OVERVIEW

This Privacy Policy explains how KetoSwiss Inc. (“KetoSwiss,” “Company,” “we,” “us,” or “our”) collects, uses,

discloses, retains, and protects personal information in connection with our wholesale website, wholesale ordering

platform, clinic partnership program, communications, events, marketing activities, and related professional services

and interactions (collectively, the “Services”).

KetoSwiss Inc., 300 Delaware Ave., Suite 210 #391, Wilmington, DE 19801, is the controller or business responsible

for personal information processed under this Privacy Policy unless otherwise stated.

Our Services are primarily designed to support United States-based businesses, clinics, healthcare professionals,

professional purchasers, and their authorized representatives. Certain public-facing portions of the Site may also be

accessed by consumers, including individuals seeking general information about KetoSwiss or requesting assistance

locating an authorized clinic. Consumers are not permitted to establish wholesale accounts or purchase Products

through the wholesale program unless separately eligible and authorized.

By using our Services or providing information to us, you acknowledge the practices described in this Privacy Policy.

Where consent is required by applicable law, we will request it separately.

1. INFORMATION WE COLLECT

We collect information based on how you interact with KetoSwiss and the Services. This may include:

• Business and professional information, such as clinic or business name, business address, professional title, role, specialty, authorized locations, business registration information, professional credentials or licensure, and resale or tax-exemption documentation.

• Contact information, such as name, business email address, telephone or mobile number, mailing address, and communication preferences.

• Account and registration information, including login credentials, account identifiers, authorized account users, account status, onboarding information, and acceptance of applicable agreements or policies.

• Order and transaction information, including Products ordered, quantities, order history, billing and shipping information, payment status, returns, credits, and transaction records. Payment card information may be processed directly by our payment service providers rather than stored by KetoSwiss.

• Communication information, including emails, support requests, forms, meeting requests, event registrations, survey responses, and other communications with KetoSwiss.

• Marketing, lead, and inquiry information, including information provided when requesting information, attending an event, meeting with KetoSwiss, joining a mailing list, submitting a clinic inquiry, requesting assistance locating an authorized clinic, or otherwise expressing interest in KetoSwiss Products or programs. Consumer clinic-location inquiries may include basic contact and general location information, such as name, email address, telephone number, city, state, or ZIP code.

• Technical and device information, including IP address, browser type, device information, operating system, log data, referring pages, and information about how you interact with the Site.

• Cookie and analytics information, including browsing activity, pages viewed, links clicked, session information, and similar online activity.

• Preference information, such as communication preferences, areas of professional interest, Product interests, and

  engagement with KetoSwiss communications.

• Social media information when you interact with KetoSwiss through social platforms, social media widgets, or

  other third-party services.

• Verification information reasonably necessary to verify a business, account, professional credential, resale status,

  or account ownership.

We may obtain information directly from you, from your organization or authorized representatives, from service

providers involved in providing the Services, from professional or public sources, and from third parties where

permitted by law.

2. PATIENT INFORMATION AND PROTECTED HEALTH INFORMATION

The standard KetoSwiss wholesale relationship, wholesale Site, CRM, automation, messaging, consumer clinic-

location inquiry functions, and related business systems are not intended for the collection, storage, or transmission of

patient/client-level medical information, consumer health information, or protected health information (“PHI”).

Clinics and other professional purchasers must not submit patient names, diagnoses, medical histories, laboratory

results, clinical notes, medical records, or other PHI through wholesale orders, shipping instructions, CRM records,

account fields, forms, text messages, support requests, or other standard wholesale systems. Consumers using a

clinic-location or general inquiry form should not submit diagnoses, symptoms, medications, medical records,

laboratory results, treatment information, or other medical or sensitive health information.

Use of the wholesale Site does not establish KetoSwiss as a Clinics HIPAA business associate.

If KetoSwiss and a Clinic later enter into a separate written arrangement that expressly involves PHI or patient-level

services, the privacy and security requirements for that arrangement will be addressed separately, including a

Business Associate Agreement where legally required.

Consumer clinic-location and general inquiry forms are intended only for basic contact and referral assistance. Where

implemented, KetoSwiss may require an acknowledgment that the form is not intended for medical records or

sensitive health information. Any separate consent for marketing email or SMS/MMS communications will be

requested independently where required.

3. HOW WE USE INFORMATION

We may use personal information to:

• review and administer wholesale account applications and Authorized Clinic Partner relationships;

• verify business information, professional credentials, account ownership, and resale or tax-exemption status;

• create and manage accounts and authorized users;

• process, fulfill, ship, track, and administer wholesale orders;

• process payments, credits, returns, and related transactions;

• provide customer service, clinic support, Product information, educational resources, and operational

• communications;

• communicate about Products, Product availability, program updates, policies, events, training, educational opportunities, and clinic resources;

• respond to inquiries and requests;

• develop and maintain relationships with prospective clinics, leads, partners, and existing Authorized Clinic Partners;

• send marketing and promotional communications where permitted by law and consistent with your preferences;

• operate, secure, maintain, troubleshoot, and improve our websites, systems, Products, programs, and Services;

• perform analytics, market research, business planning, quality assurance, and Product or service development;

• detect fraud, misuse, unauthorized access, Product diversion, security incidents, or other prohibited activity;

• administer Product complaints, quality concerns, adverse-event reports, recalls, market withdrawals, or regulatory matters;

• comply with legal, regulatory, tax, accounting, recordkeeping, and contractual obligations;

• establish, exercise, or defend legal claims; and

• support corporate governance, risk management, audits, transactions, and business operations.

4. LEGAL BASES FOR PROCESSING

Depending on applicable law and the context, we may process personal information based on consent, performance

of or steps related to a contract, compliance with legal obligations, protection of vital or legal interests, and our

legitimate business interests.

Our legitimate interests may include operating and improving our business, maintaining professional relationships,

securing our systems, preventing fraud and diversion, communicating with customers and prospective customers,

marketing our Products and Services, and protecting KetoSwiss, its customers, and its intellectual property.

Where processing is based on consent, you may withdraw that consent prospectively as permitted by applicable law.

5. COOKIES, ANALYTICS, AND ONLINE TECHNOLOGIES

We and our service providers may use cookies, tags, local storage, analytics tools, and similar technologies to operate

the Site, maintain account sessions, remember preferences, understand Site usage, improve performance, measure

communications and campaigns, and prevent fraud or misuse. KetoSwiss does not currently intend to use the

wholesale Site for cross-site behavioral advertising or consumer advertising retargeting. If our practices materially

change, we will update this Privacy Policy and provide any choices required by applicable law.

Some technologies are necessary for the Site to function. Others may be used for analytics, performance

measurement, communications, or personalization, subject to applicable law and available privacy choices.

Where required, we will provide cookie or privacy controls that allow you to manage certain non-essential

technologies.

Where required by applicable law, KetoSwiss honors legally recognized universal opt-out preference signals, including

Global Privacy Control (GPC).

6. MARKETING EMAILS

If you provide your email address or otherwise opt in or qualify to receive professional or marketing communications,

KetoSwiss may send information about Products, educational content, clinic programs, events, research, promotions,

and other KetoSwiss news.

You may unsubscribe from marketing emails using the unsubscribe mechanism included in the message or by

contacting us.

Even if you opt out of marketing communications, we may continue to send non-marketing communications relating to

your account, orders, Product safety, agreements, policy changes, or other transactional or legally required matters.

7. SMS/MMS AND MOBILE COMMUNICATIONS

If you choose to opt in to receive text or multimedia messages from KetoSwiss, we may use your mobile number to

send communications such as Product information, educational content, clinic program information, account or

ordering updates, event information, and marketing or promotional communications.

Message frequency may vary. Message and data rates may apply.

Consent to receive marketing SMS/MMS messages is not a condition of purchase or participation in the KetoSwiss

wholesale program.

You may opt out of marketing messages at any time by replying STOP or using another opt-out method provided in

the message. Where available, you may reply HELP for assistance or follow the support instructions provided in the

message.

We may use mobile messaging platforms, telecommunications providers, and other service providers to facilitate

delivery of mobile communications.

Mobile opt-in information and consent will not be sold or shared with third parties for their own marketing or

promotional purposes. Information may be disclosed to service providers as necessary to deliver and administer the

messaging service and as otherwise permitted or required by law.

If KetoSwiss launches a formal recurring mobile messaging program, additional SMS/MMS Terms & Conditions may

apply and will be provided at or before enrollment.

8. HOW WE DISCLOSE INFORMATION

We may disclose personal information to the following categories of recipients where appropriate:

• Service providers and processors that support website hosting, e-commerce, payment processing, order fulfillment, shipping, customer support, communications, CRM systems, analytics, security, professional services, and other business operations.

• Some service providers may rely on underlying technology platforms, telecommunications providers, cloud infrastructure providers, integrations, or subprocessors to perform services for KetoSwiss. These providers may process personal information only as permitted by their contractual role, applicable law, and the instructions of the party responsible for the information.

• Payment and transaction providers that process payments and related transaction information.

• Shipping, logistics, and fulfillment providers necessary to deliver Products and administer orders.

• Technology providers, including e-commerce, website, cloud, CRM, analytics, communications, and security providers.

• Professional advisers, including attorneys, accountants, auditors, consultants, insurers, and other advisers.

• Government agencies, regulators, courts, law enforcement, or other parties when disclosure is required or permitted by law or reasonably necessary to protect rights, safety, property, or legal interests.

• Business transaction parties in connection with an actual or proposed merger, financing, acquisition, restructuring, sale of assets, bankruptcy, or similar corporate transaction.

• Other parties at your direction or with your authorization.

We may also disclose aggregated, de-identified, or anonymized information that does not reasonably identify an individual, subject to applicable law.

9. SALE, SHARING, AND ONLINE PRIVACY CHOICES

KetoSwiss does not sell personal information for monetary compensation.

KetoSwiss does not currently intend to use the wholesale Site for cross-site behavioral advertising or consumer advertising retargeting. Certain analytics or online technology disclosures may nevertheless be regulated under applicable U.S. state privacy laws depending on the technology used and the legal definition that applies.

Where applicable law provides an opt-out right relating to a technology or disclosure used by KetoSwiss, KetoSwiss will provide the required method to exercise that right.

Where required by applicable law, KetoSwiss honors legally recognized universal opt-out preference signals, including Global Privacy Control (GPC).

10. INTERNATIONAL DATA PROCESSING

KetoSwiss is based in the United States. Our Services and service providers may process or access personal information in the United States and other countries where KetoSwiss or its service providers operate.

Privacy and data protection laws may differ between jurisdictions. When applicable law requires safeguards for an international transfer of personal information, KetoSwiss will use appropriate transfer mechanisms or contractual protections.

11. DATA RETENTION

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to maintain wholesale and professional relationships, administer orders and accounts, comply with legal and regulatory requirements, maintain business and tax records, resolve disputes, enforce agreements, address Product safety or quality matters, and protect against fraud or misuse.

Retention periods vary based on the type of information, the relationship involved, applicable legal requirements, and

legitimate business needs.

When information is no longer reasonably required, we may delete, anonymize, or otherwise dispose of it in

accordance with applicable law and our retention practices.

12. DATA SECURITY

KetoSwiss uses reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, use, alteration, disclosure, or destruction. Depending on the systems and information involved, safeguards may include encryption in transit, access restrictions, authentication controls, logging and monitoring, backups, confidentiality obligations, vendor security requirements, and other measures appropriate to

the risk.

No internet transmission, website, electronic storage system, or security measure can be guaranteed to be completely secure. You are responsible for protecting your account credentials and promptly notifying KetoSwiss of suspected unauthorized account access.

13. YOUR PRIVACY RIGHTS

Depending on where you reside and applicable law, you may have rights concerning your personal information, which

may include:

• the right to know or access personal information we maintain about you;

• the right to request correction of inaccurate personal information;

• the right to request deletion of certain personal information;

• the right to obtain certain information in a portable format;

• the right to opt out of certain sale, sharing, targeted advertising, or profiling activities;

• the right to withdraw consent where processing is based on consent;

• the right to appeal certain privacy-request decisions where required by law; and

• the right not to receive unlawful discriminatory treatment for exercising applicable privacy rights.

These rights are not absolute and may be subject to exceptions under applicable law.

To protect personal information, KetoSwiss may need to verify your identity and, where applicable, your authority to

act on behalf of another person before completing a request.

14. U.S. STATE PRIVACY RIGHTS

Residents of certain U.S. states may have additional privacy rights under applicable state privacy laws.

Where required, KetoSwiss will provide eligible individuals with the ability to request access, correction, deletion,

portability, and applicable opt-outs concerning personal information.

Authorized agents may submit requests where permitted by law, subject to verification requirements.

KetoSwiss will not unlawfully discriminate against an individual for exercising applicable privacy rights.

California residents may also have rights under applicable California privacy laws, including rights concerning access,

correction, deletion, and certain disclosures or uses of personal information.

Where applicable, California residents may request information concerning certain disclosures for direct marketing

purposes under California Shine the Light law.

15. BUSINESS-TO-BUSINESS, PROFESSIONAL, AND LIMITED CONSUMER INQUIRIES

Because the Site is intended primarily for businesses and professionals, much of the information KetoSwiss processes relates to individuals acting in a professional or business capacity. KetoSwiss may also process limited contact and general location information from consumers who request assistance locating an authorized clinic or

submit another general inquiry.

We may use professional contact information to communicate with Clinics, healthcare professionals, business representatives, prospective partners, leads, and Authorized Clinic Partners about the KetoSwiss wholesale program, Products, educational resources, events, and business opportunities, subject to applicable law and communication

preferences.

16. CHILDREN

The KetoSwiss wholesale Site and Authorized Clinic Partner Program are intended for adults acting in a business or professional capacity and are not directed to children.

KetoSwiss does not knowingly collect personal information from children under 13 through the wholesale Site. If we learn that such information has been collected inappropriately, we will take reasonable steps to delete it as required by law.

17. THIRD-PARTY WEBSITES AND SERVICES

Our Site may contain links to or integrate with third-party websites, platforms, applications, or services.

Third parties may have their own privacy practices and policies. KetoSwiss is not responsible for the privacy practices of independent third parties, and we encourage you to review their policies before providing information.

18. CHANGES TO THIS PRIVACY POLICY

KetoSwiss may update this Privacy Policy periodically to reflect changes in our Services, technologies, business practices, or legal requirements.

The current version will be posted on the Site with the applicable “Last Updated” date.

Where required by law, we may provide additional notice or obtain consent for material changes.

19. CONTACT US AND PRIVACY REQUESTS

For questions about this Privacy Policy or to submit a privacy request, contact:

KetoSwiss Inc.

Attention: Privacy / Data Protection

300 Delaware Ave.

Suite 210 #391

Wilmington, DE 19801

Email: [email protected]

Phone: 866-434-8385

Website: keto.swiss

Privacy requests may be subject to identity and authority verification as permitted by law.

20. INFORMATION ABOUT OTHER PEOPLE

If you provide KetoSwiss with personal information about another individual, such as another authorized clinic representative, employee, contractor, or business contact, you are responsible for ensuring that you are authorized to provide that information and, where required, that the individual has been informed about the disclosure and

applicable privacy practices.

You are also responsible for ensuring that information you provide about another person is accurate to the best of your

knowledge.

21. CRM, LEAD, AND RELATIONSHIP MANAGEMENT

KetoSwiss may maintain information about prospective clinics, leads, Authorized Clinic Partners, business contacts, and other professional relationships in customer relationship management (CRM) and related business systems.

This information may include contact details, professional role, organization, relationship history, meetings and communications, event participation, Product or program interests, educational interests, ordering history, communication preferences, and engagement with KetoSwiss communications.

We use this information to manage professional relationships, respond to inquiries, provide relevant information and

support, plan follow-up communications, improve our programs, and conduct permitted business-to-business

marketing and relationship-management activities.

22. EVENTS, PHOTOGRAPHS, AND RECORDINGS

When you register for or attend a KetoSwiss conference, meeting, webinar, training, trade show, clinic event, or other event, we may collect registration information, attendance information, professional information, communications, and related event data.

Photographs, video, or audio may be captured at certain events. Where appropriate or required by law, KetoSwiss will provide notice and obtain any required consent before using identifiable images, recordings, testimonials, or similar content for marketing or promotional purposes.

If a telephone call, video conference, webinar, or other communication is recorded for training, quality assurance, documentation, or other purposes, KetoSwiss will provide notice when required by applicable law.

23. SOCIAL MEDIA AND THIRD-PARTY PLATFORMS

KetoSwiss may maintain pages, profiles, channels, or other presences on social media and professional networking platforms. When you interact with KetoSwiss through those platforms, we may receive information such as your profile information, comments, messages, reactions, engagement information, and other information made available through the platform.

The platform operator may independently collect and process information about your use of its services for its own purposes, including analytics, personalization, and advertising. Those activities are governed by the platform operators own privacy policies and terms, and KetoSwiss does not control all aspects of that independent processing.

We may use information received through social platforms to communicate with you, understand engagement with KetoSwiss content, manage professional relationships, and support permitted marketing and market-research activities.

24. PROFILING AND AUTOMATED PROCESSING

KetoSwiss and its service providers may use analytics, segmentation, automation, or AI-enabled functionality to help operate business systems, organize professional contacts, support communications, understand professional interests and engagement, identify Site or Product interests, assist with customer service, or detect potential security,fraud, or diversion risks. Such tools may be provided through CRM, communications, analytics, or other technology

platforms used on KetoSwiss’s behalf.

KetoSwiss does not intend to use the wholesale Site or CRM to make solely automated clinical decisions or decisions that produce legal or similarly significant effects concerning an individual. Where applicable law provides rights concerning automated decision-making, KetoSwiss will provide applicable protections, including human review where required.

25. INTERNATIONAL PRIVACY RIGHTS AND SUPERVISORY AUTHORITIES

Although the wholesale Services are primarily intended for U.S.-based businesses and professionals, individuals located in other jurisdictions may have additional rights under applicable privacy laws, including laws in the European Economic Area, the United Kingdom, or Switzerland.

Where those laws apply, you may have the right to contact or lodge a complaint with the competent data protection supervisory authority in your jurisdiction. You may also contact KetoSwiss using the information in Section 19 so that we can address your privacy concern directly.