PRIVACY POLICY
Last Updated: January 07, 2024

AGREEMENT WITH THE TERMS OF THE PRIVACY POLICY

Elegant Access is generally intended for Users who are at least 13 years of age. All Users who are Minors in the jurisdiction in which they reside (generally under the age of 18) must have the permission of, and be directly supervised by, their
parent or guardian to use Elegant Access. If You are a Minor, You must have Your parent or guardian read and agree to the terms of the Privacy Policy prior to You using Elegant Access.

We recommend that You print a copy of the Privacy Policy for Your records.

DEFINITIONS
The following terminology applies to the Terms, Privacy Statement and Disclaimer Notice and all Agreements:

"Client", "You" and "Your" means an individual or business that accesses or uses Elegant Access.

"Lignum Vitae," "Us," "We," and "Our" means Lignum Vitae, LLC, a limited liability company that is registered within the state of Florida.

The "Parties" means you in your individual capacity or as an individual authorized to bind the applicable business entity to the this Agreement.

The "Elegant Access Web Application", which is accessible via a web browser at https://therapy.elegantaccess.online

The "Elegant Access Mobile Application", which is a download that is available for either the Android and iOS operating systems.

The "Elegant Access Computer Identifier" web browser extension, which is a browser extension that identifies a particular web browser to the Elegant Access servers.

"Elegant Access", the "Service" or "Services" refers to the Elegant Access Web Application, the Elegant Access Mobile Application, and the Elegant
Access Computer Identifier web browser extension, singularly and collectively.

"Registration" means the process of registering to access or use Elegant Access. You are "Registered" when You create an account and are issued a username.

The "Content" means all text, graphics, video, audio, links, communications, and other information contained within Elegant Access or on the Elegant Access website.

The "Marks" means any trademarks, service marks, and logos contained either within Elegant Access or on the Elegant Access website that are owned or licensed by Lignum Vitae, LLC.

"User" means any person, entity, business, or web technology that either accesses Elegant Access or its website or causes Elegant Access or its website to be accessed, irrespective of whether a subscription agreement
exists.

"Minor" means any person who is at least 13 years of age but has not yet emancipated according to applicable state law. Most of the time this means that the User is under the age of 18, but some states allow
a User to emancipate with judicial consent, by way of marriage, etc.

The "Terms" means the current version of the Terms of Service that is in effect at any given time.

The "EULA Agreement" means the current version of the End User License Agreement that is in effect at any given time.

The "Privacy Policy" means the current version of the Privacy Policy that is in effect at any given time.

"Registration Information" means the information required to create an account on Elegant Access. This includes the user's legal name, the user's license number, the user's current business address, phone
number, and email address, and other relevant information.

"Patient" means any patient or client of a medical or mental health provider who is a User of Elegant Access.

"Record" means any communication or documentation relating to the identity, diagnosis, evaluation, or treatment of an individual with a medical, mental or emotional condition or disorder, including alcoholism
or drug addiction.

"Recordings" means any documentation made to a patient's Record or charts, documentation or other information submitted to the Elegant Access system, or messages sent to or received from You and any Patient or other
User.

"Record Custodian" means the medical or mental health provider, or their employer or employing contractor, who is legally responsible for the maintenance of the medical or mental health record under federal or state
law. Elegant Access is the Electronic Health Records application that stores such records and Lignum Vitae is the company that licenses Elegant Access. Neither are the legal custodian of the User's records.

"Mobile Store Operator(s)" means Google, Inc.'s software distribution platform for Users who download Elegant Access on an Android device, and Apple Inc.'s software distribution platform for Users who download
Elegant Access on an Apple or other iOS device.

"Web Browser Extension Provider(s)" means the Mozilla Corporation where the Elegant Access Computer Identifier web browser extension is downloaded for the Firefox web browser, Google, Inc. where the Elegant
Access Computer Identifier web browser extension is downloaded for the Chrome web browser, Apple, Inc. where the Elegant Access Computer Identifier web browser extension is downloaded for the Safari web browser, and the Microsoft Corporation
where the Elegant Access Computer Identifier web browser extension is downloaded for the Edge web browser.

"Devices" means any Android or iOS mobile device that is owned, leased, or rented by the User, or any other device that is under the control of the User that contains a supported web browser that is capable
of accessing the Elegant Access Web Application.

"Medical Records" include but are not limited to billing records, payment and claims records, health insurance information, health plan enrollment records, case management records, clinical laboratory test reports, X-rays, wellness and disease management program information, and notes (such as clinical case notes or "SOAP" or "DAP" notes (a method of making notes in a Patient's or client's chart), as well as other records used, in whole or in part, by or for a covered entity to make decisions about individuals, including emails and other correspondence between You and Your Patient. Information about third-party payers who are responsible for the Patient's care and information regarding individuals who are responsible for the care and wellbeing of the Patient, such as parents or guardians, are also included in this definition of Medical Records.

"Medical Provider", "Mental Health Provider", or "Provider" means any medical doctor, doctor of osteopathic medicine, advanced practice nurse practitioner, physician's assistant, mental health counselor, clinical social worker, marriage and familiy counselor, psychologist, or psychiatrist, either registered, licensed, or certified as a medical or mental health provider by the appropriate credentialing agency of their applicable state, or who is employed by the United States government and no license, registration, or certification is required.

"Authentication Credential" means any passwords, PINs, security keys, tokens, public/private keys, and all other authentication devices used to either encrypt or decrypt data on the Elegant Access system, or used to authenticate and access such system.

This Privacy Policy for Elegant Access describes how and why We, Lignum Vitae, might collect, store, use, and/or share ("Process") Your and Your Patients' information when either You
or Your Patient (collectively the "User"), access Elegant Access. Such access includes but is not limited to:

When a User visits Our websites, elegantaccess.online, therapy.elegantaccess.online, or www.lignumvitae.org, or any website of Ours that links to this Privacy Policy; or

When a User Downloads and uses the Elegant Access Mobile Application, the Elegant Access Web Application, or the Elegant Access Computer Identifier web browser extension; or

When a User engages with Us in other related ways, such as sending Us emails, SMS text messages, or engaging with Us through Elegant Access.

Questions or concerns? Reading this Privacy Policy will help You understand Your privacy rights and choices. If You do not agree with Our policies and practices, please do not use Elegant Access. If You still have any
questions or concerns, please contact Us at us at the address found on our website.

SUMMARY OF KEY POINTS

This summary provides key points from Our Privacy Policy, but You can find out more details about any of these topics by clicking the link following each key point or by using Our Table of Contents below to find the section
You are looking for.

What personal information do We process? When You visit, use, or navigate Elegant Access, We may process personal information depending on how You interact with Us and Elegant Access, the choices You make, and the products
and features You use. Learn more about personal information You disclose to Us.

Do We process any sensitive personal information? We may process sensitive personal information, when necessary and with Your consent, or as otherwise permitted by applicable law. Learn more about sensitive information We process.

Do We receive any information from third parties? We may receive information from public databases, medical and mental health providers, other providers, and other outside sources. Learn more about information collected from other sources.

How do We process Your information? We process Your information to provide, improve, and administer Elegant Access, communicate with you, for security and fraud prevention, and to comply with the law. We may also process
Your information for other purposes with Your consent. We process Your information only when We have a valid legal reason to do so. Learn more about how We process Your information.

In what situations and with which parties do We share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom We share Your personal information, including Sensitive Information.

How do We keep Your information safe? We have organizational and technical processes and procedures in place to protect Your personal information. However, no electronic transmission over the internet or information
storage technology can be guaranteed to be 100% secure. Therefore, We cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat Our security and improperly collect, access, steal, or modify
information for You and/or Your Patients. Learn more about how We keep Your information safe.

What are Your rights? Depending on where You are located geographically, the applicable privacy law may mean You have certain rights regarding Your personal information. Learn more about Your privacy rights.

How do You exercise Your rights? The easiest way to exercise Your rights is by sending Us an email to document.write('<'+'a'+' '+'h'+'r'+'e'+'f'+'='+"'"+'m'+'a'+'i'+'l'+'t'+'o'+':'+'s'+'u'+'p'+'p'+'o'+'r'+'t'+'@'+'e'+'l'+'e'+'g'+'a'+'n'+'t'+'a'+'c'+'c'+'e'+'s'+'s'+'.'+'o'+'n'+'l'+'i'+'n'+'e'+"'"+'>'+'s'+'u'+'p'+'p'+'o'+'r'+'t'+'@'+'e'+'l'+'e'+'g'+'a'+'n'+'t'+'a'+'c'+'c'+'e'+'s'+'s'+'.'+'o'+'n'+'l'+'i'+'n'+'e'+'<'+'/'+'a'+'>');, or by contacting Us by United States Mail. We will consider and act upon any request in accordance with applicable data protection laws and this Privacy Policy.

Want to learn more about what We do with any information We collect? Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
14. WHO IS THE CUSTODIAN OF THE RECORDS RECORDED IN ELEGANT ACCESS?

1. WHAT INFORMATION DO WE COLLECT?
Information You or Your Patients disclose to Us
In Short: We collect information that You and Your Patients provide to Us.

We collect personal information that You and Your patients provide to Us upon registering for Service, when You express an interest in obtaining information about Us or the products and services We offer, when You or Your Patients utilize Elegant Access, or when You or Your Patients contact Us.
Personal Information Provided by You. The personal information that We collect depends on the context of Your interactions with Us and Elegant Access, the choices You make, and the products and features You use. The
personal information We collect includes but is not limited to:
Your legal business name;
Your business address;
Your business phone numbers, including any applicable fax numbers;
Your business email addresses;
Your business billing addresses;
Business and professional license numbers issued to You as a business entity or as an individual;
Names of authorized users, employees and subcontractors, vendors, Patients, emergency contacts, and parents/guardians of minor children who are Patients;
Phone numbers of the individuals and entities listed above;
Mailing addresses of the individuals and entities listed above;
Email addresses of the individuals and entities listed above;
Employment information regarding the individuals and entities listed above;
Usernames;
Security Credentials;
Billing and insurance information for Your Patients;
A Universally Unique Identifier (UUID) that uniquely identifies Your computer browser or Device to the Elegant Access servers;
Contact preferences for You and Your Patients; and
Debit/credit card numbers.
Sensitive Information. We also collect sensitive information as permitted by applicable law. We process the following categories of sensitive information, including but not limited to:
Health and mental health data for Your Patients;
Data about the sex life and sexual orientation of Your Patients;
Information revealing race or ethnic origin of Your Patients;
Information revealing religious or philosophical beliefs of Your Patients; and
Social security numbers, tax identification numbers, or other government identifiers for both You as an individual or as a business entity, and for Your Patients.

HIPAA. Much of the information collected by Us is regulated by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), as well as various state laws.

Payment Data. We may collect data necessary to process Your payment if You make purchases or subscribe to subscription services, or information to process payments made by Your Patient's. This data includes the payment instrument
number (usually a credit or debit card number), the expiration date for the payment instrument, the security code associated with the payment instrument, and the billing name and address associated with the payment instrument. All payment
data is processed by Stripe, Inc. or PayPal, Inc.. You may find their privacy notice link(s) here:
https://stripe.com/privacy and https://www.paypal.com/us/legalhub/privacy-full.

Insurance Data. We may collect data necessary to process insurance reimbursement payments. This information may include, but is not limited to, the Patient's name, date of birth, gender, social security number, insurance
identification number, information regarding the insurance policy holder, and information regarding the services provided.

Application Data. We also may collect the following information and use it for the following purposes:

Geolocation Information. We may request access or permission to track location-based information from the Devices or web browser of Your Patients, either continuously or while they are using Elegant Access.
This information is stored by the Elegant Access servers and is only revealed to the Patient's provider of record in the event of an emergency, such as when a patient has threatened suicide. There are strict guards on who can access geolocation information for a Patient, and the Patient is notified within 24 hours that their location has been revealed and by whom.
Device Access. We may request access or permission to certain features from Your web browser or Device, including the Device's camera, microphone, sensors, and other features. We do this to provide telehealth services with the implied consent of both You and Your Patient. If You wish to change Our access or permissions, You may do so in Your Device's settings.

Reminder Messages. We may, with Your Patient's consent, contact Your Patient via SMS text messages, automated telephone calls, push notifications, and device reminders,
to remind Your Patient of upcoming appointments. Such services are available on an opt-in basis and consent for these reminders can be revoked at any time by You or Your Patient.

Device Storage. We may utilize the device storage functionality of Your web browser or Device to store security credentials, unique device identifiers, login information, and other information required by Elegant Access.

Push Notifications. We may request to send You or Your Patients push notifications regarding their account or certain features of Elegant Access. Due to the nature of Elegant Access these notifications will only
be sent to a device when necessary or when requested by You or Your Patient. You or Your Patient may opt out from receiving these types of communications by turning them off in the Device's settings or by disabling them in Elegant Access.

This information is primarily needed to provide services to Our Users, to maintain the security and operation of Elegant Access, for troubleshooting, for health and safety, and for Our internal analytics and reporting purposes.

All information that You provide to Us must be true, complete, and accurate, and You must notify Us of any changes to such information.

Information collected from other sources: In Short: We may collect limited data from public databases, medical and mental health providers, and other outside sources.
In order to enhance Our ability to provide Elegant Access to You and Your Patients, We may obtain information about You and Your Patients from other sources, such as public databases, data providers, and from other third parties, including governmental
sources. This information includes mailing addresses, job titles, email addresses, phone numbers, Internet Protocol (IP) addresses and its associated meta data, information regarding insurance eligibility, and medical or mental health records
pushed from other medical or mental health providers.

2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process Your and Your Patients' information to provide, improve, and administer Elegant Access, to communicate with You and Your Patients, for security and fraud prevention, and to comply with the law. We may also process Your information
for other purposes with Your consent, and Your Patients' information with their consent.

We process personal information for a variety of reasons, depending on how Elegant Access is interacted with, including:
To facilitate account creation and authentication and otherwise manage user accounts. We may process information provided to Us so You and Your Patients can create and log in to their account, as well as keep those accounts in working order.

To deliver and facilitate delivery of Service to the User. We may process information to provide You and Your Patients with access to Elegant Access.

To enable user-to-user communications. We may process information to enable Us to communicate with You and Your Patients, to permit You to communicate with Your Patients, and to permit You to communicate with other Users.

To comply with Our legal obligations. We may process information to comply with Our legal obligations, respond to legal requests, and exercise, establish, or defend Our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share Your personal information, and/or the personal information of Your Patients, including sensitive information, in the following situations:

Business Transfers. We may share or transfer Your and Your Patients' information in connection with any merger or acquisition of all or a portion of Our business to another company.

Patient Data. We may share information regarding specific Patients with other medical and mental health providers at the direction of You or the applicable Patient. In the event this information is shared, only that information which we have specifically
been requested to share will be revealed to the other party. If You elect to Record information into Elegant Access regarding a Patient, You warrant to Lignum Vitae that You either have the Patient's consent to do so, or that You are relying on some other legal authority to do so.

When We use Google Maps Platform APIs. We may share information about the location of You or Your Patients with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). We obtain and store this information on our servers for seven (7)
days. Only the latitude and longitude information of a User's device or web browser are provided to Google Inc., and no personally identifiable information is shared. Since this information is used for emergency purposes only, such as when a Patient is experiencing suicidal
thoughts, it is not possible to opt out of the collection of this data. In the event that a Patient's location data is revealed to a User, the Patient will be notified of the disclosure approximately 24 hours after the disclosure is
requested.

Business Partners. We may share Your and/or Your Patients' information with Our business partners to process credit and debit card payments, to process insurance reimbursements, and for the collection of payments due to Lignum Vitae.

In Response to a Subpoena or Court Order. It is the policy of Lignum Vitae to comply with the privacy provisions of the HIPAA law. HIPAA
specifically requires that a party that stores Protected Health Information (PHI) only provide information in response to a subpoena issued by anyone other than a judge when that party verifies 1) The person who is the subject of the information about the request has been notified so the person has a chance to object to the disclosure,
or 2) A qualified protective order for the information has been sought from the court. Since Lignum Vitae is unable to reasonably verify that either of these conditions have been met, Lignum Vitae is unable
to respond to any subpoena for Patient information. However, Lignum Vitae is legally obligated to comply with any court order requiring disclosure of Patient information, including Protected Health Information. Lignum Vitae is also legally
obligated to respond to any HIPAA Subpoena issued by the United States Department of Justice. Lignum Vitae may also be required to respond to subpoenas issued by certain governmental investigative bodies, such as the Florida Medicaid Fraud Control Unit. Providers are not provided with such sweeping privacy protections under HIPAA and Lignum Vitae may be obligated to respond to valid subpoenas issued for information regarding You as either an individual or as a business entity.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store Your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how We use such technologies and how You can refuse certain cookies is set out in Our Cookie Policy below.

5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We generally keep information regarding You and Your Patients, especially Medical Records, for at least eleven (11) years, unless otherwise required by law.

Medical Records: Each state has differing records retention policies regarding medical and mental health records. While some states require such records be kept for a minimum of 5 years after the Patient's last session, others require these records to be maintained for at least 11 years after the Patient's last session. As a result, We shall maintain
all Medical Records, including mental health records, which are provided to Us by any source, for a period of at least 11 years after the Patient's last session, even if You or Your Patient requests that we remove such Records.

Records which are not Medical Records: Records that are not considered to be Medical Records, including but limited to emails and other correspondence between You and Us, billing and payment information for services
You subscribed to, and such other records shall be kept until they have lost their administrative value, which is generally a period of at least five (5) years. Other records, such as lists, draft documents, and superseded forms, immediately
lose their administrative value and may be permanently removed immediately. Geolocation Information collected from a Patient's web browser or other Device becomes stale after seven (7) days, though Elegant Access only records the Patient's
last known location and does not maintain a log of the Patient's travels.

No Business Purpose: When We have no ongoing legitimate business or legal need to retain You or Your Patient's information, We will either delete or anonymize such information, or, if this is not possible (for example,
because that information has been stored in backup archives), then We will securely store the information and isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect information collected about You and Your Patients through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information We process. This includes encrypting database information while it is at rest and is not
being accessed, encrypting sensitive information on a per Patient basis, and encrypting information that is sent to and from Your web browser or other Device and Our servers. We also utilize security credentials instead of passwords to minimize
the risk of phishing and hacking attacks. Elegant Access is also protected by a firewall, and an application specific firewall is also used to secure the Service from unauthorized access. Further, all record access is audited.

However, despite the safeguards and reasonable efforts to secure the information for You and Your Patients, 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, cybercriminals, or other unauthorized third parties will not be able to defeat Our security and improperly collect, access, steal, or modify
information that has been stored by Us. Although We will do Our best to protect the information that has been entrusted to us, transmission of information to and from Elegant Access is at Your own risk. You should only access Elegant Access within
a secure environment.

7. DO WE COLLECT INFORMATION FROM (OR ABOUT) MINORS?
In Short: We do not knowingly collect data directly from children under 13 years of age, though our databases do contain information about individuals of all ages that has been provided to Us by other medical providers, other mental health providers,
and other third-parties.

We do not knowingly solicit data from children under 13 years of age and require Users to be at least this age in order to Register for an account. By using Elegant Access, You represent that You are at least 18 or that You are the parent or guardian
of such a Minor and consent to such Minor child's use of Elegant Access. If We learn that a child under the age of 13 has Registered for an account, We will immediately move to suspend that account. Please contact Us at us at the address found on our website, to report such concerns.

As a Medical Records Management System, Elegant Access We routinely records information about individuals of all ages. The Children's Online Privacy Protection Act of 1998,
also known as COPPA, which generally restricts the collection of information about children under 13 years of age, does not apply to services that collect medical and mental health records from providers for the sole purpose of recording those
records for the medical or mental health treatment of the child. Therefore, COPPA is not applicable to information provided to Lignum Vitae or Elegant Access by medical or mental health providers, the child's parents or legal guardian, or
other third party sources, where such information is collected to provide medical or mental health services to the child.

8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate Your account at any time.

Withdrawing Your consent: We rely on Your expressed consent to process Your information, as well as the information for Your Patients. You have the right to withdraw Your consent at any time. You can withdraw
Your consent at any time by contacting Us by using the contact details provided in the section "Account Information" section below. However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor,
when applicable law allows, will it affect the processing of Your personal information conducted in reliance on lawful processing grounds other than consent. Further, the withdrawal of Your consent shall not relieve Us of Our obligation to
maintain the information and records provided to Us by You, Your Patients, or other parties. This information cannot be removed from Elegant Access.

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 Your access to Your account; however, the information contained within the account will be maintained in accordance with state and federal law, as well as this Privacy Policy.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If You prefer, You can usually choose to set Your browser to remove and reject cookies. If You choose to remove
or reject cookies, You will not be able to utilize Elegant Access. The Service relies on the ability to place cookies and other data on Your computer or Device to authenticate You to Elegant Access, and to maintain status information regarding
transactions that You undertake while utilizing Elegant Access.

If You have questions or comments about Your privacy rights, You may email Us at us at the address found on our website.

9. 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 Policy.

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If You are a resident of California, Colorado, Connecticut, Utah or Virginia, You are granted specific rights regarding access to Your personal information.

What categories of personal information do We collect?

We have collected the following categories of personal information regarding You and/or Your Patients within the past twelve (12) months:
Category
Examples
Collected

A. Identifiers
Contact details that include but are not limited to: legal business name, legal name of authorized Users, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

B. Personal information as defined in the California Customer Records statute: Name, contact information, education, employment, employment history, and financial information

C. Protected classification characteristics under state or federal law: Gender and date of birth

D. Commercial information
Transaction information, purchase history, financial details, and payment information

E. Biometric information
Fingerprints and voiceprints that are used to authenticate Users to the Elegant Access servers. This information is stored on the User's Device and is never transmitted to Elegant Access.

G. Geolocation data: Device location. This data is collected from Patients and is maintained for a period of seven (7) days. This information can only be revealed to a provider in the event of an emergency, such as when a Patient is experiencing suicidal thoughts. The Patient is notified of this disclosure approximately twenty-four (24) hours after their geolocation data is requested by a Provider.

H. Audio, electronic, visual, thermal, olfactory, or similar information: Images and audio, video or call recordings created in connection with Our business activities

I. Professional or employment-related information: Business contact details in order to provide You Elegant Access at a business level

J. Education Information: Student records and directory information

K. Inferences drawn from collected personal information: Inferences drawn from any of the collected personal information listed above.

L. Sensitive personal Information: Account login information, biometric data, contents of email or text messages, debit or credit card numbers, drivers' licenses, health data, personal data from a known child, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, sex life or sexual orientation, social security numbers, state id card numbers

We will use and retain the collected personal information as needed to provide Elegant Access or for:
Category A - 11 Years
Category B - 11 Years
Category C - 11 Years
Category D - 11 Years
Category E - Until Administrative Value Is Lost
Category G - 1 Week
Category H - 11 Years
Category I - 11 Years
Category J - 11 Years
Category K - 11 Years
Category L - 11 Years

Category L information may be used or disclosed to a service provider or contractor for additional specified purposes. You and Your Patients have the right to limit the use or disclosure of Your sensitive personal information.
We may also collect other personal information outside of these categories through instances where You or Your Patients interact with Us in person, online, or by phone or mail in the context of: Receiving help through Our customer support channels; Participation in customer surveys; and Facilitation in the delivery of Elegant Access and to respond to Your or Your Patient's inquiries.

HOW DO WE USE AND SHARE YOUR PERSONAL INFORMATION?
Learn about how We use Your personal information in the section, HOW DO WE PROCESS YOUR INFORMATION?

Will Your information be shared with anyone else?
We may disclose Your personal information with Our service providers pursuant to a written contract between Us and each service provider. Learn more about how We disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
Most of the data We possess is regulated under the federal HIPPA law or other applicable state laws. As such, any such dissemination of information that includes Protected Health Information must be in compliance with state and federal law. We
do not sell information provided to Us by You or Your Patients.

California Residents:
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits Users who are California residents to request and obtain from Us, once a year and free of charge, information about the categories of personal information
(if any) We disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which We shared personal information in the immediately preceding calendar year. Lignum Vitae does not provide information to third parties for direct marketing purposes. 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 are a Registered User of Elegant Access, You have the right to request removal of unwanted data that You publicly post on Elegant Access. As a Medical Records Management System, information posted to or recorded in Elegant Access is not public and information regarding Patients and Registered Users are not made publicly available.

CCPA Privacy Notice
This section applies only to California residents. Under the California Consumer Privacy Act (CCPA), You have the rights listed below.

The California Code of Regulations defines a "resident" as:
Every individual who is in the State of California for other than a temporary or transitory purpose, and

Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, We must adhere to certain rights and obligations regarding Your personal information.

Your rights with respect to Your personal data
General right to request deletion of the data — Request to delete
Both HIPAA and California law require the maintenance of Medical Records. Since most of the information provided by You to Us is used to create and maintain Medical Records, We are unable to most data from our
database upon Your request.

Right to be informed — Request to know
Depending on the circumstances, You and Your Patients have a right to know:
Whether We collect and use Your or their personal information;

The categories of personal information that We collect;

The purposes for which the collected personal information is used;

Whether We sell or share personal information to third parties;

The categories of personal information that We sold, shared, or disclosed for a business purpose;

The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;

The business or commercial purpose for collecting, selling, or sharing personal information; and

The specific pieces of personal information We collected about You.

In accordance with applicable law, We are not obligated to remove information that constitutes part of a Medical Record under state or federal law.

Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights
We will not discriminate against You if You exercise Your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information
You and Your Patients have the right to direct Elegant Access to limit its use of sensitive personal information to that use which is necessary to perform the essential services provided by Elegant Access. Once We receive the request, we are no longer allowed to use or disclose
the sensitive personal information for any other purpose unless We receive consent for the use or disclosure of sensitive personal information for additional purposes. Please note that sensitive personal information that is collected or
processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as publicly available information.

The following constitutes sensitive information:
Social security information, drivers' license numbers, state ID card numbers, passport numbers;

Account login information;

Credit card numbers, financial account information, or credentials allowing access to such accounts;

Precise geolocation;

Racial or ethnic origin, religious or philosophical beliefs, union membership;

The contents of email and text, unless the business is the intended recipient of the communication;

Genetic data, biometric data, and health data;

Data concerning sexual orientation and sex life;
To exercise Your right to limit use and disclosure of sensitive personal information, please email us at the address found on our website, or write to Us at:
Lignum Vitae, LLC
2048 Howland Blvd
Suite 390267
Deltona, Florida 32739

Verification process
Upon receiving Your request, We will need to verify Your identity to determine You are the same person about whom We have the information in Our system. These verification efforts require Us to ask You to provide information so that We can
match it with information You have previously provided Us. For instance, depending on the type of request You submit, We may ask You to provide certain information so that We can match the information You provide with the information We
already have on file, or We may contact You through a communication method (e.g., phone or email) that You have previously provided to Us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in Your request to verify Your identity or authority to make the request. To the extent possible, We will avoid requesting additional information from You for the purposes of verification. However,
if We cannot verify Your identity from the information already maintained by us, We may request that You provide additional information for the purposes of verifying Your identity and for security or fraud-prevention purposes. We will
delete such additionally provided information as soon as We finish verifying You.

Other privacy rights
You may object to the processing of Your personal information.

You may request correction of Your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the information.

You can designate an authorized agent to make a request under the CCPA on Your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on Your behalf in accordance
with the CCPA.

You may request to opt out from future selling or sharing of Your personal information to third parties. Upon receiving an opt-out request, We will act upon the request as soon as feasibly possible, but no later than fifteen (15) days
from the date of the request submission.
To exercise these rights, You can contact Us by writing to Us at
Lignum Vitae, LLC
2048 Howland Blvd
Suite 390267
Deltona, Florida 32739

You may also contact Us via email at us at the address found on our website, or by referring to the contact details at the bottom of this document. If You have a complaint about how We handle Your data, We would like to hear from You.

Colorado Residents
This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), You have the rights listed below. However, these rights are not absolute, and in certain cases, We may decline Your request as permitted by law.

Right to be informed whether or not We are processing Your personal data;

Right to access Your personal data;

Right to correct inaccuracies in Your personal data;

Right to request deletion of Your personal data;

Right to obtain a copy of the personal data You previously shared with Us; and

Right to opt out of the processing of Your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Lignum Vitae does not process Your information for the purpose of targeted advertising and does not sell your personal data. Further, Lignum Vitae is unable to remove information from any Medical Record, even at Your request, and is unable to provide information contained within any Medical Record as we are not the Records Custodian for those Records.
To submit a request to exercise these rights described above, please email us at the address found on our website, or contact Us by writing to Us at
Lignum Vitae, LLC
2048 Howland Blvd
Suite 390267
Deltona, Florida 32739

If We decline to take action regarding Your request and You wish to appeal Our decision, please email Us at us at the address found on our website.
Within forty-five (45) days of receipt of an appeal, We will inform You in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Connecticut Residents
This section applies only to Connecticut residents. Under the Connecticut Data Privacy Act (CTDPA), You have the rights listed below. However, these rights are not absolute, and in certain cases, We may decline Your request as permitted by
law.

Right to be informed whether or not We are processing Your personal data;

Right to access Your personal data;

Right to correct inaccuracies in Your personal data;

Right to request deletion of Your personal data;

Right to obtain a copy of the personal data You previously shared with us; and

Right to opt out of the processing of Your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling").

Lignum Vitae does not process Your information for the purpose of targeted advertising and does not sell your personal data. Further, Lignum Vitae is unable to remove information from any Medical Record, even at Your request, and is unable to provide information contained within any Medical Record as we are not the Records Custodian for those Records.
To submit a request to exercise these rights described above, please email us at the address found on our website, or contact Us by writing to Us at
Lignum Vitae, LLC
2048 Howland Blvd
Suite 390267
Deltona, Florida 32739

If We decline to take action regarding Your request and You wish to appeal Our decision, please email Us at us at the address found on our website.

Within sixty (60) days of receipt of an appeal, We will inform You in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.

Utah Residents
This section applies only to Utah residents. Under the Utah Consumer Privacy Act (UCPA), You have the rights listed below. However, these rights are not absolute, and in certain cases, We may decline Your request as permitted by law.

Right to be informed whether or not We are processing Your personal data;

Right to access Your personal data;

Right to request deletion of Your personal data;

Right to obtain a copy of the personal data You previously shared with Us; and

Right to opt out of the processing of Your personal data if it is used for targeted advertising or the sale of personal data.
Lignum Vitae does not process Your information for the purpose of targeted advertising and does not sell your personal data. Further, Lignum Vitae is unable to remove information from any Medical Record, even at Your request, and is unable to provide information contained within any Medical Record as we are not the Records Custodian for those Records.

To submit a request to exercise these rights described above, please email us at the address found on our website, or contact Us by writing to Us at
Lignum Vitae, LLC
2048 Howland Blvd
Suite 390267
Deltona, Florida 32739

Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA):

"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.

"Sale of personal data" means the exchange of personal data for monetary consideration.

If this definition of "consumer" applies to you, We must adhere to certain rights and obligations regarding Your personal data.
Your rights with respect to Your personal data

Right to be informed whether or not We are processing Your personal data;

Right to access Your personal data;

Right to correct inaccuracies in Your personal data;

Right to request deletion of Your personal data;

Right to obtain a copy of the personal data You previously shared with Us;

Right to opt out of the processing of Your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling").

Lignum Vitae does not process Your information for the purpose of targeted advertising and does not sell your personal data. Further, Lignum Vitae is unable to remove information from any Medical Record, even at Your request, and is unable to provide information contained within any Medical Record as we are not the Records Custodian for those Records.

Exercise Your rights provided under the Virginia VCDPA
You may contact Us by email at us at the address found on our website, or contact Us by writing to Us at
Lignum Vitae, LLC
2048 Howland Blvd
Suite 390267
Deltona, Florida 32739

If You are using an authorized agent to exercise Your rights, We may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on Your behalf.

Verification process
We may request that You provide additional information reasonably necessary to verify You and Your consumer's request. If You submit the request through an authorized agent, We may need to collect additional information to verify Your identity
before processing Your request.

Upon receiving Your request, We will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform
You of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal
If We decline to take action regarding Your request, We will inform You of Our decision and reasoning behind it. If You wish to appeal Our decision, please email Us at us at the address found on our website.
Within sixty (60) days of receipt of an appeal, We will inform You in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If Your appeal is denied, You may
contact the Attorney General to submit a complaint.

11. 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 Policy 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 Policy,

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 Policy frequently to be informed of how We are protecting Your information.

12. HOW CAN YOU CONTACT Us ABOUT THIS NOTICE?
If You have questions or comments about this notice, You may contact Our Data Protection Officer (DPO), Derek Patterson, by email at us at the address found on our website, by phone at 386-327-2298, or contact Us by writing to Us at
Lignum Vitae, LLC
Derek Patterson
2048 Howland Blvd
Suite 390267
Deltona, FL 32739

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of Your state, You may have the right to request access to the personal information We collect from you, change that information, or delete it. To request to review, update, or delete Your personal information, please contact Us by email at us at the address found on our website, or contact Us by writing to Us at
Lignum Vitae, LLC
2048 Howland Blvd
Suite 390267
Deltona, Florida 32739

14. WHO IS THE CUSTODIAN OF THE RECORDS RECORDED IN ELEGANT ACCESS?
In Short: You, as the Provider, are the sole custodian of any Records You enter into the Elegant Access system.

While Lignum Vitae may maintain and store any records You enter into the Elegant Access system on a technological basis, You as the Provider are solely responsible for the accuracy of any Records entered by or entrusted to
You. Your Patients cannot exercise any right or remedy directly to Lignum Vitae or Elegant Access that authorizes them to request the modification or deletion of any Medical Record. Any and all such requests must be made to the Record Custodian.

COOKIE POLICY
Last Updated: January 07, 2024

This "Cookie Policy" explains how Lignum Vitae, LLC uses cookies and similar technologies to recognize you when you utilize Our Services. This Cookie Policy explains what these technologies are and why we use them,
as well as your rights to control Our reliance on them.

DEFINITIONS
The following terminology applies to the Terms, Privacy Statement and Disclaimer Notice and all Agreements:

"Client", "You" and "Your" means an individual or business that accesses or uses Elegant Access.

"Lignum Vitae," "Us," "We," and "Our" means Lignum Vitae, LLC, a limited liability company that is registered within the state of Florida.

The "Parties" means you in your individual capacity or as an individual authorized to bind the applicable business entity to the this Agreement.

The "Elegant Access Web Application", which is accessible via a web browser at https://therapy.elegantaccess.online

The "Elegant Access Mobile Application", which is a download that is available for either the Android and iOS operating systems.

The "Elegant Access Computer Identifier" web browser extension, which is a browser extension that identifies a particular web browser to the Elegant Access servers.

"Elegant Access", the "Service" or "Services" refers to the Elegant Access Web Application, the Elegant Access Mobile Application, and the Elegant

Access Computer Identifier web browser extension, singularly and collectively.

"Registration" means the process of registering to access or use Elegant Access. You are "Registered" when You create an account and are issued a username.

The "Content" means all text, graphics, video, audio, links, communications, and other information contained within Elegant Access or on the Elegant Access website.

The "Marks" means any trademarks, service marks, and logos contained either within Elegant Access or on the Elegant Access website that are owned or licensed by Lignum Vitae, LLC.

"User" means any person, entity, business, or web technology that either accesses Elegant Access or its website or causes Elegant Access or its website to be accessed, irrespective of whether a subscription agreement exists.

"Minor" means any person who is at least 13 years of age but has not yet emancipated according to applicable state law. Most of the time this means that the User is under the age of 18, but some states allow a User to emancipate with judicial consent, by way of marriage, etc.

The "Terms" means the current version of the Terms of Service that is in effect at any given time.

The "EULA Agreement" means the current version of the End User License Agreement that is in effect at any given time.

The "Privacy Policy" means the current version of the Privacy Policy that is in effect at any given time.

"Registration Information" means the information required to create an account on Elegant Access. This includes the user's legal name, the user's license number, the user's current business address, phone number, and email address, and other relevant information.

"Patient" means any patient or client of a medical or mental health provider who is a User of Elegant Access.

"Record" means any communication or documentation relating to the identity, diagnosis, evaluation, or treatment of an individual with a medical, mental or emotional condition or disorder, including alcoholism or drug addiction.

"Recordings" means any documentation made to a patient's Record or charts, documentation or other information submitted to the Elegant Access system, or messages sent to or received from You and any Patient or other User.

"Record Custodian" means the medical or mental health provider, or their employer or employing contractor, who is legally responsible for the maintenance of the medical or mental health record under federal or state law. Elegant Access is the Electronic Health Records application that stores such records and Lignum Vitae is the company that licenses Elegant Access. Neither are the legal custodian of the User's records.
"Mobile Store Operator(s)" means Google, Inc.'s software distribution platform for Users who download Elegant Access on an Android device, and Apple Inc.'s software distribution platform for Users who download Elegant Access on an Apple or other iOS device.

"Web Browser Extension Provider(s)" means the Mozilla Corporation where the Elegant Access Computer Identifier web browser extension is downloaded for the Firefox web browser, Google, Inc. where the Elegant Access Computer Identifier web browser extension is downloaded for the Chrome web browser, Apple, Inc. where the Elegant Access Computer Identifier web browser extension is downloaded for the Safari web browser, and the Microsoft Corporation where the Elegant Access Computer Identifier web browser extension is downloaded for the Edge web browser.

"Devices" means any Android or iOS mobile device that is owned, leased, or rented by the User, or any other device that is under the control of the User that contains a supported web browser that is capable of accessing the Elegant Access Web Application.

"Medical Records" include but are not limited to billing records, payment and claims records, health insurance information, health plan enrollment records, case management records, clinical laboratory test reports, X-rays, wellness and disease management program information, and notes (such as clinical case notes or "SOAP" or "DAP" notes (a method of making notes in a Patient's or client's chart), as well as other records used, in whole or in part, by or for a covered entity to make decisions about individuals, including emails and other correspondence between You and Your Patient. Information about third-party payers who are responsible for the Patient's care and information regarding individuals who are responsible for the care and wellbeing of the Patient, such as parents or guardians, are also included in this definition of Medical Records.

"Medical Provider", "Mental Health Provider", or "Provider" means any medical doctor, doctor of osteopathic medicine, advanced practice nurse practitioner, physician's assistant, mental health counselor, clinical social worker, marriage and familiy counselor, psychologist, or psychiatrist, either registered, licensed, or certified as a medical or mental health provider by the appropriate credentialing agency of their applicable state, or who is employed by the United States government and no license, registration, or certification is required.

"Authentication Credential" means any passwords, PINs, security keys, tokens, public/private keys, and all other authentication devices used to either encrypt or decrypt data on the Elegant Access system, or used to authenticate and access such system.

In some cases we may use cookies to collect personal information, or that becomes personal information if we combine it with other information.

What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting
information.

Cookies set by the website owner (in this case, Lignum Vitae, LLC) are called "first-party cookies." Cookies set by parties other than the website owner are called "third-party cookies." Third-party cookies enable third-party features or functionality to be provided on or through the website (e.g., advertising, interactive content, and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.

Why do we use cookies?

We use first party cookies for several reasons. Some cookies are required for technical reasons in order for Elegant Access to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Online Properties. We do not use these forms of cookies. Third parties may serve cookies through Elegant Access for analytics and other purposes. This is described in more detail below.

How can I control cookies?
You have the right to decide whether to accept or reject cookies. Essential cookies, the only form of cookies we use, are required for the ordinary operation of Elegant Access and cannot be rejected without interfering with the provision
of Services. Therefore, if you disable to ability for Us to utilize cookies you will no longer be able to utilize Elegant Access.
The specific types of first and third-party cookies served through Elegant Access and the purposes they perform are described below (please note that the specific cookies served may vary depending on the specific Online Properties you visit):
Cookie generated by applications based on the PHP language. This is a general purpose identifier used to maintain user session variables. It is normally a random generated number and is used for many purposes, including maintaining a logged-in
status for a User between pages. This cookie is generated by elegantaccess.online. It is a session cookie and is deleted a short time after you finish using Elegant Access.
Cookie generated by Cloudflare. This is a general purpose identifier used to identify your web session to the Cloudflare server. Cloudflare helps to provide fast access to our servers and helps us to mitigate hacking attempts. This cookie is generated
by www.cloudflare.com. It is a session cookie and is deleted a short time after you finish using Elegant Access.

How can I control cookies on my browser?
As the means by which you can refuse cookies through your web browser controls vary from browser to browser, you should visit your browser's help menu for more information.

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit:
Digital Advertising Alliance
Digital Advertising Alliance of Canada
European Interactive Digital Advertising Alliance

What about other tracking technologies, like web beacons?
Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called "tracking pixels" or "clear gifs"). These are tiny graphics files that contain
a unique identifier that enables us to recognize when someone has visited our Website or opened an email including them. This allows us, for example, to monitor the traffic patterns of users from one page within a website to another, to deliver
or communicate with cookies, to understand whether you have come to the website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of email marketing campaigns. In many
instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.

Do you use Local Storage?
Websites and browser plugins may also use Local Storage to collect and store information about your use of our services, for fraud prevention, and for other site operations.

Elegant Access utilizes Local Storage to store unique information about your browser or Device to help uniquely identify you. We do this for auditing purposes and to help ensure the security of Patient Records. Local Storage is required to utilize

Elegant Access and disabling them will result in your inability to login to the Elegant Access system.

Third parties may serve cookies on your computer or mobile device to help ensure that you are a real human and not a robot attempting to access our servers. We may also use third party cookies to help us analyze web traffic, but only to the extent
third parties are not able to uniquely identify Users. The information collected through this process does not enable them to identify your name, contact details, or other details that directly identify you or your Patients.

How often will you update this Cookie Policy?
We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal, or regulatory reasons. Please therefore revisit this Cookie Policy regularly to stay informed about
our use of cookies and related technologies.

The date at the top of this Cookie Policy indicates when it was last updated.

Where can I get further information?
If you have any questions about our use of cookies or other technologies, please contact us at:
Lignum Vitae, LLC
2048 Howland Blvd
Suite 390267
Deltona, FL 32739

Phone: 386-327-2298
Fax: 386-232-5002