Camino Robotics, Inc. (the “Company” or “We”) respects consumer privacy. This Policy discloses the privacy practices governing its knowing collection, use, and disclosure of information collected via the website located at https://www.caminomobility.com (the “Site”). By accessing and using this Site, or our Smart Walker companion app, you agree to the privacy practices as described in this Privacy Policy. If you disagree with anything in this Privacy Policy, please do not use the Site or our products.

Definitions

The term Personal Information means information about a specific individual, such as your full name and address, and email address, when used to identify a particular individual. While there are many different definitions of personal information used in different jurisdictions, generally, “Personally Identifiable Information” is the most commonly used term in the United States, and “Personal Data” is referred to for individuals covered by the EU General Data Protection Regulations Legislation, known as GDPR.

The term Non-Personal Information means information that does not personally identify you and cannot presently be used to specifically identify you.

The term Information means both Personal Information and Non-Personal Information.

Information Collected

Non-Personal. We collect and store Non-Personal Information about your use of the Site, including for example, site referral information, browsing patterns, technical information (e.g., browser type and version, downloads, and operating system), and general Site use information through standard Internet protocols and logging. Like many digital companies, we use common technologies such as cookies to better understand users’ interactions with the Site on an anonymized basis. You may refuse the use of cookies by selecting the appropriate settings in your browser. We collect standard internet log information and details of visitor behavior patterns. We do this to find out things such as the number of visitors to the various parts of the Site. We do not associate any of the data gathered from this Site with any Personal Information. The cookies we use The Company uses cookies for the operation of the Site. We use analytics cookies to help us understand how visitors use the Site so we can continue to improve it. We use a cookie to remember your preferences. You can access and change your preferences at any time by changing the settings in your browser or declining to accept cookies when first entering the Site. Essential cookies enable the core functionality of our websites such as security, authentication, and accessibility, so if you change your browser settings to disable these cookies, it may affect your ability to access and use the site.

The Company may use third parties, such as Google Analytics and Meta’s Pixel tool, to analyze how visitors interact with our Site so that we can continue to develop and improve it. Google Analytics uses cookies to collect information about visitors to our site (data related to the device/browser, IP address, and on-site activity). The Meta Pixel is a piece of code on this website that can help Us better understand the effectiveness of our advertising by identifying actions users take on this website. These tools measure and report on user interactions, such as the volume of visits to our site, or a user adding an item to their cart. This Site may also use third-party services to assist us with marketing to users and re-marketing to previous visitors to our Site. These services include email and text service providers, as well as re-marketing tools that use cookies or web beacons to serve ads based on a user's prior web browsing history on the Site to then show ads and other reminders that you visited. It requires the collection of information about your internet browsing, such as your ISP, general location (city and state), the browser you used to visit our Site, and whether you have Flash installed. Any such data collected will be used in accordance with this privacy policy.

Personal Information

We only collect Information that you provide to us. If you do choose to send us Personal Information, you will do so voluntarily, for example, where you provide us with your name or email address to request a brochure, participate in surveys or other activities. We will retain such Personal Information for purposes of responding to your email or inquiry and otherwise contacting you about our products and services. When this Site enables you to purchase products or goods online, or if you agree to pay a reservation fee for our products, you will also provide Personal Information when You use our online ordering process. The order process will require a credit card transaction that includes your name, address, zip code, and credit card information. Order information is encrypted when it is transmitted for credit card processing to the credit card services provider and when returned to us. Encryption is a process by which we use software to scramble information in transit. We use a third-party service provider (such as Shopify) to process orders and payments for Us, so your credit card information is not retained by Us.

Product Use Information

When you purchase a Camino Smart Walker device, the product collects information about product performance, quality of walking, time and distance of walking, location of journeys, reporting stability or unusual use (for example if you don’t use Camino in the morning - used for alerts to carers), in time we may develop other assessments of your health, such as detecting the onset of an infection or neurological condition

Companion iOS / Android Companion App

The companion app will collect product use information and share that back with you. Should you agree to provide the app access to other health data stored on your device, such as Apple Health, we will also store that data. The data will be used to build a profile of your health and provide feedback to you via the app, web, and email.

Information Sharing

Should you opt-in and give permission, the information may be shared with your caretakers, clinicians, PTs, or others. Examples could include fall alerts, inactivity alerts, unusual activity alerts, or onsets of medical conditions. You may also opt to share information and videos of you walking with your care and medical team. To further develop and train the Camino platform we will use anonymized video and gait data to improve the system (AI Training) and collaborate with clinical researchers and other experts such as data scientists to enable us to help users walk better, reduce fall risk, detect conditions and improve the health of users.

Sharing Tools

This Site may use sharing tools that allow you to share content through social networks such as Facebook or Twitter. When you use one of these buttons, the social networking site may place a cookie on your computer. This would be a third-party cookie set by the social networking site. Once you enable this function with the social networking site, this third-party site may collect information about you via cookies. If you have any questions about the use of these third-party cookies, you should check the relevant social networking site's cookie policy.

Questionnaires and Surveys

From time to time, we may ask you to complete questionnaires or surveys, which we use to obtain additional demographic information about our users, to measure and improve the quality of our products and services, and to better assess your interests and needs. If we ask you to complete a survey or questionnaire, we collect and retain that Information and we will explain how we intend to use the Information that you provide to us. You always have the option of not responding to any questionnaire or survey.

Use and Disclosure of Non-Personal Information

We use Non-Personal Information to better understand the use of the Site, improve and revise the Site based on usage, and track product interest and/or downloads. We may also share anonymized, aggregated Non-Personal Information with our clinical advisors.

We may share Non-Personal Information about our Site with our business partners or the general public. For example, we may share information regarding the daily number of unique users to our Site with potential corporate partners or others.

Use and Disclosure of Personal Information

If you share with us any Personal Information, we may also share the Information we collect from and about you for the following purposes:

We use Personal Information to communicate with you and to perform functions, such as providing customer support or shipping products. We may hold or merge your Personal Information with other databases we obtain and use it for our marketing and advertising purposes.

Information may be disclosed to anyone who is engaged to help us make the Site available and functional, like technical agents, service providers, other subcontractors, and our affiliates and consultants. These functions include, for example, website hosting, maintenance, data analysis, customer support, email delivery services, infrastructure services, technical agents, analytics, and metrics services. They will be engaged by contract to ensure that they only use Information on our behalf and as permitted under this Privacy Policy.

We may disclose Information during due diligence or in preparation for or after a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation.

In the event that another company acquires all or substantially all of the assets related to the Site or other business of the Company, we reserve the right to include Information among the assets transferred to the acquiring company.

We may disclose Information if required by law or where we believe such action is necessary in order to protect or defend our interests or the interests of our users or business partners. We may disclose Personal Information to the extent required by law, or if we have a good-faith belief that we need to disclose it in order to comply with official investigations or legal proceedings (whether initiated by governmental/law enforcement officials, or private parties). If we have to disclose Information to governmental/law enforcement officials, we may not be able to ensure that those officials will maintain the privacy and security of any Information.

Children

Our Site is not directed toward children under 13 years of age and we do not knowingly collect any Personal Information from children under age 13 (or up to age 16 in certain jurisdictions) through the Site.

Linked Internet Web Sites

The Site may contain hyperlinks that take you to a third-party website, document, file, or other materials. These third-party hyperlinked materials may contain privacy provisions that are different from those provided herein. We are not responsible for the collection, use, or disclosure of Information collected through these third-party sites and services, and we expressly disclaim any and all liability related to such collection, use, or disclosure.

PRIVACY NOTICE-CALIFORNIA CCPAThis PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in this Privacy Policy and applies to visitors and users of this website who reside in the State of California (“consumers” or “you”). This Notice does not apply to employees or those who have a business relationship with the Company. We adopt this notice to meet the standards of the California Consumer Privacy Act of 2018 (“CCPA”), even though we are not technically required to do so. For purposes of this notice, we use the term “Personal Information” as it is defined and used under the CCPA.

Information We Collect: Personal Information we collect is what You voluntarily submit to us via our contact form (i.e, your name, and email address). We use this information to respond to your request for information and to provide our services. Sharing Personal Information: We do not sell Personal Information to any third parties and only share it as disclosed in this Privacy Policy. Rights and Choices: The CCPA provides consumers (California residents) with specific rights (i.e. access, opt-out, and deletion) regarding their Personal Information. If at any time you wish to request information, amend or delete the Personal Information we hold about you, you may contact us as set forth in the “Contact Information” section below

EUROPEAN UNION, UK AND SWITZERLAND ADDITIONAL NOTICE

Currently, we only offer our services to residents in the U.S. However, you can send us your contact information to request information. We only collect this Personal Data (as this term is referred to for individuals located in the countries of the EU, UK, or Switzerland pursuant to the European Directives 95/46/EC and 2002/58/EC (EU General Data Protection Regulations Legislation), also known as GDPR) if you voluntarily provide it to us (i.e. by sharing an email so we can contact you). You may always decline to share certain Personal Data with us.

If you live in the European Economic Area (EEA), and wish to access, amend, delete, or transfer any Personal Data we hold about you, you may contact us as set forth in the “Contact Information” section below. We do not share with or sell Personal Data to any third parties. You may request that we delete Personal Data and preferences at any time by request to us at the email below. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, the satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

If you believe your right to privacy granted by applicable data protection laws has been infringed upon, please contact us at the email below.

General

We reserve the right to change this Privacy Policy at any time and will do so by posting changes to this Privacy Policy.

The Site is hosted in the United States and is intended for and directed to users in the United States. If you are located outside of the United States, please be advised that we process and store information in the United States and your use of this Site constitutes your consent to and understanding of this processing.

Information that we collect is stored on servers that we manage, using reasonable administrative, technical, and physical safeguards designed to protect against unauthorized access or disclosure of data. Please be aware that no data transmission over the Internet is guaranteed to be 100% secure.

Contact Information

If you have any questions about the Site or this Policy, or if you would like us to delete your Information, please contact us at hello@caminomobility.com. Location. This Site is operated by Camino Robotics, Inc. in the United States: Camino Robotics, Inc. 130 W. Union St., Pasadena, CA 91103.

Dated: 20 September 2022