Tomorrow Networks Privacy Terms and Conditions for Mobile Application Users

Effective April 30, 2018

In the new mobile era, context for a brand is no longer limited to content alone. Thanks to the convergence of big data, technology and massive audience scale, Tomorrow Networks (“Tomorrow Networks,” “we,” “us,” and “our”) can help advertisers reach their audiences in new, innovative and intelligent ways. To deliver communications and advertising to consumers, we collect and use certain information about users of mobile applications (“you” or “your”) through Tomorrow Networks’ or our partners’ advertising network (“Network”).

Tomorrow Networks is committed to being a responsible participant in the mobile advertising ecosystem and to protecting personal information about Internet, mobile Internet, and mobile application users. This Tomorrow Networks Privacy Notice for Mobile Application Users (“Notice”) explain what information we collect through our Network, how we use and share that information and how we secure the information. By using the mobile applications, you consent to us collecting and using your information as described in this Notice and any updates to this Notice.

Information We Collect

Our Network collects information from mobile applications that you use and the advertisements that you see while using the mobile applications, including information about the services that you use and how you interact with the ads we deliver to you. You may encounter this when Tomorrow Networks makes a call for advertisements on a mobile application that you use. At other times, our Network may collect information from mobile applications without delivering ads. This information includes:

Advertising Identifiers.

To support behavioral targeted advertising on devices where cookies are not available, we may use identifiers such as Apple’s Identifier for Advertising and Google’s Advertising ID. These advertising identifiers do not constitute personal information.

Device Information.

We may collect information regarding the device you are using. For example, we may collect information such as the type of device with which you access the mobile applications, the operating system version and data connection type.

Location Data.

We may collect precise location information if you have elected to provide that information to us, including GPS signals sent by a mobile device or information that can be used to approximate a location (such as a IP address).

Mobile Application Data.

We may collect data from mobile apps, such as the content of the apps and event information shared by the apps, including actions visited in mobile application, time in section, path taken to reach a section and areas viewed/interacted with.

Usage Data.

We may collect other usage data relating to your activity within the mobile application. This information may include the type and number of ads shown to you, whether you closed the ad or allowed it to time out, and whether you clicked on the advertisement.

Information We Get From Third Parties.

We may receive information connected with the advertiser ID on your device from third parties. This information may include your age, gender, professional designation, practice specialty and demographic information. This information may be licensed or purchased. Our use of this information is subject to the privacy policy pursuant to which the data was originally collected.

How we use information we collect

We use the information we collect through our network to deliver communications and advertisements to you on behalf of our customers and to provide reports to our customers that analyze user demographics and behavior to provide better and more relevant communications and advertising to you and provide useful aggregated analytics to our customers.

Tomorrow Networks services are not intended for use with audiences under the age of thirteen. We do not knowingly collect personal information from anyone under the age of thirteen.

Disclosure of Information To Third Parties

Service Providers.

We may use third party partners to provide services to help us manage our technology and business, and we may share your information with those partners to the extent necessary for those partners to provide those services.

Aggregate Statistics.

We may disclose aggregate statistics regarding user behavior and demographics to measure interest in, and use of, communications and advertisements to our customers, in the form of aggregate data. However, these overall patterns or demographic reports will not describe or identify any individual user.

Compelled Disclosure.

We may disclose any information we have gathered to government authorities, and to other third parties when compelled to do so by government authorities or otherwise as

required or permitted by law, including but not limited to in response to court orders and subpoenas. We may also disclose user information in connection with investigations or when we have reason to believe that someone is causing injury to or interference with our rights or property, or anyone else that could be harmed by such activities.

Transfer in the Event of Sale or Change in Control.

We may transfer information, including your personal information, in connection with a merger, sale, reorganization, acquisition or other change of ownership or control by or of Tomorrow Networks or any affiliated company (in each case, whether in whole or in part). When one of these events occurs, we will use reasonable efforts to notify users before their information becomes subject to different privacy and security policies and practices.

Cross-border transfers

As part of providing you the website services, personal data may be transferred by Aptus Health to its affiliates in the United States, in the European Union (EU), or in India. This means that if you are located in the EU, your personal data is transferred to the US or to India, which are not considered to have the same level of data protection as in the EU. However, we have implemented appropriate safeguards as detailed hereafter so as to ensure an adequate level of protection. We also entered into standard contractual clauses or Binding Corporate Rules with our affiliates located outside the EU. Information may be stored and processed in any country where Aptus Health has engaged Service Providers. We may also transfer aggregated information and de-identified data or, if you have consented to it, your personal data to our Business Companies located outside the EU. These operations also involve transfers to countries which do not have data protection laws considered to be equivalent to those under EU law. However, we ensure all data transfers comply with applicable legal requirements (for example, by implementing appropriate contractual clauses). To obtain more details on these transfers and where appropriate copies of the applicable safeguards that were put into place, please contact: Compliance@AptusHealth.com or privacy@AptusHealth.com.

EU-U.S. and Swiss-U.S. Privacy Shield Frameworks

Aptus Health also complies with the EU-U.S. and Swiss-U.S. Privacy Shield frameworks, as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Economic Area to the US. If there is any conflict between the terms in this privacy policy and the Privacy Shield principles, the Privacy Shield principles will govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/. For questions or complaints regarding our participation in Privacy Shield, please contact us at Compliance@AptusHealth.com or privacy@AptusHealth.com. For any complaints that cannot be resolved with Aptus Health directly, Aptus Health has chosen to cooperate with Better Business Bureau organization. If your complaint is not resolved after following the recourse mechanisms described above, you may have the ability to invoke binding arbitration. Additional information is available here. To review Aptus Health Privacy Shield policy, please visit: https://aptushealth.com/privacy-shield

Changes to this Privacy Notice

Tomorrow Networks reserves the right to change, modify, add or remove portions of this Notice at any time and without notice. We will make every effort to post any changes to this Notice in this area so that you are aware of the information we collect, how it is used, and under what circumstances is disclosed.

Questions or Comments

If you have any questions or comments you may contact us at the following address:

Tomorrow Networks

1270 Avenue of the Americas, Suite 2004

New York, New York 10020

privacy@aptushealth.com