MY NEURO LLC PRIVACY POLICY

1. Important Note About Wellness Information

The Program is a wellness, education, resilience, and self-guided practice platform. It is not a medical service, and My Neuro is generally not a "covered entity" or "business associate" under the Health Insurance Portability and Accountability Act (HIPAA). Information you provide through the Program is therefore generally not protected health information under HIPAA. We nevertheless treat wellness-related information you provide, such as check-in responses, journal entries, and progress data, as sensitive information and handle it as described in this Privacy Policy. If you receive the Program through a healthcare provider or another arrangement that is subject to HIPAA or other health-privacy law, additional terms may apply under that arrangement.

2. Information We Collect

We collect the following categories of information:

a. Account and Identity Information. Name, email address, username, password credentials, telephone number if provided, organization or sponsor affiliation, program assignment, and account preferences.

b. Program Activity and Wellness Information. Check-in responses, self-assessments, journal entries, reflections, goals, preferences, exercise and session completion data, progress indicators, streaks, scores, and similar information you enter or generate while using the Program.

c. Payment and Transaction Information. If you purchase access directly, our payment processors collect payment card or other payment information. My Neuro does not store full payment card numbers. We receive transaction confirmations, subscription status, and billing history.

d. Sponsor, Grant, and Enrollment Information. If your access is provided through an employer, coach, provider, partner, grant, or administrator (each, a "Sponsor"), we may receive enrollment and eligibility information from that Sponsor, such as your name, email address, cohort, and program assignment.

e. Device and Usage Information. IP address, device type, operating system, browser type, app version, device identifiers, log data, session timestamps, pages and features used, crash data, and general location inferred from IP address. We do not collect precise GPS location.

f. Communications. Messages you send to us, support requests, survey responses, testimonials you choose to provide, and records of our communications with you.

3. How We Collect Information

We collect information directly from you when you create an account, complete check-ins or sessions, enter journal entries, communicate with us, or make a purchase. We collect information automatically through cookies, software development kits, log files, and similar technologies when you use the Program. We collect information from Sponsors who arrange your access, and from service providers such as payment processors, app stores, and analytics providers.

4. How We Use Information

We use information to:

a. provide, operate, personalize, and administer the Program, including adaptive sequencing, recommendations, and progress tracking;

b. create and manage accounts, verify eligibility, and administer subscriptions, grants, trials, and Sponsor arrangements;

c. process payments and prevent fraud;

d. provide user support and respond to inquiries;

e. communicate with you about the Program, including service messages, reminders, and, with your consent where required, marketing communications;

f. maintain safety, security, and integrity of the Program, enforce the Agreement, and protect My Neuro’s intellectual property and trade secrets;

g. analyze usage, and maintain, improve, and develop the Program, including through de-identified or aggregated data as described in Section 8; and

h. comply with legal obligations and exercise or defend legal claims.

5. How We Share Information

We do not sell your personal information, and we do not share your personal information for cross-context behavioral advertising. We share information only as follows:

a. Service Providers. We share information with vendors that perform services for us, such as hosting, data storage, payment processing, analytics, communications, email and text-message delivery, customer support, and security. Service providers are permitted to use information only to perform services for My Neuro.

b. Sponsors, Coaches, and Administrators. If your access is provided through a Sponsor, that Sponsor may receive limited administrative information necessary to support, administer, or verify your participation, such as enrollment status, program assignment, completion status, session activity, and grant status. Consistent with Section 9 of the Agreement, Sponsors, coaches, employers, partners, and administrators do not receive access to your private journal entries, private reflections, or sensitive personal responses unless that access is expressly disclosed in the Program or you authorize it.

c. Legal and Safety. We may disclose information when we believe in good faith that disclosure is required by law, subpoena, or legal process, or is necessary to protect the rights, property, safety, or security of My Neuro, our users, or others, or to enforce the Agreement.

d. Business Transfers. If My Neuro is involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction, subject to reasonable confidentiality protections and this Privacy Policy or a successor policy.

e. With Your Direction or Consent. We share information with other parties when you direct us to do so or otherwise consent.

6. Cookies and Analytics

We and our service providers may use cookies, pixels, local storage, and similar technologies to keep you signed in, remember preferences, measure usage, and improve the Program. You can control cookies through your browser or device settings, though some features may not function properly without them. Where required by law, we will request consent before placing non-essential cookies. We honor legally required opt-out preference signals, such as the Global Privacy Control, where applicable law requires.

7. Email and Text Communications

We may send service and transactional messages related to your account and Program activity. With your consent where required, we may also send marketing or promotional messages. You may opt out of marketing emails by using the unsubscribe link in the message, and you may opt out of text messages by replying STOP. Message and data rates may apply to text messages. Opting out of marketing communications does not stop service or transactional messages necessary to operate your account.

8. De-Identified and Aggregated Data

We may de-identify or aggregate information so that it no longer reasonably identifies you, and we may use and disclose that de-identified or aggregated data for any lawful purpose, including research, benchmarking, and Program development. We commit to maintaining de-identified data in de-identified form and not attempting to re-identify it, except as permitted by law to test the effectiveness of de-identification.

9. Data Retention

We retain personal information for as long as your account is active and as needed to provide the Program, comply with legal obligations, resolve disputes, enforce the Agreement, and protect our legal rights. When information is no longer needed, we delete it, de-identify it, or securely archive it. You may request deletion of your account and associated personal information as described in Section 11.

10. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information, including access controls, encryption in transit, and account-based authentication. No system is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your login credentials and for notifying us promptly of any suspected unauthorized access to your account.

11. Your Choices and Rights

You may access and update most account information through your Program settings. You may also contact us using the information in Section 16 to request that we:

a. confirm whether we process your personal information and provide access to it;

b. correct inaccurate personal information;

c. delete your personal information, subject to legal retention requirements;

d. provide a portable copy of personal information you provided to us; and

e. limit or object to certain processing where applicable law provides that right.

Depending on where you live, you may have specific rights under state privacy laws, such as the California Consumer Privacy Act as amended, the Colorado Privacy Act, the Virginia Consumer Data Protection Act, the Washington My Health My Data Act, or similar laws, including rights regarding consumer health data. We will honor rights requests as required by the law that applies to you. We will not discriminate against you for exercising your privacy rights. If we deny a request, you may appeal by contacting us and identifying your request and the reason you believe the denial was incorrect. Authorized agents may submit requests on your behalf where permitted by law, subject to verification.

12. Children’s Privacy

The Program is intended for users who are at least 18 years of age. Users who are at least 13 but under 18 may use the Program only with the consent and supervision of a parent or legal guardian, as described in the Agreement.

The Program is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete it. If you believe a child under 13 has provided personal information to us, please contact us using the information in Section 16.

13. Users Outside the United States

The Program is operated from the United States, and information is processed and stored in the United States and in other locations where our service providers operate. If you access the Program from outside the United States, you understand that your information will be transferred to and processed in the United States, where privacy laws may differ from those in your jurisdiction. Where required by applicable law, we rely on appropriate legal mechanisms for such transfers.

14. Third-Party Services and Links

The Program may link to or interoperate with third-party services, including app stores, payment processors, video or communication tools, and authentication providers. Those services are governed by their own privacy policies, and My Neuro is not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party service you use.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will provide notice through the Program, by email, or by another reasonable method before the changes take effect, and we will update the Last Updated date above. Your continued use of the Program after updated terms become effective means you accept the updated Privacy Policy. Where applicable law requires consent for a new use of previously collected information, we will obtain that consent.

16. Contact Us

Questions, requests, or complaints about this Privacy Policy or our privacy practices may be sent to:

My Neuro LLC

13475 Atlantic Blvd #8, Unit 1026

Jacksonville, Florida 32225

legal@myneurollc.com

https://myneurollc.com