Privacy Policy

PLEASE READ THIS PRIVACY POLICY OF ALURX INC., A DELAWARE CORPORATION (“ALURA”) CAREFULLY.

BY CREATING AN ACCOUNT WITH ALURA, SUBSCRIBING TO THE SERVICES, CLICKING TO INDICATE YOUR ACCEPTANCE OF THE TERMS AND CONDITIONS OF USE AND THIS PRIVACY POLICY, OR OTHERWISE ACCESSING OR USING THE SERVICES, YOU expressly consent to ALURA's collection, use, storage, processing, de-identification, pseudonymization, transmission of information through cloud service providers, disclosure of information to third-party artificial intelligence service providers as described herein, receipt of AI-generated outputs, and return of such outputs to you through the Alura Platform.

ALURA is intended solely for general wellness purposes and is not intended to be a medical device, clinical decision-support tool, or diagnostic product. ALURA is not intended for use in diagnosing, curing, mitigating, treating, or preventing any disease or medical condition.

Information submitted is not subject to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and will not receive the privacy protections afforded to protected health information under HIPAA. Do not submit information that you consider protected health information if you require HIPAA protections. If you have a medical question or need medical care, please contact a qualified healthcare provider.

The Services are intended for users located in the United States and are designed to operate under United States laws and regulations. ALURA makes no representation that the Services are appropriate or lawful for use in other jurisdictions.

1. Use of Artificial Intelligence Services

To provide personalized wellness insights, educational content, and wellness-related recommendations, ALURA submits the health, wellness, lifestyle, and related information that you provide through the Platform to carefully selected third-party artificial intelligence ("AI") and machine-learning service providers that assist ALURA in generating and delivering such content.

Information transmitted to AI service providers is protected through industry-standard encryption and security safeguards designed to protect the confidentiality and integrity of the information. Security measures may include encryption in transit, encryption at rest where available, authentication controls, access restrictions, logging, monitoring, and administrative safeguards designed to protect information from unauthorized access, use, or disclosure.

By using the Platform, you expressly consent to the processing, transmission, and analysis of your information in the manner described herein for the purpose of generating wellness-related insights, recommendations, and educational content. ALURA reserves the right to utilize, replace, or modify its third-party AI service providers from time to time, provided that such providers are subject to privacy and security obligations reasonably designed to protect user information.

AI-generated outputs may be inaccurate, incomplete, outdated, inappropriate, or unsuitable for a particular individual's circumstances and should not be relied upon as medical, psychological, therapeutic, legal, financial, employment, or professional advice.

2. Third-Party AI Service Providers

ALURA currently utilizes the following third-party artificial intelligence service providers to process user inputs and generate AI-powered content, recommendations, educational materials, search results, and wellness-related insights.

a. Google Vertex AI (Gemini)

Certain AI functionality made available through the Platform is provided through Google Gemini operating within ALURA's Google Cloud environment. Information submitted by users may be processed through Google Cloud Platform and Vertex AI solely for purposes of providing the Services. Google's processing of such information is governed by its enterprise cloud agreements, including the Google Cloud Service Specific Terms and the Google Cloud Data Processing Addendum, each as amended from time to time.

Additional information is available at:

• https://cloud.google.com/terms/service-terms
• https://cloud.google.com/terms/data-processing-addendum

Based upon Google's enterprise cloud commitments applicable to ALURA's implementation, Customer Data processed through Vertex AI is not used by Google to train or improve Google's foundation models except as otherwise permitted under Google's enterprise agreements or applicable law.

b. Perplexity Sonar API

Certain search, research, retrieval, and generative AI functionality offered through the Platform is provided through the Perplexity Sonar API.

Information submitted by users may be transmitted to Perplexity for processing and generation of responses. Perplexity's processing is governed by its enterprise API terms and related privacy commitments applicable to commercial API customers.

Additional information is available at:

• https://www.perplexity.ai/hub/legal/perplexity-api-terms-of-service

ALURA understands that the Perplexity Sonar API operates with limited or zero-retention processing of prompts and generated responses, subject to operational, security, legal, compliance, and billing requirements maintained by Perplexity.

3. Consent to Processing by AI Providers

By using AI-powered features of the Platform, you expressly authorize ALURA to transmit, process, store, and analyze User Inputs through Google Vertex AI, Perplexity Sonar API, and any successor or replacement service providers selected by ALURA to provide substantially similar functionality. You acknowledge that information transmitted to such providers may be subject to those providers' applicable terms, privacy commitments, security practices, retention practices, legal obligations, and operational requirements. ALURA does not control and is not responsible for subsequent modifications to the terms, privacy practices, security programs, retention policies, or service offerings of independent third-party providers.

4. No Direct Contractual Relationship

Reference to Google, Perplexity, or any other third-party service provider in this Privacy Policy is provided solely to inform users regarding the processing of information through the Platform. Your contract is with ALURA, not with such providers, and nothing in this Privacy Policy creates a direct contractual relationship between users and any third-party AI provider.

5. Cloud Hosting and Processing Services

ALURA utilizes reputable cloud infrastructure providers, including Google Cloud Platform, to store, process, secure, and transmit information necessary to operate the Platform and provide services to users. ALURA utilizes cloud providers whose terms, policies, and security practices are designed to protect the confidentiality and security of information stored and processed on ALURA's behalf and to restrict the unauthorized disclosure of such information to third parties. Prior to transmitting information to third-party AI service providers outside the cloud environment, ALURA processes user information within the cloud environment and employs measures designed to remove, segregate, or replace direct personal identifiers with a unique pseudonymous user identifier. Information may be processed or stored in jurisdictions different from the jurisdiction in which you reside.

6. Information We Collect

ALURA collects information that you provide directly to us, information generated through your use of the Platform, and information collected automatically through your device or browser. Depending on how you use the Services, the categories of information collected may include:

• Account Information, such as your name, email address, login credentials, and subscription information;
• Health and Wellness Information, including information relating to sleep, nutrition, physical activity, stress, resilience, habits, wellness goals, biometric information voluntarily provided by you, and other health-related information submitted through the Platform;
• Payment Information, such as billing information and payment transaction details processed by payment service providers;
• Device and Technical Information, including device identifiers, browser type, operating system, IP address, mobile device information, and application usage data;
• Communications, including communications with customer support and responses to surveys, questionnaires, or feedback requests; and
• Analytics Information, including information regarding how you access and use the Platform.

7. How We Use Information

ALURA may use information collected through the Services for the following purposes:

• To provide, maintain, operate, and improve the Platform and Services;
• To generate wellness insights, educational content, recommendations, and AI-responses;
• To develop, train, improve, test, validate, and enhance ALURA's services, algorithms, artificial intelligence systems, and related technologies.
• To personalize your user experience;
• To manage subscriptions, billing, and customer accounts;
• To communicate with you regarding the Services;
• To respond to customer support inquiries;
• To maintain the security, integrity, and functionality of the Platform;
• To detect, investigate, and prevent fraud, misuse, and security incidents;
• To conduct analytics, research, product development, and quality improvement activities;
• To comply with legal obligations; and
• For any other purpose disclosed at the time information is collected or as otherwise permitted by applicable law.

8. Disclosure of Information

ALURA does not sell the personal information provided and does not share personal information for cross-context behavioral advertising as defined under California law. ALURA may disclose the information provided to the following categories of recipients:

• Cloud hosting and infrastructure providers;
• Artificial intelligence and machine-learning service providers;
• Payment processors and billing providers;
• Analytics and technology service providers;
• Customer support and communications providers;
• Professional advisors, auditors, and legal counsel;
• Government authorities, law enforcement agencies, regulators, or courts when required by law; and
• Successors, purchasers, or other parties involved in a merger, acquisition, financing, restructuring, sale of assets, or similar corporate transaction.

ALURA may also disclose information when ALURA reasonably believes such disclosure is necessary to protect the rights, safety, property, or legal interests of ALURA, its users, or others.

9. Employer-Sponsored Wellness Programs

If your access to the Services is sponsored, subsidized, or made available through your employer or another organization, ALURA may provide that organization with aggregated, de-identified, or anonymized information regarding participation, utilization, engagement, and wellness program performance. ALURA does not disclose individually identifiable health or wellness information to sponsoring organizations except as described in this Privacy Policy, authorized by the user, required by law, or expressly described in applicable program materials.

10. Children’s Information

The Services are not intended for individuals under eighteen (18) years of age. ALURA does not knowingly collect personal information from individuals under eighteen (18). If ALURA becomes aware that it has collected personal information from an individual under eighteen (18), ALURA will take reasonable steps to delete such information as permitted by applicable law.

11. Cookies and Similar Technologies

ALURA and its service providers may use cookies, software development kits (SDKs), pixels, log files, analytics tools, and similar technologies to operate the Platform, understand user activity, improve the Services, personalize content, and maintain security. You may be able to control certain cookie settings through your browser or device settings; however, disabling certain technologies may affect functionality of the Services.

12. Deletion of Account

ALURA may delete, de-identify, anonymize, or retain information in accordance with this Privacy Policy and applicable law. Upon a verified request to delete an account, ALURA will use commercially reasonable efforts to delete or de-identify personal information maintained within ALURA's systems and under ALURA's control, subject to applicable legal, regulatory, security, fraud-prevention, dispute-resolution, and business record-retention requirements.

ALURA utilizes third-party cloud hosting providers and third-party artificial intelligence service providers to assist in providing the Services. Where information has been transmitted to such providers, ALURA will take commercially reasonable steps to request deletion of information when required or appropriate under applicable law and contractual arrangements. However, ALURA cannot guarantee the deletion of information from the systems, backups, logs, archives, training datasets, security records, or internal retention systems of independent third-party service providers.

By using the Services, you acknowledge that although ALURA will seek to honor valid deletion requests for information within its possession or control, ALURA cannot guarantee that all information previously disclosed to independent third-party providers can be permanently deleted from every location, backup system, archive, or internal record maintained by such providers. Information previously processed by third-party AI service providers may remain subject to those providers' independent retention, deletion, backup, archival, security, and recordkeeping practices.

13. Retention of Information

ALURA retains personal information only for as long as reasonably necessary to provide the Services, fulfill the purposes described in this Privacy Policy, comply with legal and regulatory obligations, resolve disputes, enforce agreements, and protect ALURA's legitimate business interests. Retention periods may vary depending upon the nature of the information, applicable legal requirements, and operational needs. Information that has been de-identified, anonymized, aggregated, or stripped of direct personal identifiers may be retained for longer periods as permitted by applicable law.

14. Your Privacy Rights

Subject to applicable law, you may have the right to request access to, correction of, deletion of, or information concerning certain personal information maintained by ALURA. ALURA may require verification of identity before responding to such requests. Residents of certain states may have additional privacy rights under applicable law. ALURA will process and respond to privacy requests in accordance with applicable state privacy laws to the extent such laws apply to ALURA.

15. State Privacy Rights

Residents of certain states may have specific privacy rights under applicable law. Depending on your state of residence and subject to applicable legal limitations and exceptions, you may have the following rights regarding your personal information:

• The right to confirm whether ALURA processes your personal information;
• The right to access personal information maintained by ALURA;
• The right to correct inaccuracies in your personal information;
• The right to request deletion of personal information;
• The right to obtain a copy of certain personal information in a portable and readily usable format;
• The right to opt out of certain processing activities, including targeted advertising, profiling in furtherance of decisions that produce legal or similarly significant effects concerning you, and the sale of personal information where applicable;
• The right to withdraw consent where processing is based upon your consent; and
• The right not to be discriminated against for exercising privacy rights provided by applicable law.

To exercise any privacy rights available to you, you may submit a request by emailing support@alurx.com. ALURA may take reasonable steps to verify your identity before responding to your request and may request additional information necessary to verify your identity and authority to make the request.

ALURA will respond to verified privacy requests within the time periods required by applicable law. Certain requests may be denied as permitted by law, including where information must be retained to comply with legal obligations, resolve disputes, protect security, prevent fraud, or enforce agreements. Where permitted by applicable law, you may designate an authorized agent to submit privacy requests on your behalf. ALURA may require the authorized agent to provide written proof of authorization and may require verification of your identity before processing the request.

16. Additional Privacy Rights

ALURA does not sell personal information and does not share personal information for cross-context behavioral advertising as those terms are defined under California law.

ALURA may collect and process sensitive personal information, including wellness information, health-related information voluntarily provided by users, account credentials, biometric information voluntarily submitted by users, and other information described in this Privacy Policy. ALURA uses such information only for purposes reasonably necessary to provide the Services, maintain security, improve platform functionality, comply with legal obligations, and otherwise as described in this Privacy Policy.

California residents may request access to, correction of, deletion of, and information regarding the categories of personal information collected, disclosed, and processed by ALURA. California residents also have the right to limit certain uses of sensitive personal information where required by law and the right not to receive discriminatory treatment for exercising their privacy rights.

17. Changes to the Privacy Policy

ALURA may update this Privacy Policy from time to time. If ALURA makes material changes, ALURA will provide notice through the Platform, by email, or through other reasonable means. The revised Privacy Policy will become effective on the date stated in the updated Privacy Policy. Continued use of the Services after the effective date constitutes acknowledgment of the revised Privacy Policy.

18. Privacy Questions

If you have questions regarding this Privacy Policy, your personal information, or ALURA's privacy practices, please contact:

• ALURA Privacy Office: Email: support@alurx.com
• General Support: Email: customerservice@alurx.com

Note: Alura Terms and Conditions of Use and Privacy Policy can be found at www.alurx.com