Privacy Policy

Version 1.0 — Effective Date: August 18, 2026

Proactive Insight Health Platform™, LLC ("Company," "we," "us") operates the Proactive Insight Health Platform™ (the "Platform"). This Privacy Policy describes how we collect, use, and share information in connection with the Platform. This Policy should be read together with our Terms of Service and Wellness Platform Acknowledgment and Consent.

1. Who We Are and How Information Flows

Company is a technology and management company. We are not a medical provider. Certain information you submit through the Platform, including health information, is reviewed by your assigned clinician, a licensed clinician associated with our independent clinical partner, Victory Health, LLC ("Medical Group"). Where information you provide constitutes protected health information ("PHI") under the Health Insurance Portability and Accountability Act ("HIPAA"), Company acts as a business associate of Medical Group pursuant to a Business Associate Agreement, and handles that information only as permitted by HIPAA and as directed by Medical Group.

2. Information We Collect

• Account information: name, email, date of birth, sex, contact information, and login credentials.
• Health profile information: height, weight, smoking status, and other information you provide during onboarding.
• Assessment responses: including PHQ-9 mental health screening responses, musculoskeletal assessment results, cognitive check responses, and lifestyle questionnaire responses.
• Laboratory results: results from laboratory panels ordered through Fullscript or uploaded by you from an outside provider.
• Clinician-generated information: result bands (Low/Moderate/Elevated) and consumer-facing notes created by your assigned clinician.
• Payment information: subscription and billing information is collected and processed by our payment processor, Stripe. Company does not store your full payment card number.
• Usage information: information about how you use the Platform, such as pages visited and actions taken, for security and product-improvement purposes.

3. How We Use Information

• To provide, operate, and maintain the Platform, including routing your information to your assigned clinician and displaying results and wellness guidance to you.
• To process subscription payments and manage your account.
• To communicate with you about your account, results, and Platform updates, including via email.
• To maintain an audit log of activity on the Platform for security, compliance, and recordkeeping purposes.
• To comply with applicable law, respond to legal process, and enforce our Terms of Service.
• In de-identified or aggregate form, to improve and develop the Platform. De-identified information does not identify you and is not treated as PHI.

We do not sell your personal information.

4. How We Share Information

• Medical Group and your assigned clinician, for purposes of clinical review as described in this Policy and our Consent.
• Service providers who help us operate the Platform, including our hosting and application platform provider (Blaze Technology, Inc., under a signed Business Associate Agreement), our email delivery provider (SendGrid, which does not receive PHI), and our payment processor (Stripe).
• Fullscript, for purposes of laboratory test ordering, dispensing, and fulfillment, and supplement recommendations you choose to purchase.
• As required by law, regulation, subpoena, or other legal process, or to protect the rights, property, or safety of Company, our users, or others.
• In connection with a merger, acquisition, financing, or sale of assets, subject to applicable confidentiality obligations.

We do not share your information with third parties for their own marketing purposes.

5. Data Security

We maintain administrative, technical, and physical safeguards designed to protect your information. Our platform infrastructure is provided by Blaze Technology, Inc., which maintains HITRUST e1 and SOC 2 Type II certifications. Access to your information is role-based and limited to personnel and systems that need it to provide the Platform, and access to clinical information is logged in an audit trail.

6. What Happens to Your Information When You Cancel or Your Subscription Ends

If you use the Platform and later cancel, or your subscription otherwise ends, here is explicitly what happens:

Platform Access

Once your subscription ends, your access to the Platform dashboard — including the ability to view historical results, log new assessments, or order additional labs — ends at the close of your final billing period. You may request a copy of your information at any time, including after cancellation, as described in Section 7.

Your Information Is Not Deleted Simply Because You Cancel

• Clinical information reviewed by your assigned clinician — including your laboratory results, assessment responses, and clinician notes — is maintained within the Platform and made available to Medical Group for its clinical review and recordkeeping. Consistent with the automated, template-based, structured design of this clinical review process, Medical Group does not maintain a separate patient chart outside the Platform; the Platform's own clinician notes and audit log serve as the record. This information is retained regardless of whether you remain a subscriber and is not deleted merely because your subscription ends.
• Platform account information (such as your login and billing history) is retained by Company for seven (7) years after cancellation, primarily for legal, accounting, and security recordkeeping purposes.

Who the Information Belongs To

Your information is not "owned" by Company to use however it wishes. Clinical information is maintained within the Platform and made available to Medical Group as the record of your asynchronous clinical review — there is no separate, traditional patient chart created outside the Platform. That information is subject to HIPAA, and you retain the rights HIPAA gives you with respect to it — including the right to request access to it or a copy of it — whether or not you remain a subscriber. Platform account and usage information is maintained by Company as described in this Policy.

Requesting Your Information or Its Deletion

You may request a copy of your information, or request that certain information be deleted, at any time, including after you cancel, by contacting us as described in Section 11. We will honor deletion requests to the extent permitted by law; however, Company and Medical Group may be legally required to retain certain clinical records for a period of time even after a deletion request, and we will tell you if that applies to your request.

If You Resubscribe

If you cancel and later resubscribe, your prior information, to the extent still retained, may be reconnected to your account so your clinician has the benefit of your prior history, consistent with this Policy.

7. Your Choices and Rights

• You may update certain account and health profile information directly in the Platform.
• You may cancel your subscription at any time through the Stripe billing portal accessible from your account.
• You may request access to, or correction of, your information by contacting us as described below. Requests concerning clinical records reviewed by the Medical Group may be directed to, or coordinated with, Medical Group, consistent with HIPAA.
• You may opt out of non-essential email communications; we may still send you essential account, billing, and safety-related communications.

8. Children's Privacy

The Platform is intended for use by adults age 18 and older. We do not knowingly collect information from anyone under 18. If you believe a minor has provided us information, please contact us so we can address it.

9. Cookies and Website Analytics

We do not currently use cookies or tracking analytics on our marketing pages. If this changes, we will update this Privacy Policy to describe what is used and, consistent with our consent management practices, notify you of the change.

10. Changes to This Policy

We may update this Privacy Policy from time to time. If we make a material change, we will notify you and, consistent with our consent management practices, may require you to review and accept the updated Policy before continuing to use certain features of the Platform.

11. Contact Us

If you have questions about this Privacy Policy or wish to exercise any of the rights described above, contact us at: info@proactiveinsight.health.

Subscriber acceptance of this Privacy Policy is captured electronically, together with the version number and timestamp of this Policy, in Company's consent management system.