WELLMIND BIOMED

PRIVACY NOTICE

Last updated June 01, 2021

Thank you for choosing to be part of our community at Wellming Biomed Technology Holdings Ltd., doing business as Wellmind Biomed ("Wellmind Biomed", "we", "us", "our"). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at info@wellmind.com.hk.

When you use our mobile application, as the case may be (the "App") and more generally, use any of our services (the "Services", which include the App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately. This privacy notice applies to all information collected through our Services (which, as described above, includes our App), as well as, any related services, sales, marketing or events.

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE USE YOUR INFORMATION?

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

4. HOW LONG DO WE KEEP YOUR INFORMATION?

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

6. WHAT ARE YOUR PRIVACY RIGHTS?

7. CONTROLS FOR DO-NOT-TRACK FEATURES

8. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

9. DO WE MAKE UPDATES TO THIS NOTICE?

10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

11. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT

FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the App, express an interest in obtaining information about us or our products and Services, when you participate in activities on the App or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the App, the choices you make and the products and features you use.

The personal information we collect may include the following:

Personal Information Provided by You. We collect names; email addresses; usernames; passwords; and other similar information.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information collected through our App

In Short: We collect information regarding your mobile device, push notifications, when you use our App.

If you use our App, we also collect the following information:

- Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, sms messages, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

- Mobile Device Data. We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID and information about the features of our App you accessed.

- Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our App for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each

purpose listed below.

We use the information we collect or receive:

- To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.

- To post testimonials. We post testimonials on our App that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at info@wellmind.com.hk and be sure to include your name, testimonial location, and contact information.

- Request feedback. We may use your information to request feedback and to contact you about your use of our App.

- To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.

- To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

- Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the App.

- Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.

- To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.

- To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

- To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our App, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS?" below).

- Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

- To deliver our eye tracking service. We are collecting the user’s facial movement data, in particular the eye movement data relative to the phone. We want to know which part of the screen the user is looking at for a set period of time. We want to analyze the user’s eye movement path when presented with a visual stimulus (e.g. photo) so as to see whether it matches the profile of ASD (autism spectrum disorder) patient eye movement or that of a person without ASD.

Please find working example attached:

Twenty 414 * 896 px pictures are presented to a participant on an iPhone screen, one at a time and 3 seconds for each viewing, with every picture containing a set of naturalistic targets (people, animals, indoor and outdoor objects) representative of natural or social environments. The pictures used in this invention, as well as sample fixation profiles of both ASD patients and typically developing children aged 3 to 18 (hereinafter referred as scanpaths) were collected from the “Saliency4ASD: Visual attention modeling for Autism Spectrum Disorder” ICME 2019 Grand Challenge data set.

The TrueDepth API would track the participant’s eye gaze position, then the app will convert the positions to become x- and y-coordinates relative to the screen and timestamps in the order of milliseconds (hereinafter referred as eye gaze paths). The eye gaze paths are then pre-processed and feature engineered for further annotation using the rater emulation model trained with the GazeCom dataset.

After each timestamped coordinate is labeled by a Random Forest classifier as either a fixation or other class of eye movement (e.g. saccade, post-saccadic oscillation, noise) from the eye movement data collected from the phone, a scanpath is created by conjoining episodes of fixations. We use the scanpaths for comparison with sample profiles of ASD and typically developing children.

Please also find reference where the analysis originated:

Startsev, M., & Dorr, M. (2019, July). Classifying autism spectrum disorder based on scanpaths and saliency. In 2019 IEEE International Conference on Multimedia & Expo Workshops (ICMEW) (pp. 633-636). IEEE.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

- Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.

- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

- Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

- Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.

For the eye tracking test offered by our app service, NO data will be shared with any third parties. We will not store the captured data, but only the final results corresponding to the user test after our analysis. A video for the entire test will be given back for user’s local storage, and we will delete the video afterwards.

4. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cyber criminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our App is at your own risk. You should only access the App within a secure environment.

6. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

If you have questions or comments about your privacy rights, you may email us at info@wellmind.com.hk.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may access your account settings and update your preferences.

7. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

8. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names andaddresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the App, you have the right to request removal of unwanted data that you publicly post on the App. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the App, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

9. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at info@wellmind.com.hk or by post to:

Wellming Biomed Technology Holdings Ltd.

Unit 502, 5/F, Biotech Centre 1, No. 9 Science Park Avenue West, Hong Kong,

Science Park

Shatin, Hong Kong

Hong Kong

11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please email: info@wellmind.com.hk.