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May 4, 2022

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Privileged and Confidential

Attorney Client Privilege

 

Privacy Policy

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This privacy policy (this “Privacy Policy”) describes how we, Voxela, Inc. (“Voxela”), use, maintain,
protect and disclose personal information collected through (i) our website, (ii) our mobile and desktop
applications (the “Apps”), (iii) e-mails, texts and other written communication and (iv) phone calls and
oral communication. Voxela provides an incident detection and management solution for nursing
facilities, assisted living facilities, memory care facilities and any other facilities similar to these
(collectively, the “Facilities”) called Voxela VCare solution (the “Solution”).

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1. Information regarding Voxela
 

Company name: Voxela, Inc.
Address: 2325, Forbes Ave, Santa Clara 95050, the US

Representative: Yuta Endo

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2. Personal Information We Collect and Means of Collecting Personal Information
 

We collect the following personal information:

  • The name, e-mail address, and other information of a user of the App when the user submits

to us such information in written form (either physically or electronically) or orally;

  • The name, e-mail address and phone number of the responsible person, the physical

address, and other information, of a Facility when the Facility submits to us such information
in written form (either physically or electronically) or orally;

  • Information about how our website and the Apps are used (including browsing histories and

referring URLs) through our website (including cookies, web beacons and Google Analytics)
and the Apps; and

  • Information about the computers, mobile devices and internet connections with which our

website and the Apps are used (including information about the browsers, operating systems
and IP addresses) through our website and the Apps.

 

3. Purpose of Collecting Personal Information
 

We collect personal information:

  • To confirm the identities of the responsible persons of the Facilities that use the Solution;

To contact (including to send notification to) the responsible persons of the Facilities that use
the Solution;

  • To confirm identities of the users of the Apps;

  • To contact (including to send notifications to) the users of the Apps;

  • To provide service regarding the Solution to the Facilities and the users of the Apps;

  • To present our website and its contents;

  • To improve our existing products and service (including the Solution);

  • To develop our new products and service; and

  • To provide information regarding our new or existing products and service.

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4. Date Sharing
 

We will make personal information available to an affiliate of Voxela the personal information
described in Section 2 above for the purposes described in Section 3 above after ensuring through an
inter-company regulation, contract or both that such affiliate complies with all requirements set forth in
the Act on the Protection of Personal Information (Law No. 57 of 2003) of Japan and related
regulations, orders and guidelines publicized by the government of Japan (the “Laws”) even if the
Laws are not applicable to such affiliate. Voxela, Inc., located at 2325, Forbes Ave, Santa Clara
95050, the US and whose representative is Yuta Endo, is responsible for the collection, use,
maintenance, protection and disclosure of personal information by Voxela’s affiliate.
We will not, without obtaining the prior consent of the data subject, make personal information
available to a third party other than an affiliate of Voxela except:

  • Where it is pursuant to a law, regulation or order;

  • To the extent that it is difficult to obtain the consent of the data subject where it is necessary

to protect life, body or property of a natural or legal person;

  • To the extent that it is difficult to obtain the consent of the data subject where there is a

special need for improvement of public health and promotion of healthy growth of children;

  • To the extent that obtaining the prior consent of the data subject may make it difficult for a

national agency, a local government or a contractor of a national agency or a local
government to perform a task set forth in a law, regulation or order where it is necessary to
cooperate with performance of such task;

  • To an academic research institution or group or a member thereof to the extent necessary for

academic research (unless the rights and interests of the data subject are not unfairly
encroached);

  • To the extent necessary for the succession of Voxela’s business; and

  • To a contractor after executing a written agreement with such contractor that ensures that

such contractor uses such personal information only on behalf of Voxela and complies with all
requirements set forth in the Laws even if the Laws are not applicable to such contractor.


5. Security measures


Voxela has created internal policies (including this Privacy Policy) satisfying the requirements of the
Laws (the “Policies”) and follows the Policies. Voxela constantly monitors updates to the Laws and
updates the Policies to meet the then-current requirements of the Laws.


Voxela collects, uses and maintains personal information to the extent necessary for the purposes
described in Section 3 above and Voxela promptly deletes the personal information that Voxela no
longer needs to maintain for the purposes described in Section 3 above.

 

Voxela has designated a person in charge of collection, use, maintenance, protection and disclosure
of personal information within Voxela (the “Responsible Person”) and the Responsible Person will
ensure, including through periodical reviews of the handling of personal information within Voxela, that
personal information is collected, used, maintained, protected and disclosed in accordance with the
Policies.


Voxela allows only limited employees, officers and contractors to access personal information held by
Voxela. To ensure this, Voxela keeps an access control system which allows only such limited
employees, officers and contractors to access personal information and keeps up-to-date firewalls,
security software and other technical measures which block access to personal data from anyone
other than such limited employees, officers and contactors. Voxela also limits equipment with which
the employees and officers can handle personal information and where such equipment can be
located or used. The employees, officers and contractors who have access to personal information
are contractually bound to comply with the Policies and periodically receive the training regarding the
handling of personal information. The employees, officers and contractors will promptly notify the
Responsible Person if they have learned of any incident regarding personal information or any
incompliance with the Policies.


6. Contact Information


To make any request pursuant to the Laws (including a request to disclose personal information held
by us and a request to make a correction of, addition to or deletion of personal information held by us)
or to make any complaints, please send an e-mail to: info@voxela.ai


In certain circumstances, we may decline such request in accordance with the Laws.

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