1. Introduction

This Privacy Policy (our “Privacy Policy”) supplements Arima Health Technology, Inc.’s (“Company,” “we,” “us,” and “our”) Terms of Service and describes how Company and Medical Groups collect, use, maintain, protect, and disclose Personal Data about you through the use of the Services. By “Personal Data,” we mean information that is personally identifiable to you.

Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Data and how we will treat it. If you do not agree with this Privacy Policy, your choice is not to use the Services. By accessing or using the Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates. This Privacy Policy may change from time to time. Any updated Privacy Policy will be effective when posted.

This Privacy Policy also does not apply to information pertaining to job applicants or our employees, contractors, or agents.

2. Protected Health Information

Please see the Medical Groups’ Notice of Privacy Practices to understand how we protect, use and disclose your protected health information as defined under the Health Insurance Portability and Accountability Act of 1996 and related laws and regulations (“HIPAA”). If your Personal Data is protected health information, we treat the protected health information in accordance with HIPAA and the Notice of Privacy Practices and not this Privacy Policy. To the extent this Privacy Policy conflicts with our HIPAA obligations or the Notice of Privacy Practices, we comply with HIPAA obligations or the Notice of Privacy Practices.

3. Use of the Services by Children

The Services are not intended for children under the age of 18. Children under the age of 18 are strictly prohibited from using the Services. We do not knowingly collect Personal Data from persons who are under the age of 18. If you are under the age of 18, do not use or provide any information on the Services or on or through any of their features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under the age of 18, we will delete that information. If you believe we might have any Personal Data from a child under the age of 18, please contact us at contact@arimahealth.com.

If you access or use the Services, you represent and warrant that you are either at least 18 years old or otherwise have adequate authority and capacity to consent to use the Services under applicable state laws, federal laws or the authorization of a parent or legal guardian who agrees to be bound by the Terms and this Privacy Policy. If you are under 18 and lack sufficient authority to access or use the Services, do not use or provide any information on the Services.

4. Personal Data We Collect About You

We collect different types of Personal Data about you. This section is intended to describe the Personal Data that we may collect about you.

We collect the following types of Personal Data from and about Users of the Services:

• name, postal address, billing address, shipping address, e-mail address, mobile telephone number, driver’s license (or other government identification) information, including number, photo, and other associated information, date of birth, credit or debit card number (for payment purposes only), photos of you, biometric data, facial scans, your medical history, and health information;

• traffic data, location data, logs, referring/exit pages, date and time of your visit to the Services, error information, clickstream data, and other communication data and the resources that you access and use on the Services;

• your Internet connection, the equipment you use to access the Services, and usage details;

5. How We Collect Your Personal Data

We collect Personal Data:

• directly from you when you provide it to us, such as:

  • information that you provide by filling in forms on the Services (this includes information provided at the time of registering to use the Services, using Medical Groups Provider consultation services, purchasing products, reporting a problem with the Services, or requesting further services), and your User Contributions (as described in Section 8);

  • records and copies of your correspondence (including email addresses), if you contact us; and

  • details of transactions you carry out through the Services and of the fulfillment of your requests (you may be required to provide financial information before placing a request through the Services).

• automatically as you navigate through the Services (information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies) – see additional detail in Section 6 below; and

• from third parties, for example, our business partners.

6. Personal Data Collected Through and Use of Automatic Data Collection Technologies

As you navigate through and interact with the Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

• details of your visits to the Services, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to the Services, error information, clickstream data, and other communication data and the resources that you access and use on the Services; and

• information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, and browser type.

The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve the Services and to deliver a better and more personalized service by enabling us to:

• estimate our audience size and usage patterns;

• store information about your preferences, allowing us to customize the Services according to your individual interests; or

• recognize you when you return to the Services.

The technologies we use for this automatic data collection include, among others:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or mobile device. On your computer or device, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting, you may be unable to access certain parts of the Services. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Services. You may be able to refuse, disable, or delete cookies and similar technologies through your browser settings. Because each browser is different, consult the instructions provided by your browser (typically in the “Help” section). If you disable cookies or similar technologies, some functionality of the Services may no longer be available.

• Pixels. Pixels are transparent images embedded in a website, email, or ad, and which contain a link to an external server. When a User interacts with an email, navigates to our Services, or views an ad, the User’s browser downloads the invisible image file. That action triggers a request from the pixel server, providing the server owner with knowledge of who downloaded the pixel as well as information like the operating system used, the type of browser used, the time the pixel was interacted with, the IP address, and more.

• Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of certain parts of the Services. Google Analytics uses cookies and other tracking technologies to help the Services analyze how users use the Services. You can find out more about how Google uses data when you visit the Services by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.

• Soliish. We use an analytics service provided by [Soliish] to collect certain information related to your use of certain parts of the Services. Soliish uses [cookies and other tracking technologies to help the Services analyze how users use the Services.] You can find out more about how Soliish uses data, please visit Soliish’s website and pages that describe Soliish’s use of data, such as https://www.soliish.com/privacy-policy.

7. How We Use Your Personal Data

We use your Personal Data for the business purposes described below:

• provide the Services;

• provide services and products to you;

• provide you with information you request from us;

• respond to inquiries;

• for internal business operations;

• for legal, security, and safety reasons;

• enforce our rights arising from contracts;

• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

• notify you about changes;

• provide you with newsletters, advertisements, and other promotional communications (with your consent);

• to contact you in response to a request;

• evaluate and improve the Services;

• to fulfill any other purpose for which you provide it;

• for any other purpose with your consent; and

• provide you with notices about your Account.

With your consent, we may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications or by contacting us at contact@arimahealth.com.

8. Disclosure of Your Personal Data

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy.

We may disclose Personal Data that we collect or you provide as described in this Privacy Policy:

• to service providers and other third parties we use to support our business (the services provided by these organizations include providing IT and infrastructure support services, and ordering, marketing, and payment processing services);

• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Company about the Service Users are among the assets transferred;

• for marketing purposes relating to our products and services;

• to artificial intelligence service providers;

• to affiliates;

• to fulfill the purpose for which you provide it (for example, we may disclose your personal information to a health care provider);

• for any other purpose disclosed by us when you provide the information; and

• with your consent.

We may also disclose your Personal Data:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;

• to enforce or apply our Terms and other agreements, including for billing and collection purposes; and

• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others (this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

We may use and disclose anonymized, de-identified, or aggregated information about Users that does not identify such Users for any purpose permitted by law without restriction.

You also may provide information (hereinafter, “posted”) to other users of the Services or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable.

9. Choices About How We Use and Disclose Your Personal Data

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for our advertising to you, and other targeted advertising.

We strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

• Tracking Technologies and Advertising. You can set your browser or operating system to refuse all or some cookies or to alert you when cookies are being sent. In addition, you can activate or deactivate certain cookies through our Cookie Policy. If you disable or refuse cookies, please note that some parts of the Services may then be inaccessible or not function properly.

• Promotional Offers from Company. If you do not wish to have your email address used by Company to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or by contacting us. This opt out does not apply to information provided to Company as a result of a Service purchase or your use of our Services.

• Targeted Advertising. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

We do not control the collection and use of your information collected by third parties as described in our Terms. These third parties may aggregate the information they collect with information from their other customers for their own purposes.

10. Third-Party Websites and Links

This Privacy Policy does not address the privacy practices of third parties, including your health care providers or health plan, device manufacturers, and third-party applications or websites linked through the Services (including social media platforms). We do not control third parties and are not responsible for their platforms, privacy policies, or use of your information. Information you submit directly to third parties is subject to that third party’s privacy policy.

11. Your Rights Regarding Your Personal Data

You can review and change your Personal Data by logging into the Services and changing your Account information. You may also contact us at contact@arimahealth.com regarding any of your rights under applicable state laws; any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible; or to delete your Account. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

See state-specific sections below on your rights under specific state laws.

12. Do Not Track Signals

We currently do not use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.

Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals.

13. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. The safety and security of your information also depends on you. Where you have chosen a password for the use of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We use encryption technology for information sent and received by us.

Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to the Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services or in your operating system.

14. Washington and Nevada Individuals

For individuals in Washington and Nevada, please refer to our Consumer Health Data Privacy Policy for additional information about the processing of your Personal Data that is “consumer health data” as defined under those laws.

15. Individuals in Other States

You may have rights under other state consumer privacy laws, including California, Colorado, Connecticut, Oregon, Texas, Utah, and Virginia. Please contact us at contact@arimahealth.com if you have questions or would like to exercise a right under these laws.

16. International Users

The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Any information you provide to us through use of the Services may be stored and processed, transferred between and accessed from the United States and other countries that may not guarantee the same level of protection of personal data as the one in which you reside. However, we will handle your Personal Data in accordance with this Privacy Policy regardless of where your Personal Data is stored/accessed.

17. Changes to Our Privacy Policy

We may change this Privacy Policy at any time. If we make material changes to how we treat our Users’ Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Services’ home page and invite you to review (and accept, if necessary) the changes. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting the Services and reviewing this Privacy Policy to check for any changes.

18. Contact Information

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below.

How to Contact Us:

contact@arimahealth.com

19. Retention of Personal Information

Unless otherwise set forth in these Privacy Policies, we retain Personal Data only as long as reasonably necessary for business operations, archival purposes, and/or to satisfy legal requirements. When determining retention periods, we consider the amount, nature, and sensitivity of Personal Data; the risk of harm from unauthorized use or disclosure; the purposes for processing; whether those purposes can be achieved through other means; and business and legal requirements.

Residual copies may remain in backup and archival systems for a limited time, after which the information will be deleted or put beyond use where deletion is not possible.

Notice of Privacy Practices

Last updated: 1/20/2026

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

This Notice of Privacy Practices (the “Notice”) describes how Medical Groups, as an affiliated covered entity composed of multiple distinct medical groups including but not limited to Sleep Clinics of America, P.C.; Sleep Clinics of Oregon, P.C.; Sleep Clinics of Kansas, P.C.; Sleep Medicine Clinic of America New York, P.C.; Sleep Clinics of California, P.C. (collectively, “we” or “our”) may use and disclose your protected health information to carry out treatment, payment, or business operations and for other purposes that are permitted or required by law. “Protected health information” or “PHI” is information about you, including demographic information, that may identify you and that relates to your past, present or future physical health or condition, treatment or payment for health care services.

This Notice also describes your rights to access and control your protected health information.

USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION:

Your protected health information may be used and disclosed by our health care providers, our staff, and others outside of our office that are involved in your care and treatment for the purpose of providing health care services to you, to support our business operations, to obtain payment for your care, and any other use authorized or required by law.

TREATMENT:

We will use and disclose your protected health information to provide, coordinate, or manage your health care and any related services. This includes the coordination or management of your health care with a third party. For example, your protected health information may be provided to any other health care provider with whom you have an existing treatment relationship to ensure the necessary information is accessible to diagnose or treat you.

PAYMENT:

Your protected health information may be used to bill or obtain payment for your health care services. For example, we may use your PHI in connection with processing payments for services provided to you.

HEALTH CARE OPERATIONS:

We may use or disclose, as needed, your protected health information in order to support the business activities of this office. These activities include, but are not limited to, improving quality of care, providing information about treatment alternatives or other health-related benefits and services, development or maintaining and supporting computer systems, legal services, and conducting audits and compliance programs, including fraud, waste and abuse investigations. We may de-identify and anonymize your information such that it is no longer considered protected health information or personally identifiable information and as such, will not contain any reference to you. In that instance, we may modify or create derivative works which contain this de-identified and anonymized information and may use that information as may be necessary to enhance the services we are providing. In addition, we may use this de-identified information for non-commercial purposes including but not limited to analytics, research, preparation of case studies and other educational and research related publication and usage. Under no circumstances will we sell or commercially market your information.

USES AND DISCLOSURES THAT DO NOT REQUIRE YOUR AUTHORIZATION

We may use or disclose your protected health information in the following situations without your authorization. These situations include the following uses and disclosures: as required by law; for public health purposes; for health care oversight purposes; for abuse or neglect reporting; pursuant to Food and Drug Administration requirements; in connection with legal proceedings; for law enforcement purposes; to coroners, funeral directors and organ donation agencies; for certain research purposes; for certain criminal activities; for certain military activity and national security purposes; for workers’ compensation reporting; relating to certain inmate reporting; and other required uses and disclosures. Under the law, we must make certain disclosures to you upon your request, and when required by the Secretary of the Department of Health and Human Services to investigate or determine our compliance with the requirements of the Health Insurance Portability and Accountability Act (“HIPAA”). State laws may further restrict these disclosures.

USES AND DISCLOSURES THAT REQUIRE YOUR AUTHORIZATION:

Other permitted and required uses and disclosures will be made only with your consent, authorization or opportunity to object unless permitted or required by law. In such cases, without your authorization, we shall not use or disclose your protected health information.

You have the right to receive an accounting of certain disclosures of your protected health information that we have made, paper or electronic, except for certain disclosures which were pursuant to an authorization, for purposes of treatment, payment, healthcare operations (unless the information is maintained in an electronic health record), or for certain other purposes.

You have the right to obtain a paper copy of this Notice, upon request, even if you have previously requested its receipt electronically by e-mail.

REVISIONS TO THIS NOTICE:

We reserve the right to revise this Notice and to make the revised Notice effective for protected health information we already have about you as well as any information we receive in the future. You are entitled to a copy of the Notice currently in effect. Any significant changes to this Notice will be posted on the Services. You then have the right to object or withdraw as provided in this Notice.

BREACH OF HEALTH INFORMATION:

We will notify you if a reportable breach of your unsecured protected health information is discovered.

Notification will be made to you no later than 60 days from the breach discovery and will include a brief description of how the breach occurred, the protected health information involved and contact information for you to ask questions.

COMPLAINTS:

Complaints about this Notice or how we handle your protected health information should be directed to our HIPAA Privacy Officer. If you are not satisfied with the manner in which a complaint is handled you may submit a formal complaint to the Department of Health and Human Services, Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/. We will not retaliate against you for filing a complaint.

We must follow the duties and privacy practices described in this Notice. If you have any questions about this Notice, please contact us at contact@arimahealth.com and ask to speak with our HIPAA Privacy Officer.

Consumer Health Data Privacy Policy

Last updated: 1/20/2026

This notice supplements the Privacy Policy and applies to personal data defined as “consumer health data” subject to the Washington State My Health My Data Act (MHMDA), the Nevada Health Data Privacy Act (NHDPA), or other applicable state consumer health privacy law.

Consumer Health Data We Collect

As described in the Personal Data We Collect About You section of the Privacy Policy, the data we collect depends on the context of your interactions with us and the choices you make (including your privacy settings), the Services you use, your location, and applicable law. Because consumer health data is defined very broadly, many of the categories of data we collect could also be considered consumer health data.

Examples of consumer health data may include:

• Information about your health-related conditions, symptoms, status, diagnoses, testing, or treatments (including surgeries, procedures, medications, or other interventions). For example, we may collect such information through surveys or other communication with you for research studies and improving product accessibility.

• Measurements of bodily functions, vital signs, or characteristics, including photographs, which may also be considered biometric information under the MHMDA, the NHDPA, or other applicable state consumer health privacy law.

• Precise location information that could reasonably indicate your attempt to acquire or receive health services or supplies.

• Information that could identify your attempt to seek health care services or information, including services that allow you to assess, measure, improve, or learn about your or another person’s health.

• Other information that may be used to infer or derive data related to the above or other health information.

Sources of Consumer Health Data

As described further in the How We Collect Your Personal Data section of the Privacy Policy, we collect personal data (which may include consumer health data) directly from you, from your interactions with our Services, from third parties, and from publicly available sources.

Why We Collect and Use Consumer Health Data

We collect and use consumer health data for the purposes described in the How We Collect Your Personal Data and Personal Data Collected Through and Use of Automatic Data Collection Technologies sections of the Privacy Policy. Primarily, we collect and use consumer health data as reasonably necessary to provide you with the Services you have requested or authorized. This may include delivering and operating the Services and their features, personalization of certain Service features, ensuring the secure and reliable operation of the Services and the systems that support them, troubleshooting and improving the Services, and other essential business operations that support the provision of the Services (such as analyzing our performance, meeting our legal obligations, developing our workforce, and conducting research and development).

We may use consumer health data for other purposes for which we give you choices and/or obtain your consent as required by law – for example, for advertising or marketing purposes. See the Choices About How We Use and Disclose Your Personal Data section of the Privacy Policy and the How to Exercise Your Rights section below for more details on the controls and choices you may have.

Our Sharing of Consumer Health Data

We may share each of the categories of consumer health data described above for the purposes described in the Disclosure of Your Personal Data section of the Privacy Policy. In particular, we may share personal data, including consumer health data, with your consent or as reasonably necessary to complete any transaction or provide any Service you have requested or authorized, as described above.

For example, we share your content with third parties when you tell us to do so. And we may disclose data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process.

Third Parties With Which We Share Consumer Health Data

As necessary for the purposes described above, we share consumer health data with the following categories of third parties:

• Service providers. Vendors or agents (“processors”) working on our behalf may access consumer health data for the purposes described above. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and Services may need access to data to provide those functions.

• Business partners. We may share consumer health data with other companies, for example, where you use a Service that is cobranded and jointly operated with another company, or where you use our Services to interact with another company.

• Financial institutions & payment processors. When you make a purchase or enter into a financial transaction, we will disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services.

• Parties to a corporate transaction. We may disclose consumer health data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.

• Affiliates. We enable access to data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our Services and operate our business.

• Government agencies. As described in our Privacy Policy, we disclose data to law enforcement or other government agencies when we believe doing so is necessary to comply with applicable law or respond to valid legal process.

• Other third parties. In certain circumstances, it may be necessary to provide data to other third parties, for example, to comply with the law or to protect our rights or those of our customers.

• Other users and individuals. If you use our Services to interact with other Users of the Service or other recipients of communications, we will share data, including consumer health data, as directed by you and your interactions.

• The public. You may select options available through our Services to publicly display and disclose certain information, such as your profile, demographic data, content and files, or geolocation data, which may include consumer health data.

How to Exercise Your Rights

If you are covered by the MHMDA, the NHDPA, or other applicable consumer health privacy law then you may have certain rights with respect to consumer health data, including rights to access, delete, or withdraw consent relating to such data, subject to certain exceptions. You can request to exercise such rights using the various tools and mechanisms described in the Choices About How We Use and Disclose Your Personal Data section of the Privacy Policy. For example, depending on the Service you use, you can access and make choices about your data through product controls. You can also access and clear some of your data through your web browser. And if you want to access or control consumer health data processed by us that is not available via those tools or directly through the Service you use, you can always contact us at contact@arimahealth.com.

If your request to exercise a right is denied, you may appeal that decision by contacting our support team at contact@arimahealth.com. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint, the Nevada State Attorney General at https://ag.nv.gov/complaints/file_complaint/, or other regulatory authority as applicable.