Nervana Privacy Notice

Nervana Health, Inc. ("Nervana," "we," "our," or "us") is a consumer educational and coaching platform, and we value your privacy and the protection of your Personal Data. This Privacy Notice ("Notice") explains how we collect, store, use, share, transfer, delete, and process information collected from or about you known as Personal Data (defined further below in this Notice), and how you may exercise any rights you may have regarding our processing of your Personal Data. Nervana, or any of its subsidiaries or affiliates, will be responsible for the collection and processing of your Personal Data (known in some jurisdictions as the data controller).

This Notice describes the types of Personal Data that Nervana may collect or process, how we may use and disclose that Personal Data, and how you may exercise any rights you may have regarding our processing of your Personal Data.

This Notice applies to Personal Data collected or processed by us:

• Through online activities and services we offer (through websites, web surveys, newsletters, applications, email, online messaging services/channels, and otherwise) ("Online Services");
• When we provide products and services, including wellness coaching, directly to you and in other situations where you interact with us, including but not limited to interacting with us by telephone, though email or SMS/text messages, or by visiting our sites and offices or our events (e.g., tradeshows and conferences) (such products and services, together with Online Services, are collectively, the "Products and Services");
• When we undertake employment recruiting activities; or
• Anywhere this Notice is posted or referenced.

Nervana may provide you with a different privacy notice in certain specific situations, in which case that privacy notice or policy will apply to the Personal Data collected or processed in that specific situation, rather than this one.

If you provide us with Personal Data of anyone other than yourself (such as a friend or family member), please note that you are responsible for complying with all applicable privacy and data protection laws prior to providing that information to Nervana (including obtaining consent, if required).

Please review this Notice carefully. To the extent permitted by applicable law, by providing us with your Personal Data or otherwise interacting with us, you are agreeing to this Notice.

Please note that in many circumstances, we cannot effectively do business with you without processing some Personal Data about you (e.g., your contact information).

Under your jurisdiction's data protection law, you may be able to exercise the following rights with respect to some or all of your Personal Data:

• to request access to and a copy or representative summary of your Personal Data (including under GDPR Article 15);
• to request that we rectify or erase your Personal Data (including under GDPR Articles 16 and 17);
• to request that we restrict or block the processing of your Personal Data (including under GDPR Articles 18, 21 and 22 and to object to the sale or sharing of your Personal Data under other relevant laws);
• This includes the right to opt out of solicitations and to opt-out of sharing your Personal Data for cross-context behavioural or targeted advertising;
• to provide your Personal Data directly to another organization, i.e., a right to data portability (including under GDPR Article 20);
• when we previously obtained your consent, to withdraw consent to processing (including under GDPR Article 21);
• to request that we limit the processing of your Sensitive Personal Data;
• to appeal the denial of a request; and
• to lodge a complaint with the data protection authority in your area (including under GDPR Article 77).

To exercise these rights, please contact us at support@trynervana.com or founders@trynervana.com.

To learn if you have the other above rights in the state in which you live, to exercise any of these rights with respect to your Personal Data, or to revoke any consent you have previously provided, please contact us using the contact information provided above. We will not discriminate against you for exercising any of the rights described above, although we may not be able to continue to provide you Products and Services or it may otherwise affect the way we are able to interact with you. To appeal our decision on a request you have submitted, you may respond directly to our decision communication.

We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. We may, after receiving your request, require additional information from you to honor your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.

In the event you wish to make a complaint about how we process your Personal Data, please contact us at support@trynervana.com and we will handle your request as soon as possible. Even if you make a complaint to us, you may always lodge a complaint with the relevant authority in your location.

If you provide us with your Personal Data, you acknowledge that such Personal Data may be transferred from your current location to the offices and servers of Nervana and the authorized third parties referred to herein, which may be located in the United States.

Please be aware that Personal Data we collect and process may be transferred and maintained outside your state, province, country, or other jurisdiction, where the privacy laws may differ to those in your location, including the United States. Nervana has put in place safeguards in accordance with applicable legal requirements, to protect your Personal Data irrespective of the standards in the country where your Personal Data may be transferred. This includes entering into agreements with third parties, such as service providers, to require them to adopt standards that ensure an equivalent level of protection for data as those we adopt.

Consistent with applicable laws and requirements, Nervana has put in place physical, technical, and administrative safeguards designed to protect Personal Data from loss, misuse, alteration, theft, unauthorized access, and unauthorized disclosure consistent with legal obligations and industry practices. However, as is the case with all websites, applications, products, and services, we unfortunately are not able to guarantee security for data collected through our Products and Services. In addition, it is your responsibility to safeguard any passwords, ID numbers, or similar individual information associated with your use of the Products and Services.

We generally retain Personal Data for as long as needed for the specific business purpose or purposes for which it was collected or obtained, and as outlined in this Notice. In some cases, we may be required to retain Personal Data for a longer period of time by law or for other necessary business purposes. Whenever possible, we aim to de-identify the information or otherwise remove some or all information that may identify you from records that we may need to keep for periods beyond the specified retention period. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject that affects the Personal Data; and (iii) whether retention is determined to be necessary or advisable for Nervana due to applicable statutes of limitations, litigation, or other legal or regulatory obligations. Nervana takes reasonable steps to dispose of Personal Data upon the expiration of retention periods taking into consideration these litigation, legal, or regulatory obligations.

We reserve the right to change this Notice from time to time. We will alert you when changes have been made by indicating the date this Notice was last updated as the date the Notice became effective or as otherwise may be required by law. It is recommended that you periodically revisit this Notice to learn of any changes.

Controller: Nervana Health, Inc (we also conduct business under the following assumed business name(s): Nervana)

If you have questions or comments about this Notice or about how your Personal Data is processed, please contact us by one of the methods below:

Email: support@trynervana.com
Phone: 9167614259

We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. We may, after receiving your request, require additional information from you to honor your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.