I. INTRODUCTION

When you use the Hailo Platform, you trust us with some of your personal data. We
are committed to keeping that trust, which starts with helping you understand our
privacy practices. This privacy policy (“notice”) describes the personal data we
collect, how it’s used and shared, and your choices regarding this data.

We recommend that you read this notice along with all our associated Terms &
Conditions.

Unless otherwise defined, terms used in this notice have the same meanings as in
our Terms & Conditions, accessible at: HailoCare.com/TOS.

II. SCOPE

This notice applies to users of the Hailo Platform anywhere within the United
States, including users of its apps, websites, features, or other products and
services.

This notice specifically applies to:

• Clients: individuals who request or receive home care services via their HailoCare account.

• Caregivers: Third-party providers licensed and/or certified as Home Care Aides or their jurisdictional equivalents who provide home care and related services to individual Clients.

III. DATA COLLECTION AND USES

A. The Data We Collect

HailoCare collects several types of information and data for various purposes. We
collect data:

• provided by users to HailoCare, such as during account creation.
• created during use of our Services, such as location, app usage, and device data.
• from other sources, including but not limited to business partners, vendors, insurance or financial institutions, and governmental authorities.

1. Data provided by users. This includes:

User profile information and demographic data: We collect data when
users create or update their Hailo accounts. This may include name, age,
date of birth, gender, occupation, profile picture, residential address,
email address, phone number, login username and password, known
health complications, banking or payment information (including related
payment verification information), driver’s license and other government
issued documents. This also includes vehicle and liability insurance
information of Caregivers, emergency contact information, user settings,
and evidence of health or fitness to provide services using the Hailo
Platform.

We may also infer demographic data from other information collected
from users. For example, if gender and/or gender identity information is
not clearly disclosed or updated, we may infer a user’s gender based on
their first name, profile picture, government identification documents, or
known health complications, to optimize user experience and enhance
safety.

• Background check information (Caregivers): This includes information submitted during the Caregiver application process, such has criminal record; driving record; educational background; residential and employment history; verification of professional licenses and certifications; investigative and disciplinary history, including administrative, civil, and/or criminal liability imposed by relevant regulatory bodies or other legal authority; known aliases; legal authorization to work within the United States. This information may be collected by an authorized vendor on HailoCare’s behalf.

• Identity verification photos: This includes photos of users and/or their government issued identifications (such as driver’s licenses or passports). Such photos may be used to verify a user’s identity, including through use of facial recognition technologies.

• User content: We collect data submitted by users when they contact HailoCare customer support, provide ratings or feedback for other users, or otherwise contact HailoCare. This may include photographs, or audio or video recordings submitted by users in connection with a customer support request. This also includes metadata relating to the method you use to communicate with HailoCare.

2. Data created during use of our services.

• Location data (Caregivers): We collect precise or approximate location
  data from the Caregivers’ mobile devices when the Hailo app is running in
  the foreground (app open and on-screen) or background (app open but
  not on-screen).
• Location data (Clients): We collect precise or approximate location data
  from Clients’ mobile devices if they enable us to do so via their device
  settings.
  HailoCare collects such data from the time a service is requested until it is
  finished, and any time the Hailo app is running in the foreground (app
  open and on-screen).
  Clients/recipients of services may use the Hailo app without enabling
  collection of location data from their mobile devices. However, this may
  affect certain features in the Hailo app. For example, Clients who have
  not enabled precise location data may have to manually enter their
  residential address or address for the specific location where they want
  to receive their requested home care services.
  In addition, precise location data collected from a Caregiver’s device
  during a home care service assignment may be linked to the Client’s
  account, even if the Client has not enabled precise location data to be
  collected from their device. This data may be used for purposes such as
  receipt generation, customer support, dispute resolution, fraud
  detection, insurance, and litigation.
• Transaction information: We collect transaction information related to
  the use of our services, including the type of services requested or
  provided (such as date/time, location, home care services provided by
  Caregiver and received by Client); and payment transaction information
  (such as amount charged and payment method).
• Usage data: We collect data about how users interact with our services.
  This includes access dates and times, app features or pages viewed,
  browser type, and app crashes and other system activity.
• Device data: We collect data about the devices used to access our
  services, including the hardware models, device IP address or other
  unique device identifiers, operating systems and versions, software,
  preferred languages, device motion data, and mobile network data.
• Communications data: We collect data regarding phone, text or in-app
  communications between users that are enabled through the Hailo
  Platform and app. This includes date and time, as well as the content of
  text or in-app messages. We may collect the content of in-app phone
  calls between Clients and Caregivers. We may also collect the content of
  customer support phone calls solely where users are notified in advance
  that the call may be recorded.

3. Data from other sources. These include:

• users or others providing information in connection with claims or disputes.

• HailoCare business partners through which users create or access their Hailo account, such as payment providers, social media services, or apps or websites that use HailoCare’s APIs or whose APIs HailoCare uses.

• users participating in potential referral programs.

• Vendors who help us verify users’ identity, background information, and eligibility to work, or who screen users in connection with sanctions, anti- money laundering, or know-your-customer requirements.

• Insurance, vehicle, or financial services providers for third-party providers/Caregivers.

• Publicly available sources.

• Marketing service providers whose data HailoCare uses for marketing or research.

• Law enforcement officials, public health officials, and other government authorities.

B. How we use personal data

HailoCare uses data to enable the reliable and convenient provision of home
care services, and other products and services. We also use such data:

• To enhance the safety and security of our users and services
• For customer support
• To enable communications between users
• To send non-marketing communications to users
• For marketing and advertising
• In connection with legal proceedings

We use the data we collect:

1. To provide our services. HailoCare uses data to provide, personalize, maintain,
   and improve our services. This includes using data to:

• create/update accounts.

• enable facilitation of home care services/features.

• using location data to calculate ETAs and track the progress of service assignments.

• match available Caregivers to Clients requesting home care services. Users can be matched based on availability, location/proximity, price, and other user settings/preferences.

• enable dynamic pricing

• process payments.

• personalize users’ accounts.

• facilitate insurance, invoicing, or financing solutions.

• provide users with updates, generate receipts, and inform them o changes to our terms, services, or policies.

• Perform necessary operations to maintain our product and services, including troubleshooting software bugs and other technical or operational problems.

HailoCare performs the above activities on the grounds that they are
necessary to fulfill the terms of our agreements with users, are compatible
with such uses, or on the grounds that they are necessary for purposes of
HailoCare’s and its users’ legitimate interests.

2. Safety and security. We use data to help maintain the safety, security, and
integrity of our services and users. This includes:

• verifying users’ identity and eligibility to provide home care services, including through reviews of background checks, to help prevent use of our services by unsafe Caregivers and/or Clients.

• using location information, and communications between Clients and Caregivers, to identify cancellation fees earned or induced through fraud.

• using device, location, user profile, usage, and other data to prevent, detect, and combat other types of fraud.

• using user ratings, reported incidents, and other feedback as grounds for investigating, and if necessary, deactivating users with low ratings or who otherwise violated our policies

3. Customer support. HailoCare uses the information we collect (which may
include call recordings) to provide customer support, including to investigate and
address user concerns and to monitor and improve our customer support
processes.

4. Research and development. HailoCare may use data for testing, research,
analysis, product development, and machine learning to improve user
experience and enhance the convenience, safety, and security of our features.

5. Enabling communications between users. For example, Caregivers may call
Clients to confirm their requested services and location. Clients may call
Caregivers to confirm their estimated time of arrival.

6. Marketing and advertising. HailoCare may use data to market its products and
services. This may include using data to send marketing communications that are
personalized based on users’ observed or inferred needs and characteristics. This
may also include measuring the effectiveness of HailoCare’s ads.

7. Legal proceedings and requirements. We use data to investigate or address
claims or disputes relating to use of HailoCare’s services, to satisfy requirements
under applicable laws, regulations, or operating licenses or agreements, or
pursuant to legal process or governmental request, including from law
enforcement.

C. Cookies and third-party technologies

Cookies are small text files that are stored on browsers or devices by websites,
apps, online media, and advertisements. HailoCare uses cookies and similar
technologies for purposes such as:

• authenticating users

• remembering user preferences and settings

• determining the popularity of content

• delivering and measuring the effectiveness of advertising campaigns

• analyzing site traffic and trends, and generally understanding the online behavior and interests of people who interact with our platform

HailoCare may also permit others to provide audience measurement and
analytics services for us, to serve advertisements on our behalf across the
internet, and to track and report on the performance of those
advertisements. These other entities may use cookies, web beacons, SDKs,
and other technologies to identify the devices used by visitors to our
websites, as well as when they visit other online sites and services.

IV. CHILDREN’S PRIVACY

HailoCare’s services do not address anyone under the age of 18 (“children”). All
Hailo users and account holders must be legal adults aged 18 or older. We verify all
users’ age and identity before allowing them to become Hailo account holders.

We do not knowingly collect personal data from any children. If you are a parent or
guardian and you are aware that your children have provided us with personal data,
please contact us immediately.

V. UPDATES TO THIS NOTICE

We may occasionally update this notice and privacy policy. We encourage users to
periodically review this notice for the latest information on our privacy practices.
Use of our services after an update constitutes consent to the updated notice to the
extent permitted by law.