive health data.
• Regular vulnerability assessments and third-party security audits.
• Role-based access control to limit data access to authorized personnel.

Retention of Personal Data

The Company retains personal data based on the following guidelines:

1. For General Users: Data is retained until account deletion or termination of services, unless otherwise required by law.
2. For Health Records: Data may be stored for up to seven years in compliance with HIPAA and other healthcare regulations.
3. For Professional Applications: Data for healthcare professionals is retained for the duration of their contract and up to six years thereafter, as required by legal and compliance frameworks.

Upon expiration of retention periods, data is securely destroyed or anonymized.

Use of Cookies and Tracking Technologies

The Company uses cookies and similar tracking technologies to enhance user experience and analyze site performance. Users can opt out of non-essential cookies through browser settings.

Contact Information for Data Requests

You can exercise your rights or direct inquiries to the Company through the following channels:

• Email: [email]
• Postal Mail: [Insert Address Template]
• Phone Support: [Insert Phone Template]

To verify your identity, additional information may be required.

Changes to this Privacy Policy

The Company reserves the right to update this Privacy Policy periodically to reflect changes in legal requirements or service offerings. Users will be notified of significant updates via email or application alerts.

This Privacy Policy underscores Spinex IO’s and Omega Care LTD’s dedication to safeguarding personal data and ensuring compliance with US privacy regulations.