Privacy Policy

Effective as of July 14, 2025.  

This Privacy Policy describes how Inclusiv Health, Inc. (“Inclusiv Health,” “we”, “us” or “our”) processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile application, social media pages, marketing activities, and other activities described in this Privacy Policy (collectively, the “Service”)).

Personal information we collect

Information you provide to us or that we may generate about you.

Personal information you may provide to us through the Service or otherwise or that we may generate about you includes:

• Contact data, such as your preferred name, email address, industry, and phone number.
• Demographic data, such as your city, state, country of residence, postal code, gender description, and age.
• Profile data, such as the username and password that you may set to establish an online account on the Service, referral or access code, biographical details, photograph or picture, links to your profiles on social networks, interests, preferences, and any other information that you add to your account profile.  
• Professional data, such as your professional title, specialty, training level, and company or educational institution name.
• Communications data based on our exchanges with you, including when you contact us through the Service (including, providing feedback or requesting support), communicate with us via chat features, communicate with us via social media, or otherwise.
• Conversational data such as transcripts created based on what you write to Inclusiv Health, and what Inclusiv Health writes back to you, as well as options you select during conversations.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Wellness-related information, such as information concerning your past, present and future wellness status, challenges, goals and any other information that you voluntarily provide in response to prompts and other questions through the Services.
• Relationship data, such as familial or other relationship to third parties whose personal information you may provide to us when interacting with the Service.
• Sensory data, such as audio or similar information.
  Intake and survey data, such as the information you provide to us as part of an intake survey, assessment, or other questionnaire.
• Derived data, such as information we derive from personal information about you based on your interactions with the Service, could include your wellness-related information, preferences, interests and other information.
• Characteristics of protected classifications, such as your age, race or ethnic origin, sexual orientation or other information that you choose to share.  
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources

We may combine personal information we receive from or generate about you with personal information we obtain from other sources, such as:

• Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
• Private sources, such as data providers and social media platforms.
• Enterprise customers, such as your employer or educational institution that provided or provides you with access to the Service.
• Third-party services, such as Google or other social media services, that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service
• Service providers. We may combine personal information we receive from or generate about you with information we receive from service providers that collect or provide personal information to us in connection with the work they do on our behalf.

Automatic data collection

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data such as your interactions with our email or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

Cookies and similar technologies

Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
• Software development kits. An SDK is third-party computer code that may be used for a variety of purposes, including to provide us with analytics regarding the use of Service, to integrate with third-party platforms, and to add features or functionality to the Service.
• Session-replay technologies, such as those provided by Amplitude that employ software code to record users’ interactions with the Services in a manner that allows us to watch video replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls during those sessions. These replays help us diagnose usability problems and identify areas for improvement. By default, these recordings are anonymized – sensitive inputs (like form fields and keystrokes) are masked automatically and our team has not explicitly configured any sensitive fields to be visible. You can learn more about Amplitude at https://amplitude.com/privacy.

Data about others

We may offer features that help users invite their contacts to use the Service (including, without limitation, to submit information relating to the users), and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

How we use your personal information

Depending on the type of personal information, we may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations

We may use your personal information to:

• provide, operate and improve the Service and our business (including, without limitation, to build, develop and operate algorithms and models);
• establish and maintain your user profile on the Service;
• facilitate your invitations to contacts who you want to invite to join the Service;
• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
  understand your needs and interests, and personalize your experience with the Service and our communications; and
• provide support for the Service, and respond to your requests, questions and feedback.

Service personalization

We may use your personal information to personalize the Service for you, which may include using your personal information to:

• understand your needs and interests;
• personalize your experience with the Service and our Service-related communications; and
• remember your selections and preferences as you navigate the Service.

Research and development

We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services.

Marketing

We and our service providers may collect and use certain of your personal information to send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Service improvement and analytics

We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Compliance and protection

We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
  enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

For example, sometimes based on your personal information, Inclusiv Health may detect data that might indicate that you or someone else were in danger. In this case, Inclusiv Health may use and otherwise share your personal information.

With your consent

In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

Data sharing in the context of corporate events

We may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information below.

To create aggregated, de-identified and/or anonymized data

We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business, and to train our artificial intelligence models and for other machine learning purposes.

Cookies and similar technologies

In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
• Functionality. To enhance the performance and functionality of our services.
• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we may use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.  
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When we no longer require the personal information, we have collected about you, we may either delete it, anonymize it, or isolate it from further processing.

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How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates

To the extent relevant, our corporate parent, subsidiaries, and affiliates.

Service providers

Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

Generative AI platforms

We use third-party artificial intelligence (AI) providers to provide certain aspects of the Service.

Enterprise customers

We may share certain limited, aggregated metric information with the enterprise customer through which you accessed the Service.

Linked third-party services

If you log into the Service with, or otherwise link your Service account to, a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Professional advisors

Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others

Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above

Business transferees

We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in or financings of Inclusiv Health, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Inclusiv Health as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Your choices

Access, update, and delete certain of your information

If you have registered for an account with us through the Service, you may be able to access, update and delete certain personal information through account features.

Opt-out of communications

You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other

Training data

As set out in the How we use your personal information section, we may use your personal information to train our AI models and for other machine learning purposes. This helps improve the Service. If you would like to opt-out of our processing of your personal information for this purpose, please navigate to “Settings” and update your relevant permissions.

Cookies

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

Blocking images/clear gifs

Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Linked third-party platforms

If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Declining to provide information

We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Delete or close your account

If you wish to request to delete or close your account, please navigate to “Settings” and take the appropriate action under “Manage Data.”

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where data protection laws may not be as protective as those in your state, province, or country.

Children

The Service is not intended for use by anyone under 13 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

• Email: team@Inclusivhealth.ai

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