Notice at Collection

Last Updated: April 27, 2026

This Notice at Collection describes the personal information that Welltory Inc. ("Welltory," "we," "us," or "our") collects from you at or before the time of collection. This notice is provided to comply with the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), and applies to California residents. This Notice is made available to other users for transparency purposes only, unless otherwise required by applicable law.

For comprehensive information about our privacy practices, please review our full Privacy Policy and Cookie Policy.

1. Categories of Personal Information We Collect

We collect the following categories of personal information. For more detailed information about the specific types of data within each category, please see our Privacy Policy:

• Identifiers and Contact Information: such as name, email address, username, user ID, and authentication credentials
• Health and Wellness Information (Sensitive Personal Information): including vital signs, physical metrics, activity data, sleep patterns, wellness tracking, nutrition data, women's health data, and related health information
• Device and Technical Information: such as device identifiers, IP address, device characteristics, operating system details, and network data
• Usage and Interaction Data: including app usage analytics, user interactions with features, and AI feature interactions
• Commercial Information: such as subscription details, in-app purchases, and transaction information
• Internet Activity: including browsing behavior and interaction data collected through cookies and similar technologies on our website (see our Cookie Policy)

2. Purposes for Collection and Use

We collect and use the categories of personal information described in Section 1 for the purposes described below.

Category of Personal Information	Purposes of Collection and Use
Identifiers and Contact Information	Account creation and management; authentication; customer support; service communications; security and fraud prevention; legal and regulatory compliance
Health and Wellness Information (Sensitive Personal Information)	Providing and personalizing health and wellness tracking Services; generating insights and recommendations; internal research and analytics; service quality assurance; security; legal compliance
Device and Technical Information	Service functionality; security and fraud prevention; troubleshooting; performance monitoring; analytics; service improvement
Usage and Interaction Data	Analyzing feature usage; improving user experience; developing and testing new features (including AI-powered features); research and analytics
Commercial Information	Subscription and payment processing; billing and invoicing; customer support; accounting; legal and tax compliance
Internet Activity Information	Website and app functionality; analytics; security; performance optimization, as described in our Cookie Policy

Sensitive Personal Information is collected and used only for purposes permitted under the CCPA/CPRA, including providing our Services, ensuring security and integrity, preventing fraud, complying with legal obligations, and performing internal research and analytics.

3. Sale and Sharing of Personal Information

We do not sell personal information, including sensitive personal information (health and wellness data) for monetary or other valuable consideration.

We do not share health or wellness data for advertising purposes. However, we disclose certain personal information — such as online identifiers, device information, and internet activity data — to advertising partners, including Meta Platforms, Inc. (via Meta Pixel, Facebook Lookalike Audience, Facebook Custom Audience, and Facebook Remarketing) and Google LLC (via Google Ads and Google Ad Manager), for purposes that may constitute "sharing" for cross-context behavioral advertising under the CCPA/CPRA, namely: conversion tracking, ad campaign optimization, and building audience segments.

You have the right to opt out of the sharing of your personal information and the processing of your personal information for targeted advertising. To exercise this right, you may: (1) click the "Your Privacy Choices" link in our website footer or the green padlock icon (powered by iubenda) and toggle off "Sharing of my personal information" and/or "Processing of my personal information for targeted advertising"; (2) use a browser or extension with Global Privacy Control (GPC) enabled — we honor GPC signals automatically; or (3) contact us at [email protected].

We disclose personal information to service providers and processors who perform services on our behalf only to the extent necessary to provide such services, subject to contractual restrictions that prohibit them from retaining, using, or disclosing personal information for any purpose other than providing services to Welltory, or as otherwise permitted by law and described in our Privacy Policy. Such disclosures do not constitute "sharing" under the CCPA/CPRA.

4. How Long We Keep Your Information

We retain personal information for as long as reasonably necessary and proportionate to achieve the purposes for which it was collected, including while your account is active, to provide our Services, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, and maintain business records.

Retention periods vary depending on the category of personal information, the nature of the data, and applicable legal requirements. Additional details about our data retention practices are provided in our Privacy Policy.

When you delete your account, we permanently delete or anonymize your personal and health data, except where retention is required or permitted by law.

5. Your Data Protection Rights

This section describes the rights available to California residents under the CCPA, as amended by the CPRA.

• Right to Know: You have the right to request information about our collection and use of your personal information, including the categories and specific pieces of personal information collected, the sources of that information, the purposes of use, the categories of third parties with whom it is disclosed, and whether such information is sold or shared. You may make up to two requests per 12-month period, free of charge.
• Right to Delete: You may request that we delete personal information we have collected from you and direct our service providers to do the same, subject to certain legal exceptions.
• Right to Correct: You may request that we correct inaccurate personal information we maintain about you.
• Right to Opt-Out of Sale or Sharing: You have the right to opt out of the sale or sharing of your personal information. We do not sell your personal information for monetary consideration. For details on what sharing occurs and how to exercise your opt-out right, see Section 3 above.
• Right to Limit Use of Sensitive Personal Information: You may direct us to limit the use and disclosure of your sensitive personal information to purposes permitted under the CCPA/CPRA, such as providing the Services, ensuring security, and complying with legal obligations. Limiting the use of certain sensitive personal information may affect our ability to provide core features of the Services.
• Right to Non-Discrimination: You will not face different pricing, service levels, or quality for exercising your rights.

Additional privacy rights, including U.S. state-specific privacy rights, may apply depending on your jurisdiction and are described in our Privacy Policy.

6. How to Exercise Your Rights

To exercise your privacy rights, please contact us at:

• Email: [email protected]
• Data Protection Officer: [email protected]

We will respond to your verified request within the timeframe specified in our Privacy Policy. You may designate an authorized agent to make a request on your behalf by providing written authorization.

7. Updates to This Notice

We may update this Notice at Collection from time to time to reflect changes in our practices or applicable laws. We will post the updated Notice on our website and indicate the date of the last update. We encourage you to review this Notice periodically.

8. Contact Us