1. Information We Collect

We collect information you provide directly to us, information collected automatically when you use the Services, and information received from third parties or connected integrations that you authorize.

1.1 Information You Provide

We may collect the following information that you provide directly to us:

• Account information, such as your name, email address, age, login credentials, and account preferences.

• Profile information, such as dietary preferences, allergies, goals, food preferences, activity preferences, and wellness interests.

• Health-related information, such as symptoms, medical history you choose to share, medications, lab values, care goals, biometric information, nutrition logs, and other health or wellness inputs you submit to personalize recommendations.

• Communications, such as messages you send to us, support requests, feedback, survey responses, and communications made through the Services.

• Payment information, such as billing details and subscription information collected through our payment processor; Neo Health does not store full payment card numbers directly unless explicitly stated otherwise.

1.2 Information We Collect Automatically

When you use the Services, we may automatically collect:

• Device information, such as IP address, browser type, operating system, mobile device identifiers, app version, language settings, and device type.

• Usage information, such as the pages or screens you view, links clicked, features used, searches, session duration, log data, crash data, and approximate timestamps of activity.

• Cookie and similar technology data, including information collected through cookies, pixels, software development kits, and similar technologies, subject to our cookie settings and any separate Cookie Policy.

1.3 Information From Third Parties and Connected Accounts

If you choose to connect third-party services, we may receive information from:

• Electronic health record systems, health information exchanges, or provider portals.

• Wearables and connected health devices, such as devices or apps that track steps, sleep, heart rate, activity, blood pressure, glucose, temperature, weight, or similar metrics.

• Platform providers and identity providers, such as Apple, Google, or other single sign-on providers.

• Service providers, business partners, or healthcare professionals involved in providing aspects of the Services.

You may choose whether to connect supported third-party accounts or devices. If you do not connect them, we will not receive that data from those sources.

2. How We Use Your Information

We may use your information to:

• Provide, operate, maintain, and improve the Services.

• Personalize health, nutrition, wellness, and grocery-related recommendations.

• Sync, import, organize, and display information from connected accounts, wearables, and EHR sources you authorize.

• Communicate with you, including responding to inquiries, providing support, sending service-related updates, and informing you about important policy or product changes.

• Monitor usage trends, troubleshoot problems, protect against fraud or misuse, and improve security.

• Develop, test, and improve product features, analytics, and models, including using de-identified or aggregated information where appropriate.

• Comply with legal obligations, resolve disputes, and enforce our Terms of Use.

We do not sell your personal information. We do not share your health information for unrelated third-party advertising purposes.

3. How We Share Your Information

We may share your information only as described below:

• Service providers, such as hosting providers, cloud infrastructure providers, analytics providers, customer support providers, payment processors, and security vendors that help us operate the Services.

• Healthcare providers or affiliated medical groups, when necessary to provide clinical, telehealth, care coordination, or health-related services that you request or authorize.

• EHR, wearable, device, or integration partners, when needed to connect, import, transmit, or sync data that you choose to link.

• Legal and compliance recipients, when required by law, subpoena, court order, regulatory request, or to protect rights, safety, and security.

• Corporate transaction recipients, such as in connection with a merger, financing, acquisition, reorganization, bankruptcy, or sale of assets.

• Other parties with your direction or consent.

We may also use and disclose de-identified or aggregated information that does not reasonably identify you, as permitted by law.

4. Connected Accounts, Wearables, and EHR Integrations

Neo Health may allow you to connect third-party services, including electronic health records, provider portals, Apple Health, Google Health Connect, wearables, fitness trackers, and other connected devices or applications. If you choose to connect these sources, you authorize Neo Health to access, receive, store, and use the information made available through those integrations in accordance with this Privacy Policy and any permissions you grant.

The availability, scope, frequency, and accuracy of imported data depend on the third-party source, your permissions, and the technical capabilities of the integration. We are not responsible for the privacy, security, availability, or accuracy of third-party platforms, and your use of those platforms remains subject to their own terms and privacy policies.

If you disconnect a linked account or wearable, Neo Health will stop collecting new data from that source on a forward-looking basis, but we may continue to retain previously collected information as described in this Privacy Policy unless deletion is required by law or approved under an applicable request process.

5. Your Rights and Choices

Depending on how you use Neo Health, where you live, and whether your information is maintained by or on behalf of a healthcare provider or other covered entity, you may have rights regarding your personal information or protected health information.

5.1 Access and Copies

You may request access to certain personal information or health information we maintain about you, subject to applicable law and verification requirements. If Neo Health maintains information on behalf of a healthcare provider or covered entity, some requests may need to be handled through that provider or entity.

5.2 Corrections and Updates

You may update certain account and profile information directly through your Neo Health account. You may also request correction or amendment of certain information, subject to applicable law and our verification procedures.

5.3 Connected Account Controls

You can choose whether to connect or disconnect supported EHR systems, wearables, and third-party accounts. You may also manage permissions through the applicable third-party platform where supported.

5.4 Communications Preferences

You may opt out of non-essential marketing communications by following the instructions in those messages. We may still send you transactional, service, legal, or security-related communications.

5.5 Confidential Communications and Restrictions

Where applicable, you may request confidential communications or ask us to limit certain uses or disclosures of health information. We are not required to agree to every request, but we will review requests in accordance with applicable law.

5.6 Complaints

If you believe your privacy rights have been violated, you may contact us using the information below. If HIPAA applies to your information, you may also have the right to file a complaint with the U.S. Department of Health and Human Services.

6. Data Retention

We retain personal information for as long as reasonably necessary to provide the Services, maintain your account, support connected integrations, comply with legal obligations, resolve disputes, enforce agreements, and protect the security and integrity of the Services.

Retention periods may vary depending on the type of data, the source of the data, whether the information is part of a health or clinical record, legal requirements, and whether you have requested deletion or account closure.

7. Security

We use reasonable administrative, technical, and physical safeguards designed to protect your information. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for safeguarding your account credentials and for using the Services through secure devices and networks.

8. International Data Transfers

If you access Neo Health from outside the United States, your information may be transferred to, stored in, and processed in the United States or other countries that may have data protection laws different from those in your jurisdiction.

9. Children’s Privacy

The Services are not intended for individuals under 18 years of age, and we do not knowingly collect personal information directly from children under 18 through the Services. If you believe a child has provided information to us unlawfully, please contact us so we can review and take appropriate action.

10. Updates to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will post the updated Privacy Policy and revise the “Effective Date” above. Your continued use of the Services after the updated Privacy Policy becomes effective constitutes your acknowledgment of the revised policy, to the extent permitted by law.

11. Contact Us

If you have questions, concerns, or requests related to this Privacy Policy or your information, please contact Neo Health at: [email protected].