Terms of use

IF YOU EXPERIENCE A MEDICAL EMERGENCY, IMMEDIATELY CALL 911. IF YOU ARE EXPERIENCING A MENTAL HEALTH EMERGENCY, DIAL 988 OR GO TO YOUR NEAREST EMERGENCY ROOM. DO NOT USE THIS SERVICE FOR EMERGENCY MEDICAL NEEDS.

Frontera Health, Inc.

Terms of Use

Dated: 12/20/2025

Carefully read these terms and conditions of use (these “Terms of Use” or these “Terms”) as they govern your access to and use of Frontera Health, Inc.’s (“Frontera“, “we“, “us“, and “our”) Platform and Services. These Terms of Use constitute a legally binding agreement made between you, whether personally or on behalf of an entity (“you“), and Frontera, concerning your access to and use of the Platform and Services. By clicking “Accept,” accessing the Platform, or using the Services, you affirmatively consent to be bound by these Terms of Use as set forth in the “Electronic Contracting, Acceptance and Agreement to Terms” section below. Your acceptance of, and compliance with, these Terms of Use is a condition to your use of the following:

• https://www.fronterahealth.com/ (our “Website”);
• Frontera software tools, which may be available on Google Play and the Apple App Store (our “App(s)”); and
• The services (“Services”) made available through our Website and/or App(s).

The business support services, including clinical support tools, our Website and/or App(s) are collectively referred to as our “Platform.” These Terms of Use govern two distinct types of users: (1) clinics and clinicians who license the Platform under a license agreement for business purposes (“Platform Licensees“), and (2) patients and their families who receive clinical Services through Providers using the Platform (“Service Recipients“). All users, whether Platform Licensees or Service Recipients, must create a user account and agree to these Terms of Use to access and use the Platform or Services. Platform Licensees acknowledge and agree that data generated by their employees, contractors, and consultants through use of the Platform (including usage data, interaction data, clinical workflow data, and any content created or uploaded) may be collected, stored, and used by Frontera for AI development and training, Platform improvement, quality assurance, and research and development purposes. To the extent such data does not constitute protected health information (“PHI“) or can be de-identified in accordance with applicable law, all such data and any AI models, algorithms, or derivative works created therefrom shall be and remain the sole and exclusive property of Frontera. Frontera contracts with Frontera Health New Mexico, Frontera Medical P.A., and may contract with any other members of any Frontera affiliated entity, independent clinical practices or healthcare providers (collectively, the “Medical Groups”). Each Medical Group is an independent medical group, and individual healthcare providers within such Medical Groups are referred to individually as “Providers.” Medical Groups and Providers provide online telehealth, clinical consultations, services, and/or treatment. Frontera is not a covered entity under Health Insurance Portability and Accountability Act (“HIPAA”) but acts as a business associate to the Medical Groups, which are HIPAA covered entities. In its capacity as a business associate, Frontera collects, stores, and processes PHI, including recordings of clinical sessions that may

include audio, video, transcripts, session notes, behavioral data, treatment responses, and other data capturing interactions between Providers and patients (including children with Autism Spectrum Disorder (“ASD“), and other neurodevelopment and behavioral disorders), on behalf of the Medical Groups in accordance with executed Business Associate Agreements (“BAAs“) and applicable HIPAA regulations. Frontera will only use and disclose PHI as permitted by the BAAs and as required or permitted by law under 45 CFR Parts 160 and 164, for purposes of clinical support tools, quality assurance, AI tool development and training, machine learning model improvement, algorithm refinement, predictive analytics development, and Platform enhancement. All recordings, data, and derivative works created by Frontera through AI training and development, including trained models, algorithms, and anonymized or de-identified datasets, shall remain the exclusive property of Frontera to the fullest extent permitted under applicable law, including HIPAA’s de-identification standards under 45 CFR § 164.514. The medical services provided by the Medical Groups through the use of our Platform are collectively referred to in these Terms of Use as the “Services.”

By clicking “Accept,” accessing the Platform, or using the Services, you acknowledge that you have read in its entirety, understand, and fully accept all terms and conditions contained in these Terms of Use, our Privacy Policy, and the Notice of Privacy Practices provided to you by the Medical Groups (which governs the collection, use and disclosure of your health information subject to HIPAA), as further described in the “Electronic Contracting, Acceptance and Agreement to Terms” section below.

If you are a Service Recipient the following applies: You further acknowledge and consent to Frontera’s collection, storage, and use of recordings of clinical sessions (including audio, video, transcripts, session notes, behavioral observations, treatment responses, clinical assessments, and any other data generated during or related to clinical sessions) involving you or your child and the Provider for purposes of clinical support, quality assurance, AI algorithm development and training, machine learning model creation and refinement, predictive analytics, clinical decision support tool development, Platform improvement, and research and development of new AI-powered healthcare technologies, as described in these Terms and our Privacy Policy. You further acknowledge and agree that Frontera may create de-identified datasets from your PHI in accordance with HIPAA standards (45 CFR § 164.514), and that such de-identified data, along with all AI models, algorithms, training datasets, and derivative works created by Frontera, shall be and remain the sole and exclusive property of Frontera in perpetuity, free from any claims by you or any third party, to the fullest extent permitted by applicable law. This authorization permits disclosure of your or your child’s protected health information to Frontera (as business associate) and its workforce members, contractors, and subcontractors who require access to perform these functions under Frontera’s direct supervision and control. Any such disclosure shall be limited to the minimum necessary information required and subject to written agreements ensuring equivalent privacy and security protections. You understand that: (i) this authorization is voluntary and that treatment, payment, enrollment, or eligibility for benefits will not be conditioned on your authorization except as permitted under 45 CFR § 164.508(b)(4); (ii) you have the right to revoke this authorization at any time by providing written notice to support@fronterahealth.com, except to the extent that action has already been taken in reliance on this authorization; (iii) if you revoke this authorization, certain Services that require recording for clinical support, quality assurance, or AI development purposes may not be available. In such event, the Medical Groups will ensure an appropriate transition of your care in accordance with applicable clinical standards of care and state and federal laws, including but not limited to providing

reasonable notice, facilitating transfer of medical records to alternative providers, and ensuring continuity of medically necessary treatment during the transition period. We will work with you to explore alternative service delivery options where feasible and clinically appropriate; however, revocation will not affect Frontera’s right to retain and use any de-identified data or AI models, algorithms, or derivative works already created from your PHI prior to revocation, as such materials are Frontera’s property and no longer constitute PHI under HIPAA; (iv) information used or disclosed pursuant to this authorization may be subject to re-disclosure by the recipient and may no longer be protected by federal privacy laws; and (v) you have the right to receive a copy of this authorization. This authorization expires upon termination of your account or five (5) years from the date of your acceptance of these Terms of Use, whichever occurs first, unless revoked earlier by you in writing.

You must read these Terms carefully before clicking “Accept” and/or using the Platform or Services. Do not click “Accept” or use our Platform or Services if you do not agree to these Terms of Use. Use without permission may constitute intellectual property infringement, computer abuse under the Computer Fraud and Abuse Act, and a violation of applicable federal and state criminal laws. If at any time the Terms of Use and/or Privacy Policy are no longer acceptable to you, you may cease use of the Platform or Services in accordance with the termination provisions of these Terms of Use. For Service Recipients receiving ongoing medical treatment, termination of Services shall be handled in accordance with applicable healthcare laws and regulations, including proper advance written notice (not less than thirty (30) days where clinically appropriate and not constituting patient abandonment), facilitation of transfer of complete medical records to alternative providers at the patient’s request, provision of emergency care during the transition period if medically necessary, reasonable assistance in identifying alternative providers where feasible, and compliance with all applicable state laws governing termination of the provider-patient relationship. The Medical Groups shall ensure that any termination does not constitute patient abandonment under applicable law and shall maintain continuity of medically necessary care during the transition period.

These Terms are between you and Frontera, and not with the App Provider (such as the Apple App Store, Google Play Store, or other similar platforms) where the App is made available (each such distribution platform an “App Provider“). The App Provider has no obligation to furnish any maintenance and support services with respect to the App. Any claims, losses, liabilities, damages, costs, or expenses attributable to any failure of the App will be the sole responsibility of Frontera.

Binding Arbitration. These Terms of Use provide that all disputes between you and Frontera that in any way relate to these Terms of Use, the Platform, and/or the Services will be resolved by BINDING ARBITRATION, except for (i) disputes relating to the Medical Groups’ provision of medical services, which shall be governed by applicable state law regarding medical malpractice claims, (ii) claims for injunctive or equitable relief related to intellectual property rights, and (iii) claims that may be brought in small claims court. ACCORDINGLY, YOU AGREE TO GIVE UP YOUR RIGHT TO GO TO COURT (INCLUDING IN A CLASS ACTION PROCEEDING) to assert or defend your rights under these Terms of Use against Frontera. Your rights will be determined by a NEUTRAL ARBITRATOR and NOT a judge or jury and your claims cannot be brought as a class action. Please review the Dispute Resolution and Arbitration Agreement section below for the details regarding your agreement to arbitrate any disputes with Frontera.

No Medical Care or Advice on the Site

We offer technology platforms and AI-powered clinical support tools for Providers and their patients to connect via the Platform. Our Platform may include artificial intelligence and machine learning tools, predictive models, clinical decision support tools, and other technologies that support Providers and improve their delivery of Services.

Frontera does not provide medical or psychological advice or care, own or operate the medical practices, employ or in any way supervise the clinicians providing medical care, and control over the care provided is the sole responsibility of the independent medical practices and the Providers they employ. Frontera’s role is limited to providing technology platforms and AI-powered clinical support tools that are licensed by the Medical Groups (which include both Frontera-affiliated entities and independent third-party clinics) to deliver clinical services for the diagnosis and treatment of children with ASD, other neurodevelopment and behavioral disorders. Platform Licensees (clinics and clinicians) obtain access to the Platform through licensing agreements, while Service Recipients (patients and families) access clinical Services provided by Providers who use the Platform. Frontera contracts for use of the Platform with the Medical Groups, which have a network of United States based Providers who provide telehealth and clinical services. Medical Group Providers may use the Platform to deliver Services to their patients provided they have license agreement to the Platform. Providers are independently contracted or employed by the Medical Group. Providers are not contracted or employed by Frontera. The Providers, and not Frontera, are responsible for the quality and appropriateness of the care they render to you.

The Providers are independent of Frontera and use the Platform to support their delivery of Services. Any information or advice received from a Provider comes from them alone, and not from Frontera. Neither Frontera, nor any of its subsidiaries or affiliates or any third party who may promote the Platform or Services or provide a link to the Services, shall be liable for any professional advice obtained from a Provider via the Platform or Services, nor any information obtained on the Platform. Frontera does not recommend or endorse any specific Providers, tests, physicians, medications, products, treatments, therapies, or procedures. You acknowledge that your reliance on any Providers or information delivered by the Providers via the Platform or Services is solely at your own risk and you assume full responsibility for all risks associated herewith.

Frontera does not make any representations or warranties about the training or skill of any Providers who deliver Services via the Platform. You will be provided with available Providers based solely on the information you submit to the Platform. You are ultimately responsible for choosing your particular Provider.

The content of the Platform, including without limitation, text, copy, audio, video, photographs, illustrations, graphics, and other visuals, is for informational purposes only and does not constitute professional medical or psychological advice, diagnosis, treatment, or recommendations of any kind by Frontera. You should always seek the advice of your qualified health care professionals with any questions or concerns you may have regarding your individual needs and any medical conditions. All information provided by Frontera, including any outputs generated by AI-powered tools, is in no way intended to create a provider-patient relationship as defined by state or federal law. If you are receiving

Services, you acknowledge and consent that clinical sessions between you or your child and Providers may be recorded (audio and video) and that such recordings will be collected, stored, and used by Frontera solely for the purposes of clinical support, quality assurance, and Platform improvement to enhance your care experience, all in strict accordance with applicable HIPAA requirements and our BAAs with the Medical Groups. Any use of de-identified data derived from such recordings for AI algorithm development, training, or research purposes shall require separate written authorization and shall be subject to additional privacy protections beyond HIPAA requirements. Frontera shall not claim ownership of any clinical data, recordings, or derivative works beyond what is necessary to provide the Services, and you retain all rights to your health information as provided under applicable law. While Frontera may facilitate your selection of, and communications with, Providers, Frontera does not provide medical or psychological services, and the provider-patient relationship is between you and the Medical Group Provider you select. DO NOT USE THESE SERVICES FOR EMERGENCY MEDICAL OR MENTAL HEALTH NEEDS. IF YOU THINK YOU MAY HAVE A MEDICAL EMERGENCY, CALL YOUR LOCAL EMERGENCY PHONE NUMBER OR YOUR HEALTHCARE PROVIDER IMMEDIATELY.

WHILE WE MAKE REASONABLE EFFORTS TO PROVIDE YOU WITH ACCURATE CONTENT, WE MAKE NO GUARANTEES, REPRESENTATIONS OR WARRANTIES, WHETHER EXPRESSED OR IMPLIED, WITH RESPECT TO OTHER CONTENT AVAILABLE THROUGH THE SERVICES. IN NO EVENT SHALL WE BE LIABLE TO YOU OR ANYONE ELSE FOR ANY DECISION MADE OR ACTION TAKEN BY YOU IN RELIANCE ON ANY SUCH CONTENT.

Services Provided

Each of the Medical Groups, which include both Frontera-affiliated medical practices and independent third-party clinics that license the Platform, utilizes the Platform to provide clinical services for ASD, other neurodevelopment and behavioral disorders, including behavioral therapy, diagnosis and treatment, and including through in clinic/home and telehealth modalities. Such clinical services are provided by qualified board-certified behavior analysts and therapists, or other qualified health care providers employed or contracted by the Medical Groups. Clinical sessions may be recorded (audio and video), transcribed, and analyzed, and such recordings and all associated data (including transcripts, behavioral annotations, clinical assessments, treatment responses, and analytical outputs) are collected, stored, processed, and used by Frontera for AI development, training, quality assurance, clinical support, and Platform improvement as described in these Terms. Frontera may create de-identified datasets from such recordings in accordance with HIPAA de-identification standards, and all de-identified data, AI models, algorithms, and derivative works created therefrom shall remain Frontera’s exclusive property in perpetuity. In addition to the Services, certain non-clinical services such as monitoring of care and progress tracking, support programs, and self-guided mental and behavioral health resources, may be available on the Platform.

RISKS OF TELEHEALTH SERVICES

Service Recipients by using the Services and Platform acknowledge the potential risks associated with any telehealth services. These include but are not limited to the following (and, if you are obtaining Services for a minor child, you acknowledge these risks on behalf of your child):

• information transmitted may not be sufficient (e.g. poor resolution of images) to allow for appropriate medical or health care decision making by the Provider;
• inability to conduct certain tests or assess vital signs in-person, which may in some cases prevent the Provider from providing a diagnosis or treatment, or from identifying my need for emergency medical care or treatment;
• delays in evaluation or treatment could occur due to failures of electronic equipment;
• a lack of access to your medical records may result in adverse drug interactions or allergic reactions or other judgment errors;
• although the electronic systems we use incorporate network and software security protocols to protect the privacy and security of health information, those protocols could fail causing a breach of privacy of your health information; and
• recordings of clinical sessions are collected and stored by Frontera, and, despite security measures, such recordings could be subject to unauthorized access or disclosure.

A Provider has the right to refuse to take responsibility for your care if the Provider, in their professional judgment, believes that you are not a good candidate for telehealth service. Using the App and associated third-party services for medical services provided by a licensed Healthcare Provider, you (or your child, if you are a parent or guardian obtaining services for a minor) will enter into a relationship where the Provider relies exclusively upon information that you provide to decide whether or not certain forms of clinical treatment are safe for you or your child. You acknowledge that clinical sessions may be recorded (audio and video), transcribed, and analyzed, and that you consent to such recording and to Frontera’s collection, storage, processing, and use of such recordings and all associated data for AI development and training, quality assurance, clinical support, Platform improvement, and research and development purposes as described in these Terms. You further acknowledge and consent to Frontera’s creation of de-identified datasets from such recordings and agree that all de-identified data, AI models, algorithms, and derivative works shall be Frontera’s exclusive property. The Provider will have limited ways to verify the information you provide, and that the Provider will consider the information you provide to be accurate, true, and complete. You agree that all information you communicate to your Provider will be, to the best of your knowledge, entirely accurate and complete.

You understand that by using the App and associated third-party services, Service Recipients will receive care only for ASD, other neurodevelopment and behavioral disorders, or other disorders deemed treatable by your Provider(s). Service Recipients will need to seek services elsewhere for any other medical, mental or emotional health needs unrelated to those approved for treatment by your Provider(s), or as instructed by your Provider(s).

It is important to follow the treatment plan specified by your Provider, which may include completing therapy sessions, and performing any homework or other requests your Provider asks of you. I, as a Service Recipient, understand that not complying with instructions from my Healthcare Provider may limit the effectiveness of my treatment and may serve as grounds for my Provider to terminate the patient-provider relationship, provided that such termination is conducted in accordance with applicable clinical standards of care and state and federal laws, including providing reasonable advance written notice (not less than thirty (30) days where clinically appropriate and not constituting patient abandonment), facilitating transfer of complete medical records to alternative providers, ensuring

continuity of medically necessary care during the transition period, providing reasonable assistance in identifying alternative providers where feasible, and complying with all applicable state laws governing termination of the provider-patient relationship to ensure patient safety and continuity of care.

By using the App, you may receive personalized content on treatment or therapy methods available to you, and that this information is being provided so that you may make your own decisions about which treatment(s) or therapies you would like to pursue. You understand it is of the utmost importance that you read the information provided within the App and, when applicable, via links to third-party websites for information about treatment.

YOU GIVE YOUR INFORMED CONSENT TO THE USE OF TELEHEALTH BY PROVIDERS THROUGH THE APP.

Registration

All users, whether Platform Licensees (clinics and clinicians licensing the Platform) or Service Recipients (patients and families receiving clinical Services), must create a user account to access and use the Platform or Services by completing the registration form with your first name, last name, e-mail address, password, emergency contact information and other information as requested and set out in our Privacy Policy (“Registration Data”). If you are registering on behalf of a child or minor, you represent and warrant that you are the parent or legal guardian of such child and have the authority to consent to these Terms on their behalf, including consent to the recording, transcription, analysis, and processing of clinical sessions involving the child, and to Frontera’s use of such recordings and data for AI development and training, quality assurance, clinical support, and Platform improvement purposes. You further represent and warrant that you have authority to consent to Frontera’s creation of de-identified datasets from the child’s PHI and to Frontera’s ownership of all de-identified data, AI models, algorithms, and derivative works created from such data. The Registration Data provided by you during the registration process must be correct. With the registration you are concluding a binding contract with us regarding the use of the Platform and Services, and you may only use the Platform and Services in compliance with these Terms of Use. After you have created an account and if you are a Service Recipient, we will ask you to complete an intake form and an initial assessment in order to enable you to make use of our Services, as available in your jurisdiction. You agree that you will not create more than one account or create an account for anyone other than yourself without first receiving permission from the other person. In exchange for your use of the Service or Platform and, if applicable, in order for Providers to send messages to you, you agree to:

• provide true, accurate, current, and complete information about yourself as prompted by our account enrollment form;
• to maintain, and promptly update such Registration Data, each time you log on, as far as possible to keep it true, accurate, current, and complete. If you provide any information that is untrue, inaccurate, not current, or incomplete, or Frontera has reasonable grounds to suspect that such Registration Data is untrue, inaccurate, not current, or incomplete, Frontera and the Medical Groups reserve the right to transition Service Recipients’ treatment to another Provider in accordance with applicable clinical standards of care and state and federal laws governing termination of the provider-patient relationship, including providing reasonable advance written notice (not less than thirty (30) days where clinically appropriate), facilitating transfer of medical records, ensuring continuity of medically necessary care during the transition period, and providing reasonable assistance in locating alternative providers where feasible, or take other clinically appropriate steps to ensure patient safety and continuity of care;
• Remain responsible for maintaining the confidentiality of your account password and username (if any), and any other security information related to your account at all times;
• Abide by all the Terms of Use and conditions, including that you have the right, authority, and capacity to enter into this agreement; and
• Age Verification. You certify that you are 18 years old or older and have the legal capacity to enter into this binding agreement.
• If you are creating an account to obtain Services for a minor child, you represent and warrant that you are the parent or legal guardian of such child and have the legal authority to consent to these Terms on behalf of the child, including consent to the collection, recording, transcription, analysis, storage, processing, and use of the child’s protected health information for AI development and training, quality assurance, clinical support, Platform improvement, and research and development purposes as described in these Terms of Use and our Privacy Policy and in accordance with HIPAA and applicable state privacy laws. You further represent and warrant that you have authority to consent to Frontera’s creation of de-identified datasets from the child’s PHI and to assign to Frontera all ownership rights in such de-identified data, AI models, algorithms, and derivative works created therefrom.
• By clicking “I Agree,” checking the acceptance box, or otherwise accessing or using the Platform or Services, you acknowledge that you intend to be legally bound by these Terms of Use as set forth in the “Electronic Contracting, Acceptance and Agreement to Terms” section.

If you have any problems accessing our website, please contact us by telephone to gain access to our Service.

Your Subscription. Purchasing a subscription on the Platform will provide access to the Platform based on the terms of your subscription (“Subscription”). In addition to the Services, certain non-clinical services such as monitoring of care and progress tracking, support programs, and self-guided mental and behavioral health resources, may be made available on the Platform and may be included in the Subscription. Depending on whether you are a Platform Licensee or Service Recipient, we may offer different subscription options that you can choose, including billing that can occur per service, weekly, every four (4) weeks, or quarterly. Certain subscriptions you may choose will continue and automatically renew until you cancel your subscription. If you chose a recurring subscription, you acknowledge that such paid services have a recurring payment and you accept responsibility for all recurring charges prior to cancellation. You can cancel the subscription at any time for any reason. Your subscription must be canceled before it renews in order to avoid the next billing cycle. We reserve the right to change our

subscription or adjust prices of our services. Any changes to your subscription will only take effect following proper notice to you.

The Platform or Services are not an insurance product. Frontera and the Medical Groups are not insurance providers and do not sell or offer any type of insurance product or coverage. The Platform or Services are not a type of or substitute for any insurance product or coverage. Any payments to the Medical Groups are not insurance premiums. The Terms of Use and any incorporated terms or conditions are not and shall not be deemed a contract for insurance under any applicable state law. Neither the Platform nor the Services qualify as the minimum essential coverage under the Patient Protection and Affordable Care Act. If you desire any type of health or other insurance, you must purchase it separately.

Other Fees. You agree to pay all other fees and charges associated with your account that are not included in the subscription fees, including, for example, appointment no-show fees, cancellation fees or late rescheduling fees, co-pays, co-insurance and deductibles and other costs not covered by your health insurance plan, and any fees for any services that are not charged on a subscription model (collectively, “Other Fees”), on a timely basis and according to the terms and the rates presented to you. By incurring such Other Fees, you authorize the Medical Groups to bill and charge your payment method on file for such Other Fees in full.

Insurance. In certain situations, you or a family member’s health plan may cover all or a portion of your use of the Services. Subject to the terms of any written agreements between the Medical Groups and the health plan, you authorize the Medical Groups to bill for Services rendered to you by sharing necessary information with the health plan to process payments and to charge your Payment Information for any fees that your insurance company does not cover, such as copays, deductibles, and coinsurance costs. Frontera, acting as a business associate under HIPAA, may facilitate such billing processes on behalf of the Medical Groups through its Platform, subject to applicable BAAs.

Assignment of Insurance Benefits and HIPAA Authorization. By electing to use insurance for the Services, you hereby:

(a) Assign all medical benefits, including but not limited to, major medical insurance, sick benefits and injury benefits, due to you for Services rendered by the Medical Groups up to the full amount of your medical bill. This assignment does not include benefits due to you because of liability of a third party, such as auto insurance or workers’ compensation insurance, unless you provide separate written authorization for such assignment;

(b) Authorize and direct your insurance carrier(s) (including private insurance) and any other health/medical plan, to issue payment directly to the Medical Groups and/or one of their affiliates or partners for medical and other services rendered to yourself and/or your dependents regardless of your insurance benefits, if any; and

(c) Authorize the Medical Groups to use and disclose your protected health information (PHI) and the PHI of your dependents, as applicable, to your insurance carrier(s) and health plan(s) and their agents, contractors, and representatives for the purposes of: (i) obtaining payment for Services; (ii) determining

coverage and eligibility; (iii) submitting and processing claims; (iv) obtaining prior authorizations; (v) appealing claim denials; (vi) coordinating benefits; and (vii) any other purpose related to payment for healthcare services.

This authorization for the use and disclosure of PHI is valid from the date you provide it until you revoke it in writing by sending notice to support@fronterahealth.com. You understand that: (i) you have the right to revoke this authorization at any time, but revocation will not affect any actions taken before we receive your written revocation; (ii) revocation may result in your inability to use insurance benefits and may require you to pay the full cost of Services; (iii) the Medical Groups may condition treatment on your provision of this authorization only to the extent permitted by law; (iv) information disclosed pursuant to this authorization may be subject to re-disclosure by the recipient and may no longer be protected by HIPAA; and (v) if revocation results in termination of Services, the Medical Groups will work with you to ensure an appropriate transition of care in accordance with applicable clinical standards of care and Colorado law, including providing reasonable notice, assistance with continuity of care, and referrals to alternative providers as clinically appropriate.

Insurance Benefits and Patient Financial Responsibility of Service Recipients. Your insurance policy is a contract between you and your insurance plan, and it is your responsibility to know your benefits, including if your insurance has any deductible, co-payment, co-insurance, out-of-network, usual and customary limit, prior authorization requirements or any other type of benefit limitation for the Services you receive, and how your benefits will apply to your payments. If you purchase Services with your insurance plan, you authorize the Medical Groups to charge your payment method on file for the Services, if applicable, and any fees not covered by your insurance, such as co-pays, co-insurance, deductibles, and Other Fees. You further authorize the Medical Groups to use and disclose your PHI as necessary to process such charges and collect payment, including sharing information with payment processors, billing companies, collection agencies, credit reporting agencies, and legal counsel, to the extent permitted by law and HIPAA. Such disclosures will be limited to the minimum necessary information required to accomplish the payment or collection purpose. Frontera, as a business associate under HIPAA, may facilitate such charges on behalf of the Medical Groups through its Platform in accordance with applicable BAAs. If all or any portion of the Services are not covered or paid by your insurance plan for any reason or you do not have health insurance, you understand that you will be ultimately responsible for all fees and costs arising out of your use of the Services and agree to pay the full amount of all Subscription Fees and Other Fees associated with your Account. Such disclosures will be limited to the minimum necessary information required to accomplish the payment or collection purpose. Questions about non-payment should be directed to your insurance plan. You agree to update your Account and inform us at support@fronterahealth.com or your Provider immediately if you lose your health insurance and/or can no longer pay for treatment. Failure to maintain current insurance information or payment methods may result in suspension or termination of Services, subject to applicable healthcare laws and regulations.

Refunds. All purchases are final and once paid, all fees, including Subscription Fees, are non-refundable regardless of whether the Platform or Services are utilized, except as required by applicable law or as otherwise provided in these Terms of Use. However, you may cancel your Subscription at any time in accordance with these Terms of Use. We reserve the right to issue refunds or credits at our sole

discretion. If we issue a refund or credit in one instance, we are under no obligation to issue the same refund or credit in the future.

Third-Party Payment Processor. All credit card, debit card and other monetary transactions on or through the Platform occur through an online payment processing application that is provided by a third-party payment processor(s). Neither the Medical Groups nor Frontera collect or store payment card information. If our third-party payment processor is unable to secure funds from your payment method for fees that are due for any reason, including, but not limited to, insufficient funds or insufficient or inaccurate information provided when submitting electronic payment, we may undertake further collection action, including application of reasonable fees to the extent permitted by law. We reserve the right to suspend or terminate your Account and access to the Platform; provided, however, that suspension or termination of access to medical Services shall be subject to applicable healthcare laws and regulations, and we will provide advance notice where required by law or medical necessity considerations.

Waiver of Claims and Unauthorized Payments. You agree to waive all claims against Frontera, the Medical Groups and their third-party service providers, including any third-party payment processor(s), related to any unauthorized payments made on or through the use of your account outside of the Medical Groups, Frontera or its third-party service providers’ control, regardless of whether such payments are authorized or unauthorized. However, you may submit a claim of the unauthorized payment to the Medical Groups or Frontera so that we can conduct a reasonable investigation as we see fit under the circumstances.

Use of the Platform And Services

Electronic Contracting, Acceptance and Agreement to Terms. You may use the Platform and Services only if you form a binding electronic contract with Frontera with respect to the Platform, only in compliance with these Terms of Use, and only for lawful purposes. By creating a user account, clicking “I Agree,” checking an acceptance box, or otherwise accessing or using the Platform or Services, you acknowledge and agree that: (a) you have read, understood, and agree to be bound by these Terms of Use; (b) you consent to conduct transactions electronically in accordance with the Uniform Electronic Transactions Act (“UETA”), the Electronic Signatures in Global and National Commerce Act (“E-SIGN Act”), and applicable state law; (c) you consent to receive all communications, agreements, documents, receipts, notices, and disclosures electronically (collectively, “Electronic Communications“) that Frontera provides in connection with your account and use of the Platform and Services and that such Electronic Communications satisfy any legal requirement that such communications be in writing; (d) your electronic acceptance constitutes your signature, acceptance, and agreement as if actually signed by you in writing and has the same legal force and effect as a handwritten signature; and (e) you have the hardware and software capabilities necessary to access and retain Electronic Communications as described below.

A user account is required to access either the Services or the Platform. To create an account, you must provide accurate and complete information and maintain and update such information to keep it accurate and complete.

Hardware and Software Requirements. To access and retain Electronic Communications, you will need: (i) a valid email address that you access regularly; (ii) a device (computer, tablet, or smartphone) capable of accessing the internet; (iii) an internet browser that supports 128-bit encryption (such as current versions of Chrome, Firefox, Safari, or Edge); (iv) sufficient electronic storage space to save Electronic Communications or a printer to print them for your records; (v) software capable of reading PDF files (such as Adobe Acrobat Reader, available free at www.adobe.com) if documents are provided in that format; and (vi) an internet connection with sufficient speed to access and download electronic documents. You acknowledge that you currently have access to the hardware and software described above and are able to receive, access, and retain Electronic Communications. You agree to notify us immediately if your email address changes or if you lose the ability to receive Electronic Communications.

Right to Withdraw Consent. You have the right to withdraw your consent to receive Electronic Communications at any time by contacting us at support@fronterahealth.com. We will process your withdrawal request within a reasonable time period not to exceed ten (10) business days. However, withdrawal of consent may result in termination of your access to the Platform and Services. If you withdraw consent, we will provide you with paper copies of legally required communications at no charge, though we may charge a reasonable fee for copies of other communications as permitted by law. Withdrawal of consent will not affect the legal validity of electronic communications provided before your withdrawal became effective.

How to Update Your Contact Information. You must keep your email address and other contact information current in your account settings. If your email address or other contact information changes, you must update it promptly to ensure you continue to receive Electronic Communications.

Type of User. The Platform and Services are offered to two distinct types of users:

(1) Individual Users: Individual users may create accounts to access the Platform and receive medical Services directly from the Medical Groups. These Services include clinical care for ASD and related neurodevelopmental conditions.

(2) Clinical Organizations: Organizations, companies, and/or businesses, including clinical practices and healthcare providers (“Clinical Organizations“), may create accounts and license our Platform solely for the purpose of using our software as a service (SaaS) to access AI-powered clinical support tools for diagnosing and treating ASD and other neurodevelopmental and behavioral disorders, subject to separate licensing agreements and applicable BAAs. Clinical Organizations that license the Platform will use it to support their provision of medical care to patients, including children with ASD.

Frontera does not provide medical care, diagnosis, or treatment directly; rather, the Platform provides AI-powered tools that support Clinical Organizations and their clinicians in delivering such care. ANY ADVICE OR INFORMATION GENERATED BY THE PLATFORM SHOULD BE REVIEWED CAREFULLY BY A QUALIFIED PROFESSIONAL BEFORE BEING RELIED UPON FOR CLINICAL DECISION-MAKING.

Electronic Acceptance. The provisions set forth in the section titled “Electronic Contracting, Acceptance and Agreement to Terms” above govern your electronic acceptance of these Terms of Use. You have no other rights to the Platform, the Services, and any information, content, files, documents, text, photographs, images, audio, videos, reviews, products, documentation, software, or other materials available on or through the Platform and Services (collectively, the “Content“). When you accept these Terms of Use, we grant you a limited, personal, non-exclusive, nontransferable, fully revocable license to access and use the Platform and Services as permitted under these Terms of Use and any other agreements you may have entered into with us.

You agree not to use the Platform and Services for unauthorized commercial purposes or to: (i) violate any applicable local, state, national, or international laws; (ii) stalk, harass, threaten, abuse, defame, demean, discriminate against, intimidate, or exhibit other harmful or disrespectful behavior toward another individual, Providers, or staff of Frontera and relevant third parties providing Services to you, or disrupt the care of other patients, as Frontera and the Medical Groups determine in our sole discretion; (iii) violate the privacy rights of any person, including collecting or storing personal data about other users or persons, or recording appointments and other audio or visual interactions with your Provider without the knowledge and consent of the Provider; (iv) impersonate any person or entity, or otherwise misrepresent your affiliation with a person or entity; (v) interfere with or disrupt the Platform and Services or servers or networks connected to the Platform and Services, or disobey any requirements, procedures, policies or regulations of networks connected to the Platform or Services; (vi) attempt to gain unauthorized access to any portion of the Platform, Services or any other accounts, computer systems, or networks connected to the Services or Platform, whether through hacking, password mining, or any other means; (vii) otherwise using the Platform in any manner that exceeds the scope of use granted herein; (viii) modify, edit, copy, reproduce, create derivative works of, reverse engineer, alter, enhance or in any way exploit the Services, Platform, or the Content in any manner, and/or (ix) attempt to indirectly undertake any of the foregoing or encourage or enable any other individuals to do or attempt any of the foregoing.

Frontera has the right to suspend or terminate your user account at any time with or without notice as it deems advisable, including where you violate these Terms of Use, as required by law, or due to security or welfare concerns; provided, however, that for Service Recipients receiving medical Services, the Medical Groups will ensure appropriate transition of care in accordance with applicable clinical standards of care, applicable state medical practice requirements, and federal healthcare regulations, including providing reasonable advance notice (except in cases of immediate safety concerns), assistance with continuity of care, transfer of medical records as requested, and referrals to alternative providers as clinically appropriate. To the extent permitted by applicable law, Frontera shall not be liable to you or any third party(s) for any loss or damage that is caused by or arises from or in connection with any such suspensions or terminations. If Frontera has previously prohibited you from accessing or using the Platform or Services, you are not permitted to access the Platform or its Services.

Platform Accessibility. You understand, agree, and acknowledge that we may modify, suspend, disrupt, or discontinue the Platform, any part of the Platform, or the use of the Platform, whether to all users or to you specifically, at any time with or without notice to you; provided, however, that we will provide at least thirty (30) days’ advance written notice of any material modifications or discontinuation of the

Platform to Clinical Organizations with active licensing agreements, except in cases of emergency, security threats, or legal requirements. Individual users will receive reasonable notice as determined by Frontera in its discretion. You agree and acknowledge that we will not be liable for any of the aforementioned actions or for any losses or damages that are caused by any of the aforementioned actions. The Platform depends on various factors such as software, hardware and tools, either our own or those owned and/or operated by our contractors and suppliers. While we make commercially reasonable efforts to ensure the Platform’s reliability and accessibility, you understand and agree that no platform can be 100% reliable and accessible and so we cannot guarantee that access to the Platform will be uninterrupted or that it will be accessible, consistent, timely or error-free at all times.

Your Device Functionality. You are responsible for obtaining and maintaining your device, software, operating system, carrier, and network access necessary to properly access and use the Platform. Frontera does not guarantee that the Platform or any portions thereof will function on or in connection with any particular device, software, operating system, carrier, or network. Frontera will have no liability for errors, unreliable operation, or other issues resulting from use of the Platform on or in connection with rooted or jail broken devices or use on any mobile device that is not in conformance with the manufacturer’s original specifications, including, but not limited to, use of modified versions of the operating system. All rate and data fees of your device’s carrier apply to your use of the Platform and Services and Frontera is in no way responsible for your carrier rates and data fees, where applicable.

Consent to Receive Calls, Text Messages, and Audio and/or Video Recording

By providing your mobile number and electronically accepting these Terms in accordance with the “Electronic Contracting, Acceptance, and Agreement to Terms” section, you expressly consent in writing under the Telephone Consumer Protection Act, 47 U.S.C. § 227, and related regulations, to be contacted by or on behalf of Frontera and the Medical Groups at the mobile number you have provided. This consent authorizes us to make or initiate calls and text messages using an automatic telephone dialing system or an artificial or prerecorded voice, to receive informational, product or service related (e.g., appointment reminders, clinical updates, etc.) messages and communications relating to the Platform and the Services provided by the Medical Groups. You acknowledge that your consent is not a condition of purchasing any goods or services, and you may revoke this consent at any time by following the opt-out procedures described herein. Message and data rates may apply. To stop receiving text messages text a reply to us with the word STOP. We may confirm your opt out by text message. If you subscribe to multiple types of text messages from us, we may unsubscribe you from the service that most recently sent you a message, or respond to your STOP message by texting you a request to identify services you wish to stop. Please note that by withdrawing your consent, some of the functions provided by the Platform may no longer be available to you. If you have revoked consent and want to re-enroll in receiving transactional text messages, you can re-enroll by updating your notification preferences in your Account.

Frontera and the Medical Groups may record (audio and video) all or part of your interaction with us, including clinical sessions between patients and Providers (“Recordings“), where permitted by applicable law and with appropriate notice. These Recordings are used for quality assurance and training purposes, to improve clinical outcomes and AI-powered clinical support tools, to better deliver the products and services to you, and to help us improve the Platform.

Ownership And Use Of Recordings. The Medical Groups, as covered entities, maintain ownership and control of Recordings containing PHI for treatment, payment, and healthcare operations purposes. However, you hereby grant Frontera a perpetual, irrevocable, worldwide, royalty-free, fully paid-up license to use, reproduce, modify, adapt, and create derivative works from all Recordings (including those containing PHI) for the following purposes: (i) providing Platform services as specified in applicable BAAs; (ii) developing, training, testing, and improving AI clinical support tools, machine learning models, and algorithms; (iii) conducting research and analytics to enhance clinical outcomes and Platform functionality; (iv) creating aggregated or statistical data and insights; and (v) any other purpose related to Frontera’s business operations and AI development activities. This license survives termination of your account and these Terms.

Authorization For Ai Training And Development. By electronically accepting these Terms in accordance with the “Electronic Contracting, Acceptance and Agreement to Terms” section, you (or your legal guardian if you are a minor) provide specific written authorization under 45 C.F.R. § 164.508 for Frontera to use and disclose your PHI contained in Recordings for AI training, model development, algorithm improvement, and research purposes beyond treatment, payment, and healthcare operations. You acknowledge and agree that: (a) Frontera will retain all Recordings and associated data indefinitely for AI development purposes; (b) once used for AI training, the information cannot be retrieved or deleted from trained models; (c) this authorization does not expire unless you revoke it in writing; (d) you may revoke this authorization at any time by written notice to support@fronterahealth.com, but revocation will not affect uses and disclosures already made, including data already incorporated into AI models; (e) revocation may result in termination of your access to the Platform and Services; (f) treatment, payment, enrollment, or eligibility for benefits may be conditioned on providing this authorization; and (g) information used or disclosed pursuant to this authorization may be subject to re-disclosure by Frontera and may no longer be protected by HIPAA privacy rules.

De-Identification And Unrestricted Use. You acknowledge that de-identified data derived from Recordings (from which all identifying information has been removed in accordance with HIPAA’s de-identification standards at 45 C.F.R. § 164.514) becomes the sole and exclusive property of Frontera and may be used by Frontera without restriction, without further authorization, and without compensation to you for research, development, commercial purposes, AI training, creating derivative AI models, licensing to third parties, and any other purpose in perpetuity. Frontera has no obligation to delete or return de-identified data at any time. We will keep such Recordings confidential in accordance with our Privacy Policy and applicable law, including HIPAA where applicable, and we will not publicly display such recordings unless legally required to do so, such as if subject to a court order or as necessary to comply with our legal obligations. By electronically accepting these Terms in accordance with the “Electronic Contracting, Acceptance and Agreement to Terms” section and accessing and using our Platform, you (or your legal guardian if you are a minor) expressly consent in writing to such Recordings for the purposes and uses set forth in these Terms of Use and as otherwise set forth in the Privacy Policy. Under Colorado law (C.R.S. § 18-9-303), you acknowledge that you have been informed that your communications may be recorded, and you provide your affirmative consent to such recording. For minors receiving services, the legal guardian’s electronic acceptance of these Terms constitutes legally valid consent for recording of the minor’s clinical sessions under applicable state and federal law, including HIPAA. You may withdraw this consent at any time by contacting us in writing, though withdrawal may limit your ability to use certain Platform features and Services. If withdrawal of consent results in termination of medical

Services for Service Recipients, the Medical Groups will ensure appropriate transition of care in accordance with applicable clinical standards of care and Colorado law, including providing reasonable advance notice, assistance with continuity of care, and referrals to alternative providers as clinically appropriate.

You can opt out of text messages by updating your notification preferences in your Account. We may send you a text message to confirm your opt out. Please note that if you withdraw your consent to receive text messages, some Platform features and certain Services may no longer be available to you, and you may not receive important and helpful information and reminders about your Services.

Sensitive Communications. You understand that while Frontera takes your privacy and the security of your health and other sensitive information very seriously, the transmission of information over the internet and mobile networks is not 100% secure. Text messages and emails that you send to or receive from Frontera outside of the Platform are not encrypted, which means that it is possible they may be intercepted by third parties. If you choose to send or receive information about your health or any other sensitive information by text message or email outside of the Platform, you do so at your own risk. By opting into text messages, you consent to sending text messages to Frontera and receiving text messages from or on behalf of Frontera that are not encrypted. Likewise, by emailing Frontera or giving us your email, you consent to receiving unencrypted email messages from or on behalf of Frontera. You expressly acknowledge and consent in writing that unencrypted communications may not be secure and that you voluntarily assume the risk of using such communications for transmitting protected health information. This written consent satisfies the requirements of 45 C.F.R. § 164.530(c) for patient agreement to receive unencrypted electronic communications containing PHI. Under Colorado law (C.R.S. § 25-1-801 et seq.), you have the right to communicate with your healthcare provider through secure means, and we strongly encourage you to use the Platform’s secure messaging features whenever possible for communications containing health information. You may withdraw this consent to receive unencrypted communications at any time by contacting us in writing, and we will thereafter communicate with you only through secure means.

Notice Concerning Frontera Platform and Services

Two Types Of Users And Services. Frontera offers its Platform and Services to two distinct categories of users: (1) Medical Groups and healthcare providers who license the Platform to deliver clinical services (“Platform Licensees“), and (2) patients and their legal guardians who access Services through Platform Licensees (“Service Recipients“). All users must create an Account to access the Platform or Services. You may use the Platform only if you form a binding electronic contract with Frontera in accordance with the “Electronic Contracting, Acceptance and Agreement to Terms” section above and only in compliance with these Terms.

FRONTERA IS A TECHNOLOGY COMPANY THAT PROVIDES AI-POWERED CLINICAL SUPPORT TOOLS. FRONTERA DOES NOT PROVIDE MEDICAL CARE, DIAGNOSIS, OR TREATMENT DIRECTLY. Medical services, including diagnosis and treatment of ASD and other neurodevelopmental and behavioral disorders, are provided by independent Medical Groups that license Frontera’s Platform. These Medical Groups are covered entities under HIPAA and are responsible for all medical care decisions and the delivery of healthcare services to patients, including children with ASD, other neurodevelopment and behavioral disorders.

Frontera acts as a business associate to Platform Licensees and provides software as a service (SaaS) that includes AI-powered tools to support clinical decision-making and treatment delivery. All such Recordings containing protected health information are owned and controlled by the Medical Groups as covered entities, and Frontera processes such information solely as a business associate in accordance with applicable BAAs and HIPAA requirements at 45 C.F.R. Part 160 and Part 164, Subparts A, C, and E. Service Recipients acknowledge that by electronically accepting these Terms in accordance with the “Electronic Contracting, Acceptance and Agreement to Terms” section above, they consent to the disclosure of their PHI (and, for legal guardians, the PHI of their minor children) by the Medical Groups to Frontera for the purposes described herein, to the extent such consent is required under applicable law. Service Recipients further acknowledge that: (i) they have received the Medical Groups’ Notice of Privacy Practices as required by 45 C.F.R. § 164.520 prior to or contemporaneously with accepting these Terms, which describes how their PHI may be used and disclosed; and (ii) they have the right to receive a paper copy of the Notice of Privacy Practices upon request at no charge by contacting support@fronterahealth.com. For uses or disclosures that require HIPAA authorization beyond this general consent, the Medical Groups will obtain separate written authorization from Service Recipients or their legal guardians as required by 45 C.F.R. § 164.508.

Electronic Consent and Acknowledgment for Service Recipients. If you are a Service Recipient, by electronically accepting these Terms or accessing the Platform, you: (1) acknowledge that the Medical Group is your healthcare provider and is responsible for your care; (2) acknowledge that Frontera provides technology tools to support the Medical Group’s delivery of care; (3) agree that you must maintain an active Account to access Services through the Platform; (4) consent to the use of electronic records, signatures, and communications in connection with these Terms and all transactions under them; (5) PROVIDE SPECIFIC WRITTEN AUTHORIZATION UNDER 45 C.F.R. § 164.508 for Frontera to use recordings of clinical sessions, all data generated through your use of the Platform, and all PHI for AI training, model development, algorithm improvement, research, and any other purpose related to Frontera’s AI development and business operations, and acknowledge that such data will be retained by Frontera indefinitely and cannot be retrieved once incorporated into AI models; (6) confirm that you have the ability to access, receive, and retain electronic records; (7) acknowledge your right to withdraw consent to electronic communications at any time by contacting support@fronterahealth.com, though withdrawal may limit your ability to use the Platform; and (8) acknowledge that your access to and use of the Platform and Services is conditioned upon providing the authorizations in item (5) above, and that refusal or revocation will result in termination of access, in which case the Medical Groups will ensure appropriate transition of care in accordance with applicable clinical standards of care and Colorado law, including providing reasonable advance notice, assistance with continuity of care, and referrals to alternative providers as clinically appropriate.

Frontera provides AI-powered clinical support tools and software designed to assist licensed healthcare professionals in diagnosing and treating ASD and other neurodevelopmental and behavioral disorders. The Platform may record clinical sessions, including video and audio of both patients and healthcare providers, for purposes of AI analysis, clinical support, and service improvement. Frontera does not directly provide medical care, diagnosis, or treatment; however, Frontera’s affiliated medical groups and

clinical practices (“Affiliated Providers”) do provide direct medical care and treatment services to patients with ASD, other neurodevelopment and behavioral disorders.

ANY ADVICE OR INFORMATION GENERATED BY THE PLATFORM, INCLUDING AI-POWERED RECOMMENDATIONS AND CLINICAL SUPPORT TOOLS, SHOULD BE REVIEWED CAREFULLY BY A QUALIFIED HEALTHCARE PROFESSIONAL BEFORE BEING RELIED UPON FOR ANY MEDICAL DECISION OR TREATMENT.

The Platform and Services are intended to support, not replace, the relationship between patients and their healthcare providers. Always seek the advice of a qualified healthcare professional with any questions you may have regarding medical care or treatment. Never disregard professional medical advice or delay in seeking it based on information provided through the Platform.

Feedback.

Frontera welcomes feedback, comments and suggestions for improvements to the Platform or Services (“Feedback”). You can submit Feedback by emailing support@fronterahealth.com or through the Platform’s feedback mechanism. In doing so, you grant to us a non-exclusive, transferable, worldwide, perpetual, irrevocable, fully-paid, royalty-free license, with the right to sublicense, under any and all intellectual property rights that you own or control to use, copy, modify, and/or create derivative works based upon and otherwise exploit the Feedback for any purpose. “Feedback” includes any information, data, observations, or insights you provide about the Platform or Services, including information derived from your use of the Platform. To the extent Feedback contains or is derived from PHI or clinical session recordings, you hereby authorize Frontera to use such information in de-identified form for AI training, Platform improvement, and any other business purpose, and such de-identified Feedback becomes the exclusive property of Frontera.

Intellectual Property

Content. Frontera, its Affiliated Providers, and/or Frontera’s licensors, as applicable, retain all right, title, and interest in and to the Platform, the Services and all Content available on or through the Platform and Services, and any patent, copyright, trade secret, trademark, service mark, or other intellectual property, or proprietary right in any of the foregoing. Notwithstanding the foregoing, patients and their legal guardians (Service Recipients) retain ownership of their PHI, including clinical session recordings, subject to the licenses granted herein and applicable law. Under HIPAA and Colorado law, you have the right to: (i) access and obtain a copy of your PHI in electronic format if maintained electronically; (ii) request correction or amendment of your PHI; (iii) request an accounting of disclosures of your PHI; (iv) request restrictions on certain uses and disclosures of your PHI; (v) request confidential communications; and (vi) in certain circumstances, request deletion of your personal health information, subject to legal exceptions. You may exercise these rights by submitting a written request (including electronic requests via email to support@fronterahealth.com) in accordance with our Notice of Privacy Practices. For clarity, use, reproduction, copying, or redistribution of Frontera trademarks, service marks, and logos or those of Frontera’s third-party licensors are strictly prohibited without the prior written permission of Frontera

or the licensor, as applicable. The Platform may contain other proprietary notices and copyright information, the terms of which you agree to follow.

User Generated Materials. All names, photographs, information, communications and any other content that you submit to or publish on or through the Platform, or that you submit to or publish on an online social media account (e.g., Facebook, Instagram) that you own and link or otherwise associate with the Platform or your Account, including any medical information you provide via the Platform, if any and as applicable, is referred to in these Terms as “User Generated Materials.”

Clinical Session Recordings. Video and audio recordings of clinical sessions conducted through or in connection with the Platform, including recordings capturing patients (including minors with ASD, and other neurodevelopment and behavioral disorders) and healthcare providers during diagnosis and treatment, constitute a special category of User Generated Materials subject to heightened protections. You acknowledge that PHI you submit through the Platform, including clinical session recordings, will be handled in accordance with HIPAA requirements and our BAA.

License Grant. You own and are responsible for all User Generated Materials. For non-PHI User Generated Materials, you grant Frontera, its Affiliated Providers, and related third parties involved in providing you the Services a worldwide, transferable, sub-licensable, irrevocable, perpetual license to use, reproduce, modify, publish, list information regarding, edit, translate, distribute, syndicate, perform and display (publicly or otherwise), adapt, analyze, exploit, and make derivative works of all such User Generated Materials for any purpose.

For User Generated Materials containing PHI, including clinical session recordings, by electronically accepting these terms, you provide specific written authorization under 45 CFR § 164.508 for Frontera, its Affiliated Providers (acting as Covered Entities or Business Associates under HIPAA), and related third parties acting as Business Associates to use, reproduce, modify, analyze, create derivative works from, and disclose your PHI for the following purposes: (i) treatment, payment, and healthcare operations as defined under HIPAA; (ii) AI-powered clinical analysis and support, whether or not directly related to your care; (iii) quality assurance and compliance activities; (iv) training, development, testing, and improvement of AI algorithms, machine learning models, and clinical tools; and (v) research and analytics, whether or not the data is de-identified; (vi) creating aggregated datasets and statistical analyses; (vii) developing commercial AI products and services; and (viii) any other purpose related to Frontera’s AI development and business operations.

License Scope And Duration. This authorization and license is perpetual, irrevocable to the maximum extent permitted by law, worldwide, royalty-free, fully paid-up, and includes the right to sublicense to Frontera’s contractors, partners, and successors. This license does NOT terminate upon deletion of your account or revocation of authorization with respect to: (a) any PHI or data already incorporated into AI models, training datasets, or derivative works; (b) any de-identified data created from your PHI; (c) any aggregated or statistical data derived from your information; or (d) any uses or disclosures already made in reliance on this authorization. You acknowledge that once your data is used to train AI models, it cannot be retrieved, deleted, or separated from those models.

De-Identified Data Ownership. Any data derived from your PHI that has been de-identified in accordance with HIPAA standards under 45 CFR § 164.514 becomes the sole and exclusive property of Frontera in perpetuity. Frontera may use, disclose, license, sell, or otherwise exploit de-identified data without restriction, without further authorization from you, and without compensation to you. You have no ownership rights in de-identified data.

Revocation Limitations. While you have the right to revoke this authorization at any time by submitting written revocation to support@fronterahealth.com, you acknowledge and agree that: (1) revocation will NOT affect any uses, disclosures, or AI training already completed; (2) revocation will NOT result in deletion of data already incorporated into AI models or training datasets; (3) revocation will NOT affect de-identified data, which remains Frontera’s property; (4) revocation may result in immediate termination of your access to the Platform and Services, provided that Frontera and the Medical Groups will ensure that any ongoing medical treatment is transitioned in accordance with applicable clinical standards and healthcare laws, including proper notice and coordination of care to prevent abandonment, provided that Frontera and the Medical Groups will ensure that any ongoing medical treatment is transitioned in accordance with applicable clinical standards and healthcare laws, including proper notice and coordination of care to prevent abandonment; and (5) revocation will only prevent future uses of identifiable PHI that has not yet been incorporated into AI systems. You further acknowledge that treatment, payment, enrollment, or eligibility for benefits IS CONDITIONED on providing this authorization, and refusal to provide or revocation of this authorization will result in inability to use the Platform or receive Services, subject to the transition obligations described above subject to the transition obligations described above. You agree not to provide any User Generated Materials that (i) are false, inaccurate, defamatory, abusive, libelous, unlawful, obscene, threatening, harassing, fraudulent, pornographic, or harmful, or that could encourage criminal or unethical behavior, (ii) violate or infringe the privacy, copyright, trademark, trade dress, trade secrets, or intellectual property rights of any person or entity, or (iii) contain or transmit a virus or any other harmful component. Frontera may, but does not assume the obligation to, monitor and/or delete any User Generated Materials that it deems in its sole discretion to be in violation of the foregoing sentence. You represent and warrant that you have the legal right and authorization to provide all User Generated Materials to Frontera, and if relevant, its related third parties, so Frontera or those entities can provide you with the Services.

DMCA. The Digital Millennium Copyright Act of 1998 (the “DMCA”) provides recourse for copyright owners who believe that material appearing on the internet infringes their rights under U.S. copyright law. If you believe in good faith that materials available on the Service infringe your copyright, you (or your agent) may send to Frontera a written notice by mail or email, requesting that Frontera remove such material or block access to it. If you believe in good faith that someone has wrongly filed a notice of copyright infringement against you, the DMCA permits you to send to Frontera a counter-notice. Notices and counter-notices must meet the then-current statutory requirements imposed by the DMCA. See http://www.copyright.gov/ for details. Notices and counter-notices must be sent in writing to Frontera as follows: By mail to Frontera, 1517 Blake Street, Suite 250 Denver, CO 80202 Attention: DMCA; or by email to support@Fronterahealth.com.

Electronic Contracting, Consent, Acceptance and Agreement to Terms; Technical Requirements

YOU ACKNOWLEDGE THAT YOU MAY USE THE PLATFORM OR SERVICES ONLY IF YOU FORM A BINDING CONTRACT WITH FRONTERA AND ONLY IN COMPLIANCE WITH THESE TERMS.

Methods of Acceptance: By any of the following actions, you agree to be bound by these Terms: (i) Electronically accepting these Terms; (ii) Clicking “I AGREE” or any similar acceptance button or checkbox; (iii) Creating an Account; (iv) Accessing or using the Platform or Services; or (v) Executing any document that references or incorporates these Terms.

Electronic Transaction Consent: You consent to transact business electronically in accordance with the UETA and the E-SIGN Act. You agree that electronic signatures, contracts, orders, and other records, and electronic delivery of notices, policies, and records of transactions initiated or completed through the Platform will have the same legal effect, validity, and enforceability as paper records and manual signatures.

Technical Requirements: You must have a user account to access the Platform or Services. You represent that you have the hardware and software, as described above, necessary to access electronic records and that you consent to receive all communications, agreements, and notices electronically. You may request paper copies of any electronic communications by contacting support@fronterahealth.com, though you acknowledge that such requests may delay processing and may be subject to reasonable fees.

Withdrawal of Consent: You may withdraw your consent to receive electronic communications at any time by contacting support@fronterahealth.com, but such withdrawal may result in termination of your access to the Platform and Services. For Service Recipients receiving medical treatment, Frontera and the Medical Groups will ensure that any ongoing medical care is transitioned in accordance with applicable clinical standards and healthcare laws, including proper notice and coordination of care to prevent patient abandonment.

Indemnification

You agree to defend, indemnify, and hold Frontera, its Affiliated Providers, and any other affiliates harmless from and against any and all rights, demands, losses, liabilities, damages, claims, causes of action, actions, and suits (no matter whether at law or equity), fees, costs, and attorney’s fees of any kind whatsoever arising directly or indirectly out of or in connection with: (i) your use or misuse of the Platform or Services, or any information posted on the Platform; (ii) your breach of the Terms of Use or Privacy Policy; (iii) the content or subject matter of any information you provide to Frontera, the Affiliated Providers, your Provider, or a customer service agent; or (iv) any negligent or wrongful act or omission by you in your use or misuse of the Platform, Services, or any information on the Platform, including without limitation, infringement of third party intellectual property rights, privacy rights, or negligent or wrongful conduct. Notwithstanding the foregoing, you shall not be required to indemnify Frontera or its Affiliated Providers for claims arising from: (a) Frontera’s or its Affiliated Providers’ unauthorized use or disclosure of PHI or clinical session recordings in violation of HIPAA or these Terms, provided that authorized use includes use of de-identified data and recordings for AI model training and

platform development as described in these Terms; (b) security breaches or data breaches caused by Frontera’s or its Affiliated Providers’ failure to implement reasonable safeguards; or (c) medical malpractice or negligence by healthcare providers employed by or affiliated with Frontera’s Affiliated Providers.

Disclaimers of Warranties; Limitation of Liability; Release

YOU EXPRESSLY AGREE THAT ANY ACCESS AND USE OF THE PLATFORM AND SERVICES IS VOLUNTARY AND AT YOUR SOLE RISK. THE PLATFORM AND SERVICES ARE PRESENTED ON AN “AS IS” AND “AS AVAILABLE” BASIS. TO THE FULLEST EXTENT PERMITTED BY LAW, FRONTERA, THE MEDICAL GROUPS AND THE PROVIDERS DISCLAIM ALL REPRESENTATIONS OR WARRANTIES OF ANY KIND, EITHER EXPRESSED OR IMPLIED, WITH RESPECT TO THE PLATFORM, THE SERVICES, AND ANY CONTENT, INFORMATION, PRODUCT, SERVICE OR OTHER MATERIALS PROVIDED ON OR THROUGH THE PLATFORM OR THE SERVICES, INCLUDING, BUT NOT LIMITED TO, THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, THE QUALITY, ACCURACY, COMPLETENESS OR TIMELINESS OF INFORMATION, QUIET ENJOYMENT, AND NON-INFRINGEMENT OF THIRD PARTIES’ RIGHTS. NEITHER FRONTERA NOR THE MEDICAL GROUPS WARRANT THAT THE PLATFORM WILL FUNCTION WITHOUT DELAYS, DISRUPTIONS, INTERFERENCES, IMPERFECTIONS, CORRUPTION, CYBER ATTACK, VIRUSES, MALWARE, OR ANY ADVERSE INCIDENT, OR THAT DEFECTS IN THE PLATFORM WILL BE CORRECTED. YOU ARE RESPONSIBLE FOR IMPLEMENTING PROCEDURES SUFFICIENT TO SATISFY YOUR NEEDS FOR DATA BACK-UP AND SECURITY.

YOU ACKNOWLEDGE AND UNDERSTAND THAT THE USE OR MISUSE OF THE PRODUCTS OBTAINED THROUGH THE PLATFORM OR SERVICES, INCLUDING MEDICATIONS, MAY RESULT IN UNDESIRABLE OR UNEXPECTED CONSEQUENCES. TO THE FULLEST EXTENT OF APPLICABLE LAW, FRONTERA, THE MEDICAL GROUPS AND THE PROVIDERS DO NOT ACCEPT ANY LIABILITY FOR THE CONSEQUENCES ARISING FROM THE APPLICATION, USE, OR MISUSE OF ANY PRODUCTS OR SERVICES CONTAINED ON OR MADE AVAILABLE THROUGH THE PLATFORM, INCLUDING ANY INJURY OR DAMAGE TO ANY PERSON OR PROPERTY AS A MATTER OF NEGLIGENCE, OR OTHERWISE.

HIPAA COMPLIANCE, ELECTRONIC RECORDS, AND AI TRAINING: You acknowledge that PHI may be created, transmitted, stored, and accessed electronically through the Platform and in connection with the Services. Frontera and the Medical Groups maintain administrative, physical, and technical safeguards designed to protect the confidentiality, integrity, and availability of electronic PHI in compliance with the Health Insurance Portability and Accountability Act (HIPAA) and its implementing regulations, including the HIPAA Security Rule (45 CFR Part 164, Subpart C).

DATA USE FOR AI TRAINING AND PLATFORM DEVELOPMENT: You acknowledge and expressly consent that Frontera may use, retain, process, and analyze data collected through the Platform and Services, including de-identified clinical data, session recordings, usage data, and other information, for purposes of training, improving, and developing Frontera’s artificial intelligence models, machine learning algorithms, and platform functionality. To the fullest extent permitted under HIPAA and applicable Colorado law, Frontera will de-identify PHI in accordance with the de-identification standards set forth in 45 CFR § 164.514(a)-(c) before using such data for AI training purposes. Once properly de-identified in

compliance with HIPAA standards, such data is no longer considered PHI and Frontera retains all rights, title, and interest in such de-identified data in perpetuity, including the right to use, reproduce, modify, distribute, and create derivative works from such data for any lawful business purpose, including commercial purposes.

For Platform Licensees, you acknowledge that data generated by your employees, contractors, and consultants through their use of the Platform, including usage patterns, clinical documentation, and platform interactions, may be collected and used by Frontera for AI training and platform development purposes.

For Service Recipients, you acknowledge that clinical session recordings, treatment data, diagnostic information, and behavioral data collected during your receipt of Services may be de-identified and used by Frontera for AI training and development purposes. You understand that once de-identified, you will have no ownership rights or control over such data.

You consent to the electronic creation, storage, transmission, and access of your PHI. You have the right to: (i) receive a paper copy of any HIPAA authorization or notice of privacy practices upon request; (ii) revoke any HIPAA authorization in writing (which may be submitted electronically), provided that such revocation does not affect Frontera’s rights to use previously collected and de-identified data; and (iii) access, amend, and receive an accounting of disclosures of your PHI as provided under HIPAA, except that you have no right to access or amend de-identified data that is no longer considered PHI.

Limitation of Liability. TO THE FULLEST EXTENT PERMITTED BY LAW, FRONTERA AND THE MEDICAL GROUPS AND THEIR OFFICERS, DIRECTORS, MEMBERS, MANAGERS, OWNERS, SHAREHOLDERS, PARTNERS, AGENTS, EMPLOYEES, REPRESENTATIVES, AFFILIATES, SUCCESSORS, ASSIGNS, TRANSFEREES, CONTRACTORS, OR LICENSEES (COLLECTIVELY, THE “RELATED PARTIES”), ARE NEITHER RESPONSIBLE NOR LIABLE FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, EXEMPLARY, PUNITIVE OR SPECIAL DAMAGES WHATSOEVER (INCLUDING, WITHOUT LIMITATION, THOSE RESULTING FROM LOST PROFITS, LOST DATA, SUBSTITUTE SERVICES, OR BUSINESS INTERRUPTION, OR FOR ANY DAMAGES FOR PERSONAL OR BODILY INJURY OR EMOTIONAL DISTRESS, INCLUDING DEATH) CAUSED BY OR ARISING FROM OR IN CONNECTION IN ANY WAY TO THE PLATFORM, PRODUCTS, SERVICES, CONTENT OR INFORMATION CONTAINED WITHIN THE PLATFORM, INCLUDING ANY SERVICES PERFORMED OR PRODUCTS OFFERED BY THE THIRD PARTIES (AS DEFINED HEREIN), WHETHER BASED ON WARRANTY, CONTRACT, TORT, OR ANY OTHER LEGAL THEORY AND WHETHER OR NOT ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. YOUR SOLE REMEDY FOR DISSATISFACTION WITH THE PLATFORM OR SERVICES IS TO STOP USING THE PLATFORM OR THOSE SERVICES. TO THE EXTENT ANY ASPECTS OF THE FOREGOING LIMITATIONS OF LIABILITY ARE NOT ENFORCEABLE, THE MAXIMUM LIABILITY OF FRONTERA, THE MEDICAL GROUPS AND THEIR RELATED PARTIES TO YOU WITH RESPECT TO YOUR USE OR ACCESS OF (OR INABILITY TO USE OR ACCESS) THE PLATFORM OR SERVICES IS $500 (FIVE HUNDRED DOLLARS). YOU HEREBY AGREE TO WAIVE, TO THE FULLEST EXTENT PERMITTED BY LAW, ALL LAWS THAT LIMIT THE EFFICACY OF SUCH LIMITATIONS OR RELEASES.

ANY CLAIMS ARISING IN CONNECTION WITH YOUR USE OF THE PLATFORM OR SERVICES MUST BE BROUGHT WITHIN ONE (1) YEAR OF THE DATE OF THE EVENT GIVING RISE TO SUCH ACTION; ACTIONS

BROUGHT THEREAFTER ARE FOREVER BARRED. EXCEPT AS EXPLICITLY PROVIDED HEREIN, YOU UNDERSTAND AND AGREE THAT YOUR USE OF THE PLATFORM OR SERVICES IS PREDICATED UPON YOUR WAIVER OF ANY RIGHT TO PARTICIPATE IN A CLASS ACTION SUIT FOR ANY LOSSES OR DAMAGES RESULTING FROM YOUR USE OF THE PLATFORM OR SERVICES.

SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES OR THE LIMITATION OR EXCLUSION OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES. TO THE EXTENT THAT FRONTERA AND THE MEDICAL GROUPS MAY NOT DISCLAIM ANY IMPLIED WARRANTY OR LIMIT ITS LIABILITIES, THE SCOPE AND DURATION OF SUCH WARRANTY AND THE EXTENT OF FRONTERA AND THE MEDICAL GROUPS’ LIABILITY WILL BE THE MINIMUM PERMITTED UNDER APPLICABLE LAW.

Release. You hereby release and hold harmless Frontera, the Medical Groups and their Related Parties from and against all claims that you have or may have against them for infringement, violation of the rights of privacy or publicity, defamation, disparagement, personal injury, property damage, negligence and/or any other legal theory arising from or in connection with the Platform or Services and products offered or provided on or through the Platform or Services and/or the rights and privileges granted or conveyed by you under these Terms of Use (including, without limitation, those rights and privileges relating to the User Materials and/or any elements, derivatives or marketing of the foregoing).

If you are a California resident, you waive California Civil Code Section 1542, which provides:

A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor or released party.

If you are not a California resident, you waive your rights under any statute or common law principle similar to Section 1542 that governs your rights in the jurisdiction of your residence.

Disputes and Binding Arbitration

PLEASE READ THIS SECTION CAREFULLY – IT MAY SIGNIFICANTLY AFFECT YOUR LEGAL RIGHTS, INCLUDING YOUR RIGHT TO FILE A LAWSUIT IN COURT.

THIS SECTION OF THE TERMS OF USE SHALL BE REFERRED TO AS THE “ARBITRATION AGREEMENT.” YOUR ACCEPTANCE OF THIS ARBITRATION AGREEMENT IS GOVERNED BY THE “Electronic Contracting, Acceptance and Agreement to Terms” SECTION OF THESE TERMS.

By accepting these Terms in accordance with the “Electronic Contracting, Acceptance and Agreement to Terms” section above, you and Frontera (collectively, “Parties“) agree that any dispute, claim, or controversy (except those specifically exempted below) arising out of or relating to (i) this Agreement and prior versions of this Agreement, or concerning the existence, applicability, breach, termination, enforcement, interpretation, scope, waiver, or validity thereof; and (ii) the use of the Platform or Services (collectively, “Disputes“) will be resolved on an individual basis by final and binding arbitration, regardless of its date of accrual. Except as it otherwise provides, this Arbitration Agreement is intended

to apply to the resolution of Disputes that otherwise would be resolved in a court of law or before a forum other than arbitration. All claims in arbitration are subject to the same statutes of limitation that would apply in court. You and the Company mutually agree to waive your respective rights to trial by jury.

The Parties acknowledge that the Agreement involves interstate commerce and agree that all issues relating to arbitration or enforceability of this Arbitration Agreement will be governed by the Federal Arbitration Act (9 U.S.C. §§ 1 et seq.). The arbitration shall be administered by the American Arbitration Association (“AAA”) under its Consumer Arbitration Rules (“AAA Consumer Rules“), which are available via the internet at www.adr.org or by using a service such as Google to search for “AAA Consumer Arbitration Rules”; provided however, that if there is a conflict between the AAA Consumer Rules and this Arbitration Agreement, this Arbitration Agreement shall govern. The following terms and procedures shall apply:

The arbitration shall be heard by one arbitrator selected in accordance with the AAA Consumer Rules. The arbitrator shall be a member of the bar of the state in which the arbitration will be conducted or a retired judge from any jurisdiction and, in either case, shall have experience in the law underlying the dispute.

Other than issues related to the Class Action Waiver (as defined below), the arbitrator, and not any federal, state, or local court or agency, shall have exclusive authority to resolve any dispute arising out of or relating to the interpretation, applicability, enforceability or formation of this Arbitration Agreement, any part of it, or of the Agreement including, but not limited to, any claim that all or any part of this Arbitration Agreement or Agreement is void or voidable.

Each party will pay the fees for its own attorneys, subject to any remedies to which that party may later be entitled under applicable law. In all cases where required by law, the Company will pay the arbitrator’s and arbitration fees. If under applicable law the Company is not required to pay all of the arbitrator’s and/or arbitration fees, such fee(s) will be apportioned between the Parties in accordance with said applicable law. Any disputes regarding whether the Company is required to pay the arbitrator’s and arbitration fees and/or how those fees are to be apportioned between the Parties will be resolved by the arbitrator.

The arbitrator shall issue orders (including subpoenas to third parties for pre-hearing discovery) allowing the parties to conduct discovery sufficient to allow each party to prepare its claims and/or defenses, taking into consideration that arbitration is designed to be a speedy and efficient method for resolving disputes.

Except as provided in the Class Action Waiver (as defined below), the arbitrator may award all remedies to which a party is entitled under applicable law and which would otherwise be available in a court of law, but shall not be empowered to award any remedies that would not have been available in a court of law for the claims presented in arbitration. The arbitrator shall apply the state or federal substantive law, or both, as is applicable.

Either party shall be permitted to file a motion to dismiss and/or motion for summary judgment and the arbitrator will apply the standards of the Federal Rules of Civil Procedure governing such motions.

The arbitrator’s decision or award shall be in writing with findings of fact and conclusions of law. Judgment may be entered on the arbitrator’s decision or award in any court of competent jurisdiction.

If the parties cannot otherwise agree on a location for the arbitration, the arbitration shall take place in Denver, Colorado. A party may apply to a court of competent jurisdiction for temporary or preliminary injunctive relief in connection with an arbitrable controversy in accordance with applicable law, and any such application shall not be deemed incompatible with or waiver of this Arbitration Agreement. The court to which the application is made is authorized to consider the merits of the arbitrable controversy to the extent it deems necessary in making its ruling, but only to the extent permitted by applicable law. All determinations of final relief, however, will be decided in arbitration.

If for any reason the AAA will not administer the arbitration, either party may apply to a court of competent jurisdiction with authority over the location where the arbitration will be conducted for appointment of a neutral arbitrator.

Nothing in this Arbitration Agreement prevents the investigation by a government agency of any report, claim or charge otherwise covered by this Arbitration Agreement. This Arbitration Agreement also does not prevent federal administrative agencies from adjudicating claims and awarding remedies based on those claims, even if the claims would otherwise be covered by this Arbitration Agreement. Nothing in this Arbitration Agreement prevents or excuses a party from satisfying any conditions precedent and/or exhausting administrative remedies under applicable law before bringing a claim in arbitration.

Class, Collective, and Other Representative Action Waivers (“Class Action Waiver“). By accepting these Terms as set forth in the “Electronic Contracting, Acceptance and Agreement to Terms” section, you and Frontera mutually agree to waive your right to have any dispute, claim, or controversy brought, heard or arbitrated as a class, collective, and/or other representative action to the maximum extent permitted by law, and an arbitrator will not have any authority to hear or arbitrate any such class, collective, or other representative action. You also waive your right to receive notice of any class, collective, or other representative action that may be filed. Notwithstanding any other clause contained in this Arbitration Agreement or the AAA Consumer Rules, as defined above and incorporated herein by reference, any claim that all or part of this Class Action Waiver is unenforceable, unconscionable, void or voidable may be determined only by a court of competent jurisdiction and not by an arbitrator. In any case in which (i) the dispute is filed as a class, collective, or other representative action; and (ii) there is a final judicial determination that all or part of the Class Action Waiver is unenforceable, the class, collective, or other representative action to that extent must be litigated in a civil court of competent jurisdiction, but the portion of the Class Action Waiver that is enforceable shall be enforced in arbitration.

Mass Arbitration. To the extent permitted by applicable law, to increase efficiency of resolution, in the event 25 or more arbitration demands of a similar nature are filed against Frontera or the Medical Groups, presented by or with the assistance or involvement of the same law firm or organization, this will constitute a “Mass Arbitration” and the following terms and procedures shall apply:

The Parties shall cooperate to group the arbitration demands into randomized batches of no more than 100 demands per batch. To the extent there are fewer than 100 arbitration demands left over after the batching previously described, a final batch shall consist of the remaining demands.

Claimants’ counsel shall organize and present the batched demands to the arbitration provider in a format as directed by the arbitration provider.

The arbitration provider shall treat each batch of demands as one case, with each case having one demand for arbitration, one appointed arbitrator, and one set of administrative documents, and administrative and filing fees per batch. A separate arbitrator will be appointed to, and administrative and filing fees assessed for, each batch of demands.

Arbitration demands are of a “similar nature” if they arise out of or relate to a similar factual scenario and raise the same or similar legal issues and seek the same or similar relief. For purposes of this Arbitration Agreement, “Parties” includes Frontera, the Medical Groups, and any licensee of the Platform or Services Recipient that are signatories to this Agreement. You shall cooperate in good faith with Frontera and the arbitration provider to implement such a batch approach to resolution and fees. Disagreements over the applicability of this batch arbitration process will be settled in a single, consolidated arbitration proceeding that includes all affected parties and is resolved by a single arbitrator subject to the requirements of this section. Notwithstanding any provision in the Agreement to the contrary, batch arbitrations shall take place in Denver, Colorado.

Exceptions to Arbitration. Notwithstanding the foregoing, this Arbitration Agreement shall not require arbitration of the following claims: (i) individual claims brought in small claims court so long as the matter remains in such court and advances only on an individual basis; (ii) individual claims of sexual assault or sexual harassment occurring in connection with your use of the Platform or Services, or in connection with medical services provided by the Medical Groups; (iii) claims related to violations of HIPAA, state healthcare privacy laws, or unauthorized use or disclosure of recordings containing PHI of patients, including recordings of diagnosis and treatment sessions; (iv) injunctive or other equitable relief in a court of competent jurisdiction to prevent the actual or threatened infringement, misappropriation, or violation of a party’s copyrights, trademarks, trade secrets, patents, or other intellectual property rights; and/or (v) claims that cannot be arbitrated under applicable federal or state law governing healthcare services or data privacy. Also, this Arbitration Agreement does not apply to disputes that may not be subject to arbitration as expressly provided by a controlling federal or state statute. Disputes between the parties that may not be subject to a pre-dispute arbitration agreement as provided by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Public Law 111-203), Ending Forced Arbitration of Sexual Assault and Sexual Harassment Act (H.R. 4445), or as provided by an Act of Congress are excluded from the coverage of this Arbitration Agreement.

Optional Pre-Arbitration Dispute Resolution and Notification. Before initiating arbitration, you and Frontera may first attempt to resolve any disputes informally for 30 days, unless this time period is mutually extended by the Parties. The informal negotiations begin upon receipt of written notice from one party to the other (“Notice of Dispute“), which may be provided electronically in accordance with

UETA and the E-SIGN Act. The Notice of Dispute must: (i) include the full name and contact information of the complaining party; (ii) describe the nature and basis of the dispute, claim, or controversy; and (iii) set forth the specific relief sought. Frontera will send its Notice of Dispute to your billing or email address on file with your account. You will send your Notice of Dispute to: Frontera, 1517 Blake St. Ste 250 Denver, CO 80202, or via email to support@fronterahealth.com with confirmation of receipt required. Electronic notices sent via email shall be deemed received when the sender receives an automated or manual confirmation of delivery or, if no confirmation is received, three (3) business days after sending to the email address on file. You agree to maintain current contact information in your account and acknowledge that failure to do so may result in your not receiving important notices. All offers, promises, conduct and statements, whether oral or written, made in the course of the negotiation by any of the Parties, their agents, employees, and attorneys are confidential, privileged and inadmissible for any purpose, including as evidence of liability or for impeachment, in arbitration or other proceeding involving the parties, provided that evidence that is otherwise admissible or discoverable shall not be rendered inadmissible as a result of its use in the negotiation.

Acceptance and Agreement to Terms of Arbitration Agreement. BY CREATING AN ACCOUNT, CLICKING “I AGREE,” OR OTHERWISE ACCESSING OR USING THE PLATFORM OR SERVICES, YOU ACKNOWLEDGE AND AGREE TO THE TERMS AS SET FORTH IN THE “ELECTRONIC CONTRACTING, ACCEPTANCE AND AGREEMENT TO TERMS” SECTION ABOVE AND THE ARBITRATION AGREEMENT.

You agree to notify Frontera immediately of any change to your email address or other contact information by updating your account information or by contacting support@fronterahealth.com.

Application to Third Parties. This Arbitration Agreement shall be binding upon, and shall include any claims brought by or against any third parties, including but not limited to your spouses, heirs, third-party beneficiaries and assigns, where their underlying claim(s) arise out of or relate to your use of the Platform or Services (whether as a Platform Licensee or Service Recipient), the provision of medical services by the Medical Groups, or Frontera’s collection, use, or retention of data for AI training and platform development purposes, provided such third parties have consented to this Arbitration Agreement in accordance with the “Electronic Contracting, Acceptance and Agreement to Terms” provisions set forth above, or are legally authorized representatives acting on behalf of the user with documented legal authority.

For claims involving minors receiving medical services, the legally authorized representative must: (i) have proper legal authority to bind the minor to arbitration under applicable Colorado law; (ii) provide consent in accordance with the “Electronic Contracting, Acceptance and Agreement to Terms” provisions, including consent to data collection and AI training as described in these Terms; and (iii) acknowledge receipt of a separate disclosure explaining the arbitration agreement’s effect on the minor’s rights and Frontera’s data use practices for AI training.

For Platform Licensees, employees, contractors, and consultants of Platform Licensees who may bring claims related to the collection or use of their data for AI training purposes shall be subject to this Arbitration Agreement if the Platform Licensee has properly obtained their consent as required under these Terms.

To the extent that any third-party beneficiary to this Agreement brings claims against the Parties, those claims shall also be subject to this Arbitration Agreement, subject to the same consent and disclosure requirements.

Right to Opt Out of Arbitration. You may opt out from this Arbitration Agreement within 30 days after you first create your user account and access or use the Platform or Services by sending written notice of your decision to opt-out to support@fronterahealth.com, using the subject line “Arbitration Opt-Out.” Please state that you are opting out of this Arbitration Agreement and Class Action Waiver and provide your name and address. You will receive a confirmation of receipt in accordance with the “Electronic Contracting, Acceptance and Agreement to Terms” provisions. If you opt out of this Arbitration Agreement and Class Action Waiver within the 30-day period, neither you nor Frontera will be required to arbitrate disputes and may instead litigate those disputes without regard to this Arbitration Agreement and Class Action Waiver. Should you not opt out of this Arbitration Agreement and Class Action Waiver within the 30-day period, you and Frontera shall be bound by the terms of this Arbitration Agreement and Class Action Waiver. You have the right to consult with counsel of your choice concerning this Arbitration Agreement and Class Action Waiver.

Changes to Arbitration Agreement. Frontera and the Medical Groups will provide 30 days’ notice of any material changes to the Arbitration Agreement. Changes will become effective on the 30th day and apply to all claims not yet filed. If you continue to maintain your user account and use the Platform or Services after the 30th day, you agree that any unfiled claims of which Frontera and the Medical Groups do not have actual notice are subject to the revised Arbitration Terms. If you do not agree to such changes, you may opt out by providing notice as described in the Arbitration Agreement.

If you reject any such changes by opting out of the Arbitration Terms pursuant to your right to opt out of arbitration, you may exercise your right to a trial by jury or judge, as permitted by applicable law, but any prior existing agreement to arbitrate disputes under a prior version of the Arbitration Terms will not apply to claims not yet filed. If Frontera and the Medical Groups change this Arbitration Agreement after the date you first accepted this Arbitration Agreement (or accepted any subsequent changes to this Arbitration Agreement), you agree that your continued maintenance of your user account and use of the Platform or Services 30 days after such change will be deemed acceptance of those changes. If you do not agree to such changes, you may opt out by providing notice as described in the Arbitration Agreement.

Survival. This Arbitration Agreement survives after the termination or expiration of the Parties’ relationship.

Miscellaneous Terms

You reaffirm your acknowledgment of the hardware and software requirements set forth in the “Electronic Contracting, Acceptance and Agreement to Terms” provisions above.

You understand and acknowledge that the Platform and Services may be subject to limitations, delays and other problems inherent in the use of third-party communication networks and facilities that are

outside of Frontera’s control, and thus Frontera will not be responsible for any delays, failures, or damages associated with the Platform which result from any system delays, downtimes, interruptions or other failures of or problems with the Platform which are outside of Frontera’s control. Frontera and the Medical Groups will not be deemed to be in breach of or liable for any breach of these Terms of Use or Frontera’s Privacy Policy due to any event or occurrence beyond Frontera and the Medical Groups’ reasonable control, including without limitation, acts of God, terrorism, war, invasion, epidemic, pandemic, failures of any public networks, electrical shortages, earthquakes or floods, civil disorder, strikes, fire, or other disaster; provided, however, that this force majeure provision shall not excuse obligations related to the protection of PHI under HIPAA and the HITECH Act, including but not limited to the Security Rule (45 CFR Part 164, Subpart C), Breach Notification Rule (45 CFR §§ 164.400-414), data security requirements, the secure storage, transmission, and handling of recordings containing patient PHI in compliance with the HIPAA Security Rule’s administrative, physical, and technical safeguards (45 CFR §§ 164.308, 164.310, 164.312), obligations related to AI training and model development using de-identified data as permitted under these Terms of Use, or payment of fees already incurred. Changes in federal, state or local laws and regulations are not considered force majeure events and do not excuse compliance with applicable legal requirements.

The Terms of Use and our relationship with you shall both be interpreted solely in accordance with the laws of the State of Colorado, excluding any rules governing choice of laws; provided, however, that where the Medical Groups provide medical services to patients, such services and any related claims shall also be governed by the healthcare laws and regulations of the state in which such services are provided, including but not limited to medical malpractice laws, patient rights statutes, and healthcare privacy regulations. Except for claims that must be arbitrated pursuant to the Arbitration Agreement, any claim or dispute arising in connection with your use of the Platform or Services (whether as a Platform Licensee or Service Recipient) shall be decided exclusively by a court of competent jurisdiction located in Denver, Colorado, and you consent to the personal jurisdiction of and venue in such courts, accept service of process by mail, and waive any and all jurisdictional and venue defenses or objections otherwise available.

THESE TERMS OF USE CONSTITUTE THE ENTIRE AGREEMENT BETWEEN YOU AND US REGARDING YOUR USE OF THE PLATFORM AND SERVICES, INCLUDING WITHOUT LIMITATION THE COLLECTION, USE, DE-IDENTIFICATION, AND RETENTION OF DATA FOR AI TRAINING, MODEL DEVELOPMENT, AND PLATFORM IMPROVEMENT PURPOSES. YOU CONFIRM THAT YOU HAVE NOT RELIED UPON ANY PROMISES OR REPRESENTATIONS BY US EXCEPT AS SET FORTH IN THIS AGREEMENT. YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THE PROVISIONS REGARDING FRONTERA’S USE OF DE-IDENTIFIED DATA, RECORDINGS, AND OTHER NON-PHI FOR AI DEVELOPMENT PURPOSES AS SET FORTH HEREIN.

You acknowledge and agree that Frontera is a third-party beneficiary of the terms applicable to the Services provided by the Medical Groups and that the Medical Groups and Providers are third-party beneficiaries of the terms applicable to the Platform licensed by Frontera. Clinical licensees of the Platform (including affiliated Medical Groups) are third-party beneficiaries of the terms governing the Platform’s functionality, data security, and HIPAA compliance obligations. Otherwise, unless expressly stated in the Terms of Use to the contrary, nothing herein is intended to create or establish third-party

beneficiary status rights or their equivalent in any other referenced individual, subcontractor or third party, and, except as specifically set forth in these Terms of Use, no third party shall have any right to enforce any right or enjoy any benefit that is created or established under these Terms of Use.

We may change the Terms of Use by posting modifications on the Platform and providing notice in accordance with the “Electronic Contracting, Acceptance and Agreement to Terms” provisions. Unless otherwise specified by us, all modifications shall be effective 30 days after posting and notice; provided, however, that for clinical licensees with active licensing agreements, material changes to terms governing data security, HIPAA compliance, or the handling of recordings containing PHI shall require 60 days’ prior written notice and shall not become effective until the licensee’s express written consent is obtained or the licensee terminates the agreement. Any such material changes must be documented in an amendment to the applicable BAA. Changes that would reduce the level of protection for PHI below HIPAA’s minimum standards are not permitted and shall be void ab initio. Notwithstanding the foregoing, Frontera may modify or expand its use of de-identified data, aggregated data, and non-PHI for AI training, model development, platform improvement, and research purposes without requiring express written consent, provided such modifications comply with applicable de-identification standards under 45 CFR § 164.514 and do not affect the security or confidentiality of PHI. The last update date of the Terms of Use is posted at the bottom of the Terms of Use. By maintaining your user account and using the Platform or Services after the changes become effective, you agree to be bound by such changes to the Terms of Use. If you do not agree to the changes, you must terminate your user account and cease all access to the Platform and participation in the Services. For Service Recipients actively receiving medical treatment at the time of such termination, Frontera and the Medical Groups shall ensure appropriate transition of care in accordance with applicable clinical standards of care and applicable state healthcare laws and regulations, including providing reasonable advance notice, offering referrals to alternative providers when clinically appropriate, and ensuring continuity of care during the transition period as required by the applicable standard of care and medical ethics obligations.

You may not assign, transfer, or delegate these Terms of Use, your user account, or any part thereof without each of Frontera and the Medical Groups’ prior written consent. Frontera and the Medical Groups may freely transfer, assign, or delegate all or any part of the Terms of Use, and any rights or duties hereunder or thereunder, including without limitation the right to use, retain, and further develop de-identified data, AI models, training datasets, and related intellectual property; provided, however, that any assignment or transfer by Frontera of its obligations as a Business Associate under HIPAA, including obligations related to the storage and security of recordings containing PHI, must be to an entity that: (i) agrees in writing to be bound by the same or greater HIPAA obligations and data security requirements as set forth in 45 CFR §§ 164.308, 164.310, and 164.312; (ii) executes a compliant BAA; and (iii) receives prior written authorization from the Covered Entity (Medical Groups) as required by 45 CFR § 164.502(e)(1). Frontera shall provide the Covered Entity with at least 30 days’ prior written notice of any proposed assignment and shall remain liable for any breaches occurring during the transition period. Notwithstanding the foregoing, Frontera may assign or transfer its rights to de-identified data, AI models, algorithms, and related intellectual property without restriction or consent, as such assets do not constitute PHI and are the exclusive property of Frontera. The Terms of Use will be binding upon and inure to the benefit of you, Frontera, and the Medical Groups, and your and their respective heirs, successors, and permitted assignees.

The paragraph headings in the Terms of Use are solely for the sake of convenience and will not be applied in the interpretation of the Terms of Use.

If any provision of the Terms of Use is held by a court of competent jurisdiction to be illegal, invalid, unenforceable, or otherwise contrary to law, the remaining provisions of the Terms of Use will remain in full force and effect.

For the avoidance of doubt, all clauses regarding intellectual property (including Frontera’s ownership of AI models, algorithms, training methodologies, and improvements developed using data collected through the Platform and Services), arbitration, limitations of liabilities, indemnification, licenses granted to Frontera for use of data in AI training and development, and obligations related to the protection, security, and confidentiality of recordings and PHI collected during the term of use shall survive the termination or expiration of your user account, use of the Platform, the Services, or the Terms of Use. Frontera’s rights to retain and use de-identified data, aggregated data, anonymized data, and any data that does not constitute PHI under 45 CFR § 164.514 for AI training, model development, platform improvement, analytics, research, and any other lawful business purposes shall survive termination indefinitely and shall not be subject to return or destruction obligations. Frontera’s obligations as a Business Associate under HIPAA and the HITECH Act shall survive for so long as Frontera maintains, stores, or has access to any PHI, including recordings of diagnosis and treatment sessions. Upon termination, Frontera shall, at the direction of the Covered Entity and as required by 45 CFR § 164.504(e)(2)(ii)(I), either return or destroy all PHI in its possession or control, and shall retain no copies, except as required by law or as permitted for de-identified data that no longer constitutes PHI. For Service Recipients receiving medical services through the Medical Groups, upon revocation of authorization, termination of services, or any other event causing cessation of medical treatment, Frontera and the Medical Groups shall ensure appropriate transition of care in accordance with applicable clinical standards of care and applicable state healthcare laws and regulations, including but not limited to providing reasonable notice to the patient or their legally authorized representative, offering referrals to alternative providers when clinically appropriate, maintaining continuity of care during any transition period as required by the applicable standard of care, and ensuring the patient’s access to their medical records as required by HIPAA and state law. The Medical Groups shall not abandon patients and shall comply with all applicable ethical obligations and state medical board requirements governing termination of the provider-patient relationship. Prior to any such return or destruction, Frontera may create and retain de-identified datasets, aggregated datasets, and derivative works that do not contain PHI, and such datasets and derivative works shall remain the exclusive property of Frontera. If return or destruction is not feasible, Frontera shall continue to protect the PHI in accordance with HIPAA requirements and limit further uses and disclosures to those purposes that make return or destruction infeasible. For clarity, data that has been properly de-identified in accordance with the Expert Determination method or Safe Harbor method under 45 CFR § 164.514(b) is not subject to return or destruction and may be retained by Frontera indefinitely.

Contact us

Please direct any questions you may have about creating a user account, the Platform, the Services, these Terms of Use, or your rights regarding electronic transactions and records to any one of the following:

• By email: support@fronterahealth.com
• By phone: (720) 248-8144
• Mailing Address: Frontera, Inc. / Medical Groups, 1517 Blake Street, Suite 250 Denver, CO 80202

The foregoing contact information may change from time-to-time by supplementation, amendment or modification of these Terms of Use.