Privacy Policy

This Privacy Policy explains how we collect, use, store, disclose and protect personal information when you use the Longevity Life Academy mobile application and related account, program, support and wellness services that link to this Privacy Policy (collectively, the "Services").

1. Information We Collect

The information we collect depends on the features you use and the information you choose to provide.

1.1 Account and Identity Information

We may collect:

• name;
• email address;
• age or date of birth;
• sex;
• account and authentication identifiers;
• Sign in with Apple or Google sign-in identifiers;
• communication preferences; and
• information you provide when contacting us.

The App uses email-based authentication and may use Apple or Google sign-in services.

1.2 Health and Wellness Data

The Services allow you to provide, and in some cases authorize us to receive, information relating to your health, fitness, lifestyle and wellbeing ("Health and Wellness Data").

This may include:

• age and sex;
• height and weight;
• sleep duration, stages, efficiency, latency and related sleep information;
• heart rate and resting heart rate;
• heart-rate variability (HRV);
• steps, workouts, active energy, active minutes and exercise information;
• VO₂ max;
• blood pressure;
• blood oxygen;
• respiratory rate;
• glucose and continuous glucose monitoring information;
• mindfulness activity;
• nutrition, meals and hydration;
• mood and stress information;
• supplements;
• health and wellness goals;
• symptoms or health concerns that you choose to provide;
• medical conditions or medical history that you choose to provide;
• medications;
• laboratory and blood-test results, including information such as fasting glucose, HbA1c and lipid results;
• sleep notes;
• completion of daily wellness practices; and
• other health or wellness information that you choose to enter into the Services.

Health and Wellness Data is sensitive information. We use it only for the purposes described in this Privacy Policy.

1.3 Apple Health Data

If you use the App on iOS and grant permission, the App may read information from Apple Health.

Depending on the information available in your Apple Health account and the permissions you grant, the App may read:

• Step Count
• Heart Rate
• Resting Heart Rate
• HRV (SDNN)
• Sleep Analysis
• Active Energy Burned
• Mindful Session
• Workout
• Blood Glucose
• Blood Pressure Systolic
• Blood Pressure Diastolic
• VO₂ Max
• Water
• Exercise Time
• Respiratory Rate
• Oxygen Saturation

The App may synchronize permitted Apple Health information in the background.

Height and weight are not read from Apple Health and are collected only when you provide them directly to LLA.

LLA does not use Apple Health information for advertising or marketing and does not sell or disclose Apple Health information to data brokers.

The LLA App does not use iCloud or CloudKit to store or synchronize the health information it collects. Your use of Apple Health itself remains subject to Apple's own services, settings and privacy practices.

You control which Apple Health information LLA may access through Apple's health and privacy permission settings and may revoke those permissions at any time.

1.4 Health Connect Data

If you use the App on Android and grant permission, the App may read information from Health Connect while the App is open.

Depending on the information available and the permissions you grant, LLA currently reads:

• steps;
• heart rate;
• resting heart rate;
• heart-rate variability (HRV);
• sleep information;
• active calories;
• exercise sessions; and
• mindfulness activity.

Height and weight are not read from Health Connect and are collected only when you provide them directly to LLA.

You can manage or revoke LLA's Health Connect permissions through Health Connect or the applicable Android privacy settings.

Revoking Apple Health or Health Connect permissions stops future access from that source but does not automatically delete information that LLA previously received. You may delete previously collected information by deleting your account or exercising your applicable privacy rights as described below.

1.5 Wearables and Connected Devices

LLA currently has no direct integration with manufacturers of smart watches, smart rings or other wearable devices.

However, a wearable or another application may independently write information to Apple Health or Health Connect. If you have authorized LLA to read the applicable information from Apple Health or Health Connect, information originally generated by such a device may therefore reach LLA indirectly through those platforms.

Where available, we may retain information identifying the source from which a health measurement was obtained.

1.6 Manually Entered Information

You may also enter information directly into the App, including health measurements, laboratory results, CGM averages, mood, stress, meals, hydration, supplements, sleep notes and completed wellness practices.

Information that you enter manually is treated as Health and Wellness Data under this Privacy Policy.

1.7 Longevity Scores and Derived Information

LLA uses Health and Wellness Data to calculate and maintain information such as:

• your Longevity Score;
• your Longevity Age;
• six individual wellness-pillar scores;
• trends and changes in relevant measurements;
• completion of daily practices; and
• personalized wellness information and recommendations.

The App may maintain a daily record or "snapshot" containing health measurements available for that day, manually entered information, the source of the information where available, calculated scores and completed practices.

Both underlying measurements and calculated or derived results may be stored on our systems.

1.8 Analytics and Technical Information

We use Google Firebase Analytics to understand how the App is used and to improve its operation.

Information sent to Firebase Analytics may include:

• Firebase app-instance identifier;
• LLA user identifier;
• App version;
• operating system;
• screen and usage events; and
• an age-group range, such as 40–49.

We do not send the user's exact age or health measurements to Firebase Analytics.

The App is designed so that Health and Wellness Data is excluded from analytics events through technical controls.

We do not currently use Firebase Crashlytics or another crash-reporting SDK in the App.

1.9 Push Notifications

If you enable notifications, we collect and process a device notification token so that we can send App notifications and reminders.

We use Expo's push-notification service to relay notification tokens.

Push notifications are designed not to contain your Longevity Score or individual health measurements. Notifications may, for example, tell you that you have practices remaining for the day, provide information about your activity streak, or provide a general reminder.

You can disable notifications through your device settings and, where available, through the App.

1.10 Communications With LLA

If you communicate with LLA, we may process the information contained in your communications and information necessary to respond to your request.

The App does not provide an instructor or administrative portal through which instructors can access your App health records.

You may nevertheless choose separately to share information with an LLA instructor or other LLA representative. For example, you may voluntarily share information derived from a glucose-monitoring device. Information that you voluntarily provide in that manner will be treated in accordance with this Privacy Policy.

2. Lingo Continuous Glucose Monitor

LLA may provide or resell access to the Lingo continuous glucose monitoring product operated by Abbott as part of an LLA program.

Lingo is a separate third-party product and service operated by Abbott or its applicable affiliates.

LLA does not currently have a technical integration with Lingo and does not automatically receive your continuous glucose readings from Abbott or the Lingo application.

Your use of Lingo, including information collected directly through the Lingo device or application, is subject to Abbott/Lingo's own terms and privacy practices.

You may choose to:

• manually enter information derived from Lingo into LLA; or
• voluntarily share Lingo-derived information with an LLA instructor or representative.

Once you provide that information to LLA, we treat it as Health and Wellness Data under this Privacy Policy.

3. How We Use Your Information

We use personal information as necessary to:

• create, authenticate and administer your account;
• provide the Services;
• obtain and process health information that you have authorized us to access;
• maintain your health and wellness history;
• calculate your Longevity Score, Longevity Age and wellness-pillar scores;
• personalize your educational and wellness experience;
• provide wellness insights, recommendations and daily practices;
• track your progress;
• communicate with you about the Services;
• send account-related and transactional communications;
• send reminders and notifications that you have enabled;
• enable data export and account-management features;
• troubleshoot, maintain and improve the App;
• measure use and performance of the App;
• maintain security and prevent fraud, abuse and unauthorized use;
• comply with applicable laws and legal obligations; and
• establish, exercise or defend legal rights.

We do not use Health and Wellness Data to determine eligibility for employment, insurance, credit or other similarly significant decisions.

4. Artificial Intelligence

If we introduce such functionality in the future, we will assess the applicable privacy requirements and update our disclosures and obtain consent where required before using Health and Wellness Data in that manner.

5. Health-Data Consent

Where required by applicable law, including where Health and Wellness Data constitutes special-category or similarly protected data, LLA processes such information based on your explicit consent.

Consent to LLA's processing of Health and Wellness Data is separate from the operating-system permissions through which Apple Health or Health Connect permits the App to access particular data types.

You may choose not to grant Apple Health or Health Connect permissions. You may also revoke those permissions later through your device settings.

Where we rely on your consent, you may withdraw it at any time by contacting us at Privacy@eteachergroup.com.

Withdrawal of consent does not affect processing that occurred lawfully before withdrawal. If you withdraw consent to processing necessary for a core health or wellness feature, we may be unable to continue providing that feature.

6. How We Disclose Personal Information

We disclose information only where reasonably necessary to provide and operate the Services, or as otherwise described below.

6.1 Service Providers

We use selected service providers to operate the App and Services.

Current providers include:

• Amazon Web Services (AWS) – application infrastructure, hosting and storage;
• Google Firebase Analytics – App analytics;
• SendGrid – transactional email delivery;
• Apple – Sign in with Apple and applicable operating-system functionality;
• Google – Google sign-in and applicable Android functionality; and
• Expo – push-notification token relay and delivery infrastructure.

These providers process information on our behalf or as otherwise necessary to provide their respective services.

We require service providers to process information for authorized purposes and subject to appropriate contractual and security obligations where required by law.

6.2 eTeacher Systems

The LLA App currently has no integration with eTeacher's CRM, and App information is not currently transferred to other eTeacher systems for sales or cross-brand marketing.

Health and Wellness Data is not used to market other eTeacher brands or services.

6.3 Advertising and Attribution

The App currently contains:

• no advertising SDK;
• no advertising network integration; and
• no marketing-attribution SDK.

We do not use Health and Wellness Data for behavioral advertising or advertising profiling.

6.4 Legal and Safety Requirements

We may disclose information where reasonably necessary to:

• comply with applicable law, regulation, court order or lawful governmental request;
• investigate fraud, misuse or security incidents;
• protect the rights, safety or property of LLA, eTeacher, our users or others; or
• establish, exercise or defend legal claims.

6.5 Corporate Transactions

Information may be transferred as part of a merger, financing, acquisition, restructuring, sale of assets or similar corporate transaction, subject to applicable law and appropriate protections for sensitive information.

7. Payments

The current LLA App does not contain an integrated payment processor.

If you purchase an LLA program, product or service outside the App, payment information may be processed through the applicable eTeacher sales or payment environment or a third-party payment provider.

Such payment processing may be governed by additional privacy notices presented in connection with the relevant transaction.

8. Data Retention and Deletion

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and as required or permitted by applicable law.

Active Accounts

Health and Wellness Data, daily snapshots, scores and account information may be retained while your account remains active so that we can provide the Services and maintain your wellness history.

Account Deletion

The App includes a Delete Account function in the Profile section.

Where personal information associated with your account is maintained by a service provider, we will cause deletion or de-identification to be completed within 30 days following the applicable account-deletion request, except where retention is legally required or permitted.

Residual copies contained in backups may remain for up to 90 days before being overwritten or deleted in accordance with our backup-management procedures.

Information that we are legally required to retain, or that is reasonably necessary to establish, exercise or defend legal claims, may be retained for the applicable required period and will not be used for other purposes.

Analytics

User-associated analytics information is retained only for legitimate App operation and improvement purposes and is subject to our configured analytics-retention practices.

Following account deletion, user-associated analytics information is subject to the deletion/de-identification process described above.

9. Data Export

The App provides a data-export function through the Profile section.

You may use this functionality to obtain a copy of information associated with your account, subject to security restrictions designed not to expose authentication secrets or other security-sensitive information.

You may also contact us at Privacy@eteachergroup.com to exercise applicable access or portability rights.

10. Security

Health and Wellness Data is sensitive, and we use technical and organizational measures designed to protect personal information against unauthorized access, acquisition, loss, misuse, alteration and disclosure.

These measures include protections relating to data transmission, system access, application architecture and service-provider security.

Access to underlying systems is limited to authorized personnel who require such access for legitimate operational, technical, security or legal purposes.

The App does not provide instructors, coaches or other users with administrative access to another user's health data.

No system can guarantee absolute security, and we cannot guarantee that unauthorized access, loss or misuse will never occur.

11. International Data Transfers

eTeacher Ltd. is based in Israel.

Personal information may be processed in Israel and in other countries in which our service providers operate or maintain infrastructure.

Israel is recognized by the European Commission as providing an adequate level of protection for personal data transferred from the European Economic Area.

Where applicable law requires additional safeguards for an international transfer, we use an appropriate legal transfer mechanism, which may include adequacy decisions, contractual safeguards or another legally recognized mechanism.

12. European Economic Area and United Kingdom

For users in the European Economic Area or United Kingdom, eTeacher Ltd. acts as the controller of personal data processed in connection with the Services.

Legal Bases

Depending on the processing activity, our legal bases may include:

• performance of a contract or steps taken at your request before entering a contract, for providing and administering the Services;
• explicit consent, for processing Health and Wellness Data where required under Article 9 of the GDPR;
• consent, where required for particular device access, communications, analytics or other processing;
• legitimate interests, such as maintaining, securing and improving the Services, where those interests are not overridden by your rights; and
• compliance with legal obligations.

Health information constitutes a special category of personal data under the GDPR. Where applicable, we rely on your explicit consent under Article 9(2)(a) for the processing of Health and Wellness Data, together with an applicable legal basis under Article 6.

Your Rights

Subject to applicable conditions and exceptions, you may have the right to:

• access personal information we hold about you;
• correct inaccurate or incomplete information;
• request deletion;
• restrict certain processing;
• object to certain processing;
• withdraw consent;
• receive certain information in a portable format; and
• lodge a complaint with an applicable supervisory authority.

You may exercise these rights by contacting Privacy@eteachergroup.com.

EU Representative

RF PRIVACY MINDERS LTD

33 Konstantinou Paleologou

The Square, 2nd Floor

CY-6036 Larnaca

P.O. Box 42364

CY-6533 Larnaca

Cyprus

Email: info@privacyminders.com

13. Israel

eTeacher Ltd. processes personal information in accordance with applicable Israeli privacy and data-protection law, including the Israeli Privacy Protection Law and regulations adopted under it.

Health information and other sensitive information may receive enhanced protection under applicable Israeli law.

Where Israeli law provides you with rights concerning information held about you, you may exercise those rights by contacting Privacy@eteachergroup.com.

14. United States Privacy Rights

Depending on your state of residence and the applicability of the relevant law, you may have rights relating to personal information or consumer health data.

These may include rights to:

• know or confirm whether we process your information;
• access information;
• correct inaccurate information;
• delete information;
• obtain a portable copy of information;
• obtain information regarding categories of recipients;
• withdraw consent to certain health-data processing; and
• appeal certain decisions relating to privacy-rights requests.

We do not sell Health and Wellness Data or other App personal information.

We do not use App information for cross-context behavioral advertising or targeted advertising.

To submit a request, contact Privacy@eteachergroup.com. We may take reasonable steps to verify your identity before completing a request.

Where applicable law gives you a right to appeal a decision concerning a privacy request, you may submit an appeal to the same address with the subject line "Privacy Request Appeal."

15. California Residents

If the California Consumer Privacy Act and related California privacy law applies to our processing of your information, you may have rights to request access to categories and specific pieces of personal information, correction and deletion, subject to applicable exceptions.

We do not sell personal information and do not share App personal information for cross-context behavioral advertising.

We will not discriminate against you for exercising an applicable privacy right.

16. Consumer Health Data

Where U.S. state consumer-health-data laws apply, Health and Wellness Data may constitute "consumer health data" or similarly protected information.

Depending on applicable law, this may include information concerning:

• physical or mental health status;
• bodily functions and vital measurements;
• sleep;
• exercise;
• nutrition;
• medications and supplements;
• laboratory results;
• symptoms and conditions;
• glucose and metabolic information;
• health or wellness interventions;
• information received from health and fitness platforms; and
• health-related inferences or scores derived from such information.

We primarily collect such information:

• directly from you;
• from Apple Health where you authorize access;
• from Health Connect where you authorize access; and
• indirectly from a wearable or other service where that service first writes information to Apple Health or Health Connect and you have authorized LLA to access the applicable category.

We use this information to provide the health, wellness, scoring, personalization and educational features that you request.

We do not sell consumer health data.

We disclose consumer health data only to service providers or other recipients as necessary to provide the Services, comply with law, protect rights and security, or where you direct or authorize the disclosure.

Where applicable law requires consent for the collection or sharing of consumer health data, we will obtain the required consent.

17. Children

The Services are intended only for individuals who are 18 years of age or older.

Age eligibility is enforced during onboarding and through server-side controls.

We do not knowingly provide the App to or collect personal information through the App from anyone under 18.

If we learn that information has been collected from a person under 18 in violation of this requirement, we will take appropriate steps to delete it.

18. Your Choices

You can control your information in several ways:

• Apple Health: Manage or revoke permissions through Apple Health or iOS health/privacy settings.
• Health Connect: Manage or revoke permissions through Health Connect or Android settings.
• Push notifications: Disable notifications through your device settings.
• Data export: Export account information through Profile.
• Account deletion: Select Delete Account in Profile.
• Health-data consent: Contact us to withdraw consent where we rely on consent for processing.
• Privacy requests: Contact Privacy@eteachergroup.com.

Please note that revoking a platform permission prevents future access from that platform but does not itself delete information already received by LLA.

19. Third-Party Services and Links

The Services may refer or link to products, websites, applications or services operated by third parties, including Lingo/Abbott and Apple or Google services.

Those third parties operate independently and may process information under their own privacy policies and terms.

This Privacy Policy does not govern information collected directly by an independent third party unless that information is subsequently provided to LLA.

20. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to the Services, technology, our business practices or applicable legal requirements.

When we make changes, we will update the "Last Updated" date.

If a change materially affects how we collect or use Health and Wellness Data, we will provide additional notice or obtain consent where required before applying the new practice.

21. Contact Us