Privacy Policy

Introduction

KeborMed, Inc., a Delaware corporation ("KeborMed," "we," "us," or "our"), operates the website kebormed.com. We are committed to protecting your privacy. This Privacy Policy describes our practices regarding the personal information we collect from visitors to our website (kebormed.com). How this Policy applies depends on our role, as explained in "Our Role" below.

Geographic Scope: This Privacy Policy is designed to comply with United States federal and state privacy laws, including the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and with the General Data Protection Regulation (GDPR) regarding information of individuals in the European Union.

This Policy does not apply to any websites, mobile applications, or other online services that do not link to this Policy, or any face-to-face or telephonic interactions with us. Our website may contain links to other websites operated by third parties, which we do not control and for which we are not responsible.

Our Role

Website. For information about visitors to our website, including people who contact us through it, KeborMed determines how personal information is used, and this Policy applies in full.

Kubyk Platform. Kubyk is a product of KeborMed. The Kubyk website (kubyk.health), the Kubyk Platform portals and any associated mobile applications, and the information Kubyk customers process through them, are covered by the Kubyk Privacy Policy at kubyk.health/privacy, not by this Policy.

Information We Collect

Information You Provide

• Contact Information: Name, work email address and organization provided when you contact us.
• Feedback and Correspondence: Information you provide when you contact us through our contact form, such as the topic you choose and your message, or otherwise correspond with us.

Our contact form sends your message to KeborMed by email, through our email service provider, and sends you an email confirming that we received it. The website itself does not store what you submit.

Information Collected Automatically

We or our service providers may automatically collect certain information from your device, including: IP addresses, language preferences, device identifiers, browser information, and pages visited. We also collect information about how you interact with the website, including navigation paths, time spent, and features used. We use cookies, pixel tags, and similar technologies to collect this information on our website. Except for strictly necessary cookies, we use them only as described in "Cookies and Your Choices" below. We work with third-party analytics providers, such as Google Analytics, to understand how people find and interact with our website.

Cookies and Your Choices

When you first visit our website, a cookie banner lets you accept all, reject all, or choose which categories of optional cookies we may use. You can change your choice at any time with the "Your Privacy Choices" link at the bottom of our pages, or block or delete cookies in your browser settings.

Visitors in the United States: we use analytics cookies unless you opt out, and marketing cookies only if you allow them. We determine this from your browser's time zone.

Visitors outside the United States: we use analytics and marketing cookies only if you allow them.

Global Privacy Control: If your browser sends a Global Privacy Control (GPC) signal we do not set marketing cookies.

We use the following categories of cookies:

• Strictly Necessary Cookies: Required for the website to work and to remember your cookie choice (the kebormed_consent cookie). Cannot be disabled. Provider: KeborMed.
• Analytics Cookies: Help us understand how visitors use our website. Provider: Google (Google Analytics 4).
• Marketing Cookies: Used by our advertising and marketing partners to measure our campaigns and show relevant ads on other websites. Providers: Google (advertising signals), Meta Platforms (Meta Pixel), LinkedIn (Insight Tag), and Swan.

Display Preferences: If you choose a color theme or pause animations on our website, your choice is kept in your browser's local storage (kebormed_color_scheme and kebormed_motion). These settings stay on your device and are not sent to us.

Legal Basis for Processing

We process your personal information based on the following legal grounds:

• Contract Performance: Processing necessary to respond to your requests and to take steps you ask us to take before entering into a contract with you.
• Legitimate Interest: Processing for analytics, service improvement, security monitoring, and fraud prevention.
• Consent: Processing for marketing communications and non-essential cookies (you may withdraw consent at any time).
• Legal Obligation: Processing required to comply with applicable laws, regulations, or legal process.

How We Use Your Information

We use your personal information to:

• Provide and operate our website, and improve it using website information
• Respond to your messages and communicate with you, including the email confirming that we received a message sent through our contact form
• Personalize your experience and send marketing communications (with your consent)
• Comply with legal obligations, respond to legal process, and protect our rights

How We Share Your Information

Service Providers

We may engage other companies to perform business-related functions on our behalf, including:

• Cloud infrastructure providers (Microsoft Azure: website hosting)
• Analytics providers (Google Analytics: website usage analysis)
• Email service providers (SendGrid: delivery of contact form messages and confirmation emails)
• Advertising and marketing partners (Google, Meta Platforms, LinkedIn, and Swan), on our website only and only with your consent, as described in "Cookies and Your Choices"

We authorize these parties to use personal information only as necessary to perform their functions and require them to protect your information.

Legal Requirements

We may disclose your information if required to do so by law, or in the good faith belief that such disclosure is necessary to: comply with legal obligations; respond to lawful requests from government authorities; protect our rights, property, or safety; or protect against legal liability.

No Selling of Personal Information

We do not sell your personal information, and we have not sold personal information in the preceding twelve (12) months. We do not share personal information with third parties for their own direct marketing purposes. Advertising cookies on our website (see "Cookies and Your Choices") may constitute a sale or sharing of personal information for cross-context behavioral advertising under California law. You can control those cookies as described in "Your Privacy Choices" below.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law. Specific retention periods:

Data Security

We implement industry-standard technical and organizational measures to protect your information. Despite our efforts, we cannot guarantee absolute security in all circumstances.

• Security Certifications: KeborMed maintains ISO 13485 (medical device quality management) and ISO 27001 (information security management) certifications.
• Encryption: All data is encrypted in transit and at rest using industry-standard encryption.

Data Breach Notification

In the event of a security breach affecting your personal information, we will notify you as required by applicable law. We will provide notification without undue delay after confirming a breach that affects your personal information.

Your Rights and Choices

Opt Out of Marketing

You may opt out of marketing communications by following the unsubscribe instructions in any marketing email, or by contacting us at privacy@kebormed.com.

Deletion Requests

You may request deletion of your personal information by emailing privacy@kebormed.com. We will respond to deletion requests within the period required by applicable law, subject to any legal retention requirements.

Cookie Preferences

You can manage your cookie preferences at any time with the "Your Privacy Choices" link at the bottom of our pages. You can also block or delete cookies in your browser settings; strictly necessary cookies are needed for the website to work.

California Privacy Rights (CCPA/CPRA)

This section applies to California residents under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA).

Your Rights

California residents have the following rights:

• Right to Know: Request information about how we have collected, used, and shared your personal information.
• Right to Access: Request a copy of the personal information we maintain about you.
• Right to Delete: Request deletion of the personal information we have collected or maintain about you.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt-Out of Sale/Sharing: To the extent personal information is shared for cross-context behavioral advertising through advertising cookies on our website, you may opt out at any time. We do not otherwise sell or share your personal information.

Your Privacy Choices

KeborMed does not sell your personal information. Advertising cookies on our website may constitute a sale or sharing under California law. To opt out, click the "Your Privacy Choices" link at the bottom of our pages and turn off Marketing cookies, or turn on Global Privacy Control in your browser, which we honor automatically. You may also contact us at privacy@kebormed.com.

Exercising Your Rights

To exercise your California privacy rights, contact us at privacy@kebormed.com or by mail at the address below. You are entitled to exercise these rights free from discrimination. We will verify your identity before processing your request.

Other U.S. State Privacy Rights

Residents of other U.S. states with consumer privacy laws may have similar rights, including the right to access, correct and delete personal information and to opt out of targeted advertising. You can exercise them in the same way: through "Your Privacy Choices", Global Privacy Control, or by contacting privacy@kebormed.com. Occasionally we may be unable to fulfill a request, for example if we cannot verify your identity, or if we are required by law to retain it. If that happens, we will explain why, and you may appeal by emailing privacy@kebormed.com.

Children's Privacy

Our website is intended for use by individuals 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If we discover we have collected personal information from someone under 18, we will delete it promptly. If you believe we have collected information from someone under 18, please contact us immediately at privacy@kebormed.com.

Rights of EU Data Subjects (GDPR)

In compliance with the General Data Protection Regulation (GDPR), individuals in the European Union have specific rights regarding their personal data:

• Right of Access: You have the right to ask us for confirmation on whether we are processing your personal data, and access to the personal data and related information on that processing.
• Right of Rectification: You have the right to have your personal data corrected, as permitted by law.
• Right to Erasure: You have the right to ask us to delete your personal data, as permitted by law.
• Right to Restriction of Processing: You have the right to request the limiting of our processing under certain circumstances.
• Right to Data Portability: You have the right to receive the personal data that you have provided to us, in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to our processing of your personal data as permitted by law.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a competent supervisory authority subject to applicable law.
• Right to Withdraw Consent: If we are processing your personal data based on your consent, you have the right to withdraw your consent at any time.

To exercise any of these rights, please contact us at privacy@kebormed.com.

Changes to This Privacy Policy

We reserve the right to amend this Privacy Policy at any time. When we make changes, we will post the updated notice on our website and update the "Last Updated" date. For material changes, we will provide notice via email or through our website. Please review this Policy periodically for any changes.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

• Email: privacy@kebormed.com
• Mail: KeborMed Inc., Attn: Privacy Officer, 815 Superior Ave. East, Suite 1618, Cleveland, Ohio 44114