Keet Inc.
PRIVACY POLICY
(REVISED FEBRUARY 2015)

Keet Inc., a Delaware corporation ("Keet," "our," "us," or "we") offers a physical therapy care platform-as-a-service (the "Service") that is designed to allow physical therapists to efficiently manage the patient care process and to allow patient end users ("Patients") to effectively complete their home treatments outside of the physical therapy office and meaningfully interact with physical therapist users ("Therapists"). The Beta Service includes a responsively designed web application (the "App").

Keet respects your privacy. In that regard, we have created this Privacy Policy to let you know the information we collect, how we use that information and any potential disclosures of such information.

This Privacy Policy applies to:

This Privacy Policy does not apply to:

The term "you," as used in this Privacy Policy, refers to a Patient or Caregiver end user of the Service. Please read this Privacy Policy carefully and save it. If you do not agree with it, you should not access the Website or use the Service. By using the Service or the Website or by submitting electronic communications to us, you consent to the practices prescribed in this Privacy Policy.

What information does Keet collect?

Information Collected from Caregivers

If you are a Patient, you acknowledge that we may collect your Personal Information or Health Information from you directly or through your Caregivers. It is your choice whether or not to provide that Personal Information or Health Information through the Service; provided that if, as a Patient, you designate a Caregiver, the Caregiver may elect to provide your Personal Information or Health Information on your behalf. In such case, the Caregiver is solely responsible for obtaining your consent to provide the Personal Information or Health Information. If you choose not to provide requested Personal Information or Health Information, you may not be able to use certain features of the Service.

Information You Voluntarily Disclose

Please keep in mind that whenever you voluntarily disclose Information through any messaging or news feed features or otherwise voluntarily utilize features of the Service that inherently share Information such as features that allow a Patient to share Information with a Caregiver or that allow a Patient or Caregiver to share a Patient's Information with a Therapist, that Information can be collected and used by others. You submit this Information at your own risk. We are not responsible for the security or privacy of any Information you choose to submit in connection with these public features.

How does Keet use Information?

Except as described in this Privacy Policy or in our Terms of Service, Personal Information, Health Information and Technical Information (collectively, "Information") that Patients or Caregivers provide or that we collect from Patients or Caregivers, will be kept confidential. We may use your Information, including your Personal Information and Health Information, as follows:

The Service exists in order to allow Patients and Therapists to communicate with one another regarding the Patient's physical therapy program. In order to provide for this type of exchange, we need to ensure that each user that contributes Information expressly permits the uses that we envision. For this reason, we need a license from you to use your Information, whether collected directly from you or, if applicable, your Caregiver. You hereby grant to Keet a non-exclusive, transferable, sublicensable, royalty free license to use your Information in order to provide the Service to the Patient, and the Patient's Caregivers and Therapists and as necessary to monitor and improve the Service. The license is non-exclusive (meaning you are free to license the Information to anyone else in addition to us), fully-paid and royalty-free (meaning that we are not required to pay you for our use of the Information), sublicensable (so that we are able to use affiliates and subcontractors to provide the Service), transferable (meaning that we may transfer it to a third party should we restructure our business), irrevocable (meaning that you may not revoke or rescind such license for any reason once the Information is uploaded) and worldwide (because the Internet is and the Service may be global in reach).

We may also use your Information for any other purpose with your consent.

Data and Blind Data

You also grant Keet a perpetual, non-exclusive, transferable, sublicensable, royalty free license to use such Information other than Personal Information and Health Information and other data we collect from you via Patient's or Caregiver's use of and interaction with the Service in order to collect, develop, create, extract or otherwise generate statistics and other information and to otherwise compile, synthesize and analyze such Information and data ("Blind Data"), such as to generate anonymous usage statistics. If we generate Blind Data, it will be owned by us and we may use it for any lawful business purpose. Any Blind Data will not personally identify you or the source of the Data.

Information We Share

Except as described in this Privacy Policy, Keet does not share, rent or sell the Personal Information we collect with third parties.

Keet or its agents, vendors or contractors may disclose Information, including your Personal Information, to third parties in the following circumstances:

If, as a Patient, you validate another end user as your designated Caregiver, we may share certain Information with that Caregiver.

Additionally, Keet may Share your Information with Therapists with whom you have a relationship for the provision of physical therapy services. We share this Information (including certain Personal Information and Health Information) with Therapists in order to provide elements of the Service and to allow communication between the Therapists and you.

Security of Your Information

We maintain physical, electronic, and procedural safeguards designed to protect the Information. These safeguards include storing your Information on secure servers using encryption technology. All Personal Health Information (PHI) records are encrypted with 256-bit AES encryption keys as soon as they enter the infrastructure. Every record is encrypted with a unique initialization vector by a unique encryption key to achieve semantic security. The system verifies each record's integrity on a regular basis and on each record request using a hash-based authentication code (HMAC) calculated using its own unique 256-bit HMAC key. Encryption keys, initialization vectors and HMAC keys are re-keyed and each record re-encrypted on a regular basis. Despite the actions and precautions we take, no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of the Information and you acknowledge and agree that you transmit it to us at your own risk.

Third-Party Websites, Services and Technologies

We may provide links to third-party websites on the Website or in other communications to you. These links may appear as a specific domain name or URL or may be activated by clicking on an advertisement or other icon or graphic. Please be aware that other websites and services, including the websites of third parties that you connect with through the Service, may collect personally identifiable information about you. We cannot control and are not responsible for the information collection practices of any third-party websites, services or applications. We encourage you to carefully review their terms of use, privacy policies, and any other legal notifications before using or providing information through such websites, services or applications.

Further, the Service may employ third party technologies that require you to accept such third party's terms. This Privacy Policy does not cover the information practices of those third-party technologies.

International Transfers

Information collected from you may be stored and processed in the United States or any other country in which Keet or its affiliates, subsidiaries, agents or contractors maintain facilities. If you are accessing the Service, Website or the App from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your data to the United States and processing globally. By providing your Information, you consent to any transfer and processing in accordance with this Privacy Policy.

HIPAA

This Privacy Policy and the privacy and security practices described in this Privacy Policy are designed to comply with the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"). Therapists and their employers, to the extent they are "Covered Entities" under HIPAA (as such term is defined in HIPAA) have their own privacy and security obligations with respect to your Personal Information and Health Information. Additionally, we have agreements in place with Therapists or their organizations, which define certain of our security and privacy obligations. We encourage you to contact each Therapist with whom you interact through the Service and the App regarding their privacy and security practices. For more information regarding your rights under HIPAA, see https://www.hhs.gov/hipaa/index.html.

Children's Privacy

The Service, Website and the App are not intended for children under the age of 13. We do not knowingly collect Information from children under 13. If you believe that we may have collected Information from a child under the age of 13, please contact us at info@keethealth.com.

Information Choices and Changes

We may need to communicate with you about the Service, Website or the App, and we would like to make certain commercial offers available to you from time to time. As such, by signing up for our newsletter or by creating an account on the Website, you consent to receive commercial messages (whether by phone, email, text or push notifications) from us or our third party partners, and acknowledge and agree that your email addresses and other information may be used for the purpose of initiating commercial messages. We will allow you to opt-out of receiving commercial messages, but in order to stop receiving any messages from us whatsoever (including administrative messages regarding the Service), you will need to terminate your account.

Depending on your browser, you may be able to remove and reject cookies from our Website by changing your browser settings. The default setting of many browsers is set to accept cookies until you change your settings. Please note that if you disable or refuse cookies, certain features of the Website may become inaccessible or may not function properly.

Changes to this Privacy Policy

This is our entire Privacy Policy and it replaces any earlier version. We may change this Privacy Policy by posting a new version on the Website or through the Service or the Website, and it is your responsibility to review this Privacy Policy periodically. If we make material changes to our practices regarding the collection, use and sharing of your Personal Information, we will notify you via e-mail to the email address you provide to us and/or through a notice on the Website home page or via the Service or the Website.

When we do change the Privacy Policy, we will also revise the "revised" date. Your continued use of the Service, Website or the App after such date constitutes your agreement to this Privacy Policy and any updates.

Contacting Keet

For questions or comments regarding this Privacy Policy, please contact us at 98 San Jacinto, Austin Tx 78701, 413.230.0085 and info@keethealth.com.