Privacy Policy

Changes To This Policy

We may modify this Policy from time to time, in which case we will update the "Last Updated" date at the top of this Policy. If we make material changes to how we use or disclose personal data, we will use reasonable efforts to notify you. If you do not agree to any updates to this Policy, please do not continue using or accessing the Services.

Information We Collect

When you use or access the Services, we collect certain categories of information about you from a variety of sources. We may use this information to provide and improve the Services, maintain our business relationship, enhance safety and security, provide customer support, and comply with applicable legal obligations.

Information You Provide to Us

Information that you directly submit through our Services may include:

• Basic contact details and personal identifiers: such as name and email. We use this to create and maintain your account.
• Demographic data: such as age, gender, height, weight, and race/ethnicity.
• Health and wellness data: such as information about your physical, mental, and emotional well-being, data collected from wearable devices, and information about your medical and family medical history. For more information, please see our Consumer Health Data Privacy Policy.
• Account information: such as your Apple ID, Google account ID, username, and password. You are responsible for keeping your account credentials safe.
• Any other information you choose to include in communications with us.

Information Collected Automatically

We and third parties may use cookies, pixels or other tracking technologies to automatically collect:

• Device information (device type, operating system, unique device identifier, IP address)
• Location information (approximate location derived from your IP address)
• Interaction data (browser type, log data, date/time stamps, clickstream data)

Our website is not designed to respond to "Do Not Track" signals received from browsers.

Information Collected From Other Sources

• Data from wearables and health tracking devices you choose to link to the Services
• Analytics data from providers such as Mixpanel and Google Analytics

De-identified and Anonymized Information

We may deidentify or anonymize your information such that it cannot reasonably be used to identify you, and we may use and/or disclose such information for any purpose.

Disclosure of Your Information

We may disclose your information to the following categories of third parties:

• Our affiliates or others within our corporate group
• Vendors or service providers who help us provide the Services (cloud storage, security, analytics, payment processing, etc.)
• Third parties in connection with an asset sale, merger, bankruptcy, or other business transaction
• Law enforcement, judicial orders, and regulatory authorities as required by applicable law

Third-Party Websites and Links

We may provide links to third-party websites or platforms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. You should review the applicable privacy policies of any third-party sites you visit.

Children's Privacy

Our Services are not intended for children. We do not seek or knowingly collect any personal data about children. If we become aware that we have unknowingly collected information about a child under 13 years of age, we will make commercially reasonable efforts to delete such information. Parents or guardians may contact us at info@tolion.com to request deletion.

Data Security and Retention

Despite our reasonable efforts to protect your information, no security measures are impenetrable. We recommend that you do not use unsecure channels to send us sensitive or confidential information.

We retain your information for as long as is reasonably necessary for the purposes specified in this Policy, considering whether we need it to provide the Services, resolve disputes, enforce agreements, or comply with legal obligations.

Data Transfers

The information we collect may be stored and processed in countries outside the European Economic Area (EEA) and UK. For any transfers of data from the EEA or UK, we rely on the European Commission's standard contractual clauses or the UK Information Commissioner's international data transfer addendum, as applicable.

Contact Information

For any questions, requests, or concerns regarding this Policy or your rights, please contact us:

• Email: info@tolion.com
• Address: Tolion Health Inc., 11 Blossom Circle, Natick, MA 01760