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Privacy Policy

Last Revised: January 6, 2015

SHEnetics, Inc. (“Company”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (as defined below) we collect from users of our mobile application (“Application”).

1. Questions; Contacting Company; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or phone number:

SHENETICS INC.

Attn: Privacy Policy

5580 La Jolla Blvd #25

La Jolla, CA 92037

2. A Note to Users Outside of the United States. If you are a non U.S. user of the Application, by using the Application and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you consent to such transfer.

3. Types of Data We Collect. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

(a) Information You Provide to Us.

· We may collect Personal Data from you, such as your first and last name, e-mail, and password when you create an account to log in to the Application (“Account”).

· We may also collect biometric data from the unique features of your face to create an Account, identify you as a user of the Application, and log you in to the Application.

· If you use our Application on your mobile device, we may collect your phone number and the unique device id number.

· If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information. If you want to deactivate this feature, you can either reinstall the Application or deactivate GPS on your mobile device.

· Certain functionalities of the Application may require our collection of your phone number. We may associate that phone number to your mobile device identification information.

· If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.

· When you participate in one of our surveys, we may collect additional profile information.

· We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, and other requested information if you contact us via e-mail regarding support for the Application.

· We may also collect Personal Data, such as at other points in our Application or services that state that Personal Data is being collected.

(b) Information Collected From Your Device’s Address Book. The Application includes an “address book feature”, which securely collects and uploads the phone numbers and contact information of those persons listed as contacts in your mobile device or computer’s address book (your “Contacts”). SHEnetics may collect and upload this information to enable you to seamlessly access your Address Book Information from your computer or mobile device(s) via the Application.

(c) Media Files. The Application may access the media files on your computer or mobile device, such as music, video and image files. This information is collected locally on the Application and is not uploaded to our servers or otherwise exported from your computer or mobile device.

(d) Information Collected via Technology. · Information Collected by Our Servers. To make our Application more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, MAC address, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

· Mobile Services. We may also collect non-personal information from your mobile device if you have downloaded our Application. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the Application(s), and information about the type of device you use, such as your Unique Device Identifier (UDID), name and type of your device, operation system and mobile network details. In addition, in the event our Application(s) crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Application(s). This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.

· Local Storage. We may collect and store information (including Personal Data) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

4. Use of Your Personal Data

(a) General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:

· facilitate the creation of and secure your Account on our Application;

· identify you as a user in our system;

· provide improved administration of our Application and services;

· provide the Application as well as the services you request;

· improve the quality of experience when you interact with our Application;

· send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;

· send you administrative e-mail notifications, such as security or support and maintenance advisories;

· respond to your inquiries related to employment opportunities or other requests;

· to solicit your feedback; and

· send newsletters, surveys, offers, and other promotional materials related to our Application and for other marketing purposes of Company.

(b) Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Application. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

5. Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

(a) Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Application; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Company. These third party service providers are required not to use your Personal Data other than to provide the services requested by Company.

(b) Affiliates. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

(c) Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.

(d) Social Networking Sites. Our Application may enable you to post content to SNSs (e.g., Facebook or Twitter). If you choose to do this, we will provide information to such SNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such SNSs. We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs.

(e) Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Company; (c) to protect or defend the rights or property of Company or users of the Application; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

6. Your Choices Regarding Your Information. You have several choices regarding use of information on our Application:

(a) Email Communications. We will periodically send you free newsletters and e-mails that directly promote the use of our Application. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.

(b) Changing or Deleting Your Personal Data. All Users may review, update, correct or delete the Personal Information in their User account (including any imported contacts) by contacting us or by editing their profile via the Application. If you completely delete all of your Personal Information, then your User account may become deactivated. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

(c) Applications. You can stop all collection of information by the Application by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You may at any time opt-out from further allowing us to have access to your location data by disabling your devices GPS or other location based services.

7. Security of Your Personal Data. Company is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while Company uses reasonable efforts to protect your Personal Data, Company cannot guarantee its absolute security.

8. Changes to This Privacy Policy. This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here http://www.shenetics.com/privacy.html and we will change the “Last Updated” date above. You should consult this Privacy Policy regularly for any changes.