LifeSpan Digital Health, Inc. (registered in the United States, 9040 S. Rita Road, Suite 1270, Tucson, AZ 85747), and its affiliates (collectively, “LifeSpan,” “we,” “us,” or “our”) care about your privacy and are committed to protecting your Personal Data in accordance with fair information practices and applicable data privacy laws.

Scope of This Privacy Policy

This Privacy Policy (“Policy”) explains how we collect and use individuals’ Personal Data (“you” or “user”) in the course of our operations, including our websites, mobile applications, the emPower+ Wellness Hub, and other services provided by us (collectively, the “Services”).

Personal Data is all information relating to an identified or identifiable individual and does not include data whereby personally identifiable information has been removed (such as anonymous data).

Please read this Policy carefully. If you do not agree with this Policy or any part thereof, you should not access or use any part of the Services or otherwise provide us with your Personal Data. If you change your mind in the future, you should stop using the Services and provide us with no further Personal Data.

Collection of Personal Data

We collect Personal Data in a variety of ways through our normal business activities, in both online and offline contexts. This includes, for example, when you place orders or purchase our products or Services, enter into agreements or communicate with us, or visit and use our website or mobile application (“App”).

We also receive Personal Data from our customers in order to perform Services on their behalf and from social networks or third-party partners such as analytics providers.

What Personal Data We Collect

Use of the Services is voluntary. To the extent that you choose to use the Services, we may collect Personal Data about you directly from you or from third parties, as described below.

Information Collected from You

Contact Information
Information that allows us to communicate with you, such as your name, job title, age, date of birth, prefix and title, gender, username, mailing address, telephone number, email address, or other contact details.

Relationship Information
Information that helps us do business with you, such as product and Service interests, preferences, language, marketing preferences, and demographic data.

Transaction Information
Information about how you interact with us, including purchases, inquiries, account details, order and contract information, delivery and shipping details, billing information, credit card number, and information about how you use our websites.

Service Information
Information that helps us provide our Services, including content you add in the App, responses to quizzes and questionnaires, information regarding your emotional status, and interactions with an emPower+ Coach.

If you subscribe to the emPower+ program, we may also process biometric and wellness-related data, including:

• Galvanic Skin Response (GSR)

• Heart Rate Variability (HRV)

• Skin Temperature (ST)

• Voice data

• Motion and geolocation data (e.g., 9-axis accelerometer)

• Bluetooth data

• Emotion recognition data
  
  

The emPower+ app collects heart rate and sleep data to recognize sleep stages, improve bedtime routines, and provide insights into well-being. We do not make medical diagnoses based on this data. Instead, the data is presented through the app interface and used to provide wellness intervention recommendations.

Our scoring engine uses these metrics to assess potential burnout risk.

Specific data categories include:

• Respiratory Rate: Used to predict burnout, optimize recovery, and enhance resilience

• Sleep Session Data: Critical to understanding the relationship between sleep and burnout

• Heart Rate Metrics: Including heart rate, resting heart rate, and HRV (RMSSD), used alongside sleep, diet, and exercise data to calculate overall wellness scores
  
  

Users may revoke permissions to access Health Connect data at any time through device settings or within the app. All data is anonymized, remains local, and is not shared with third parties.

Support Information
Information provided when you contact us for support, including email address and the content of communications, complaints, and feedback.

Cookie Information
Information collected via cookies, including IP address and advertising identifiers. Please refer to our Cookie Policy for details.

System-Related Information
Automatically collected technical information about your device, such as model, operating system, and version.

Information Collected from Other Sources

Third Parties
We may obtain Personal Data from third-party sources. If we combine this data with information collected directly from you, it will be treated as Personal Data under this Policy.

How We Use Personal Data

We use Personal Data for the following purposes:

• Providing the Services: To fulfill contractual obligations, process orders, manage accounts, deliver products and Services, and provide customer support.

• Support and Communication: To respond to inquiries, complaints, and provide service updates.

• Service Improvement: To analyze usage trends, improve functionality, and develop new features.

• Marketing and Advertising: To send marketing communications, where permitted by law and with consent when required.

• Legal Compliance and Enforcement: To enforce Terms of Service, comply with legal obligations, and defend against legal claims.

• Scientific Research: To conduct proportionate scientific research, including the use of sensitive Personal Data where permitted.

• Anonymization: To de-identify data for analytics and research purposes.
  
  

Where Personal Data is required to provide Services or by law, failure to provide it may prevent us from delivering Services.

IP Addresses and Cookies

We use IP addresses, browser, and device information to administer and improve our Services and for security purposes. Cookies help personalize user experiences. You may disable cookies through your browser settings. For more information, see our Cookie Policy.

Information Security

We implement appropriate technical, physical, and organizational safeguards to protect Personal Data. Access is limited to authorized personnel on a need-to-know basis. While we take reasonable measures to secure data, transmission over the internet carries inherent risks.

Data Disclosures

We may share Personal Data with:

• Affiliates

• Vendors and service providers

• Public authorities and law enforcement where required by law

• Third parties in connection with mergers, acquisitions, or asset transfers

• Third parties with your consent

  
  

We are not responsible for third-party privacy practices.

Your Options and Rights

You may:

• Withdraw consent

• Access your Personal Data

• Correct inaccurate data

• Request erasure

• Object to or restrict processing

• Request data portability

  
  

Requests may require identity verification. Certain requests may be limited under applicable law.

Data Retention

We retain Personal Data only as long as necessary for the purposes for which it was collected or as required by law.

Children’s Privacy

The Services are not intended for individuals under 18. We do not knowingly collect Personal Data from children.

Updates to This Privacy Policy

We may update this Policy periodically. Please review it regularly to stay informed of changes.

How to Contact Us

For questions or requests regarding this Policy, contact us at: privacy@lifespandh1.com