Effective Date: 29 July 2022

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Feel Therapeutics Inc. (registered in the United States, 870 Market Street, San Francisco, CA 94102), and its affiliates (Feel, we, us or our) care about your privacy and are committed to protecting your Personal Data in accordance with fair information practices and applicable data privacy laws. The Greek branch of Feel (Sentio Labs Private Company, Iraklitou 93, Chalandri, 152 35, Athens, Greece) is the controller of Personal Data collected from European Economic Area (“EEA”) residents.

‍Scope Of This Privacy Notice

This Privacy Notice (“Notice”) explains how we collect and use individuals’ Personal Data (“you” or “user”) in the course of our operations, including our websites, mobile applications, the Feel program, the Feel Relief Program and other services provided by us (collectively the “Services”). Personal Data is all information relating to an identified or identifiable individual, and does not include data whereby personally identifiable information has been removed (such as anonymous data).

Please read this Notice carefully. If you do not agree with this Notice or any part thereof, you should not access or use any part of the Services, or otherwise provide us with your Personal Data. If you change your mind in the future, you should stop using the Services and provide us with no further Personal Data.  

We collect Personal Data in a variety of ways through our normal business activities, in both online and offline contexts. This includes, for example, when you place orders or purchase our products or Services, enter into agreements or communicate with us, or visit and use our website or our mobile app (“App”). We also receive Personal Data from our customers in order to perform Services on their behalf and from social networks, or third party partners such as analytics.

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What Personal Data We Collect

Use of the Services is voluntary. To the extent you choose to use the Services, we may collect Personal Data about you directly from you or from third parties, as listed below:

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Information Collected from You

• Contact Information that allows us to communicate with you, such as your name, job title, age, date of birth, prefix and title, gender, username, mailing address, telephone numbers, email address or other addresses that allow us to send you messages.

• Relationship Information that helps us do business with you, such as the types of products and Services that may interest you, contact and product preferences, languages, marketing preferences and demographic data.

• Transaction Information about how you interact with us, including purchases, inquiries, customer account information, order and contract information, delivery and shipping details, billing information and credit card number, and information about how you use and interact with our websites.

• Service Information that helps us provide our Services to you, which may include content that you choose to add in the App or when otherwise using the Services, responses to quizzes and questionnaires completed on our website or our App regarding the user’s emotional status, and information regarding your interaction with the Feel Coach. If you have subscribed to the Feel program we may also process galvanic skin response (GSR), heart rate variability (HRV), skin temperature (ST), voice data, monitoring and geolocation data (e.g. 9-axis accelerometer), Bluetooth data, and emotion recognition data (as derived from processing the acquired biometric data).

• Support Information that helps respond to your queries, such as your email address, and the contents and nature of your correspondence with us, including technical support requests, complaints, queries and feedback on your use of the Services.

• ‍Cookie Information related to your visit and use of the Services via cookies (see our Cookie Policy for more information https://www.myfeel.co/cookie-policy). This information may include Personal Data, such as your IP address, and advertising identifiers.

• System Related Information. When you use our Services we will automatically collect potentially non-Personal Data about your device including model, version and operating system.

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Information Collected from Other Sources

• Third parties. We may obtain information, including Personal Data from third parties and sources other than from you. If we combine or associate information from other sources with Personal Data that we collect through our Services, we will treat the combined information as Personal Data in accordance with this Notice.

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How We Use Personal Data

We use your Personal Data for one or more of the following purposes:

• Providing the Services. We use your Personal Data to perform our contractual obligation towards you to allow you to use the Services, including fulfilling your orders for products or Services and related activities, such as product and service delivery, customer service, account and billing management, support and training and to provide other Services related to your purchase. Where required under applicable law, we will only process sensitive Personal Data with your opt-in consent.
• Providing you with support, responding to your requests and complaints, and otherwise communicating with you. If you reach out to us for support regarding the Services, we will perform our contractual obligation towards you by using your Personal Data to respond and resolve your queries and facilitate support.  It is also in our legitimate interests to otherwise communicate with you regarding your use of the Services.  We may also notify you about major updates in our Services.
• Improving or understanding usage of the Services. It is in our legitimate interests to process your Personal Data to ensure the efficient operation of the Services, to understand and analyze the usage trends and preferences of our users, to improve our Services, and to develop new products, Services, features, and functionalities.
• Advertising and marketing. It is in our legitimate interests to use your email address and other Personal Data to send marketing communications, including updates on promotions and events relating to products and Services offered by us and by third parties we work with, and assess your eligibility to continue to the Feel Program after the Feel Relief Program is completed. Generally, you can opt out of receiving any promotional communications as described below under Your Options and Rights. Where required under applicable law, we will only send you promotional emails with your opt-in consent.
• Enforcing the Feel Terms of Service, complying with legal and administrative obligations and defending Feel against legal claims or disputes. It is in our legitimate interests to enforce our Terms of Service, to ensure the integrity of Feel, to conduct audits, and to defend ourselves against legal claims or disputes.  Where we do so, we will use the Personal Data relevant to such a case.  Some processing may also be necessary to comply with a legal obligation placed on us.
• Scientific research. We may use your Personal Data, including Sensitive Personal Data, for scientific research purposes that are proportionate to the aim pursued.
• Anonymization. We may anonymize or otherwise de-identify your Personal Data and use the resulting information for other purposes, including analytics and scientific research.

When you visit our websites or otherwise request us to provide a service, we will notify you in those cases in which the information is required (i) to provide our Services or (ii) by law. Where your Personal Data is required, we may be unable to provide you with our Services unless you provide us with the relevant information.

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‍IP Addresses and Cookies

Like other websites, our website uses your domain, IP address, device and browser information to administer the products and Services we offer to you, to improve our products and Services, and for security purposes.

Our website also uses “Cookies” which are pieces of data sent from a web server to a web browser that enable a web server to identify users that visit a site hosted by that server. Feel may use Cookies in order to identify you to our website or App so that Feel can provide more customized information and Services to you. In general, if you choose, you can disable the use of Cookies by reviewing your browser’s preferences and options. For more information on our use of Cookies and how you may control them, please see our Cookie Policy: https://www.feeltherapeutics.com/cookie-policy

‍Information Security

We apply appropriate technical, physical and organizational measures that are reasonably designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, in particular where Personal Data is transferred over a network, and against all other unlawful forms of processing. Access to Personal Data is restricted to authorized recipients on a need-to-know basis. We maintain a comprehensive information security program that is proportionate to the risks associated with the processing. The program is continuously adapted to mitigate operational risks and to ensure the protection of Personal Data taking into account industry-accepted practices.  We also use enhanced security measures (e.g. encryption) when processing sensitive Personal Data. However, the transfer of Personal Data through the internet carries its own inherent risks and we do not guarantee the security of your data transmitted through the internet.  You make any such transfer at your own risk.

‍Data Disclosures

We may disclose Personal Data to our affiliates for any of the purposes described in this Privacy Notice.

We may use third parties, such as our vendors, partners and service providers, to provide or perform Services and functions on our behalf, and to otherwise cooperate in the context of a project. We may make Personal Data concerning individuals available to these third parties, as necessary, to perform these Services and functions, and to fulfil the project. Any access to such Personal Data will be limited to the purpose for which the information was provided.

We may also make Personal Data concerning individuals available to public or judicial authorities, law enforcement personnel and agencies as required by law. Where permitted by law, we may also disclose such information to third parties (including legal counsel) when necessary for the establishment, exercise or defense of legal claims or to otherwise enforce our rights, protect our property or the rights, property or safety of others, or as needed to support external audit, compliance and corporate governance functions.  

Personal Data may be transferred to a party acquiring all or part of the equity or assets of Feel or its business operation in the event of a sale, merger, liquidation, dissolution, or sale or transfer of the substantial assets of Feel or any of its business operations. We may also transfer and share such information to our affiliates within the group, in compliance with applicable law.

We may disclose your Personal Data to third parties with your consent.

We are not responsible for the content or privacy and security practices and policies of third-parties or Services to which links or access are provided through our service. We encourage you to learn about third-parties’ privacy and security policies before providing them with your information.

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International Transfers

Personal Data provided to Feel will be processed by us inside the European Economic Area and will be accessed by our staff and third parties working for us for the purposes set forth in this notice or for other purposes subject to your approval. Your Personal Data may be also held, processed and accessed outside the European Economic Area to countries that have not been determined by the European Commission to provide an adequate level of data protection, for instance the United States. In any such transfer, Feel will ensure that appropriate data protection safeguards (e.g. European Commission’s Standard Contractual Clauses) are in place. To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please contact us using the contact information below.

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Your Options and Rights

By providing Personal Data to us, you understand and agree to the collection, processing, international transfer and use of such information as set forth in this Privacy Notice. Where required by applicable law we will ask your explicit consent.

You may elect to opt-out of our Services at any time by providing Feel with written or electronic notice. Upon receipt of such notice, we will cease contacting you and sharing information concerning you. Please note that if you withdraw your consent, we will be unable to provide you with our Services.

You may access the Personal Data that Feel has on file for you and you may ask that we revise your Personal Data to ensure that it is current and correct. 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, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so under applicable law.

If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained in the email. You may also opt out from receiving commercial email from us and any other promotional communications that we may send to you from time to time, by contacting us via the contact details at the end of this Policy.

If you opt out of receiving commercial email from us or otherwise modify the nature or frequency of such emails, it may take up to ten business days for us to process your request. During that time, you may continue to receive promotional communications from us. If you opt out of receiving commercial messages from us, you will still receive administrative messages from us regarding our Services.

If you are located in the EEA, you may exercise these additional rights in relation to your Personal Data that we hold:

• Withdrawal of consent. Where we rely on consent for the processing of your Personal Data, you have the right to withdraw your consent at any time.
• Access. You have the right to access the Personal Data we hold about you, and to receive an explanation of how we use it and who we share it with.
• Correction. You have the right to correct any Personal Data we hold about you that is inaccurate or incomplete.
• Erasure. You have the right to request for your Personal Data to be erased or deleted.
• Object to processing. You have the right to object to our processing of your Personal Data where we are relying on a legitimate interest.
• Restrict processing. You have a right in certain circumstances to stop us processing your Personal Data other than for storage purposes.
• Portability. You have the right to receive, in a structured, commonly used and machine-readable format, Personal Data that you have provided to us if we process it on the basis of our contract with you, or with your consent, or to request that we transfer such Personal Data to a third party.

Please contact us if you wish to exercise any of these rights. Before processing your requests, we will ask for your identification to ensure you are the requestor. In certain situations, and subject to applicable law, we may not be able or obliged to grant part or all of your individual requests. We also have the right to refuse and/or charge a monetary fee for requests which are manifestly unfounded or excessive, for example because of their repetitive character. You have the right under applicable data protection law to lodge a complaint with a Supervisory Authority.

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Data Retention

We will retain your Personal Data for so long as necessary for the purposes for which they were collected. When determining the retention period, we take into account various criteria, such as the type of products and Services requested by or provided by you, possible re-enrolment with our Service and the impact on the Services we provide you if we delete some information from or about you. We will also retain your Personal Data as required under applicable retention policies or as permitted by applicable law.

Children's Privacy

The Services are not directed to children, and we do not knowingly collect Personal Data from anyone under the age of 18. If you learn that a child has provided us with Personal Data in violation of this Policy, please contact us as indicated below.

Updates to our Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our Personal Data practices. We will post a prominent notice on our website to notify you of any significant changes to our Privacy Notice and indicate when it was most recently updated. You should also check this page from time to time to ensure that you are happy with any changes.

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How to Contact Us

We welcome all requests, suggestions and questions concerning our use of your information. All such communication should be directed to privacy@myfeel.co. You can also write to us at: Skalidi 16-18, Katechaki, Athens 11525, Greece.

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