Privacy Policy

1. Who we are

We are Aion Longevity Ltd, incorporated and registered in England and Wales under company number 15911609 with registered office at 20 Wenlock Road, London, England, N1 7GU (“we”, “our”, “AION”) and which terms shall also include our Affiliates. “Affiliates” means any entity that directly or indirectly controls, is controlled by, or is under common control with us. “Control” for purposes of this definition, means direct or indirect ownership or control of more than 50% of the voting interests of the subject entity). We are a wellness membership platform. This privacy and cookies policy (the “Policy”) refers to the website https://www.aionlongevity.com and to our applications, whichever of them you use: the Aion app at https://app.aionlongevity.com, and our iOS and Android apps (together, the “Website”).

Your privacy is of paramount importance to us. This Policy applies to the Website and the services related thereto (the “Service”). This Policy is designed to protect you, our users, by informing you what personal data is collected, how we will use the information about you, with whom we share it, how long we keep it and how to contact us if you have any queries or concerns about our use of your personal information. Your use of the Website is subject to your agreement with this Policy.

In this Policy, the term “Personal Data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes personal data as described in Data Protection Legislation (as defined below).

Please read the following carefully. Registering for an account (“Your Account”) on our Website, use of Your Account or otherwise accepting the terms of this Policy indicates that you have reviewed this Policy and have agreed to be bound by it. If you do not agree to these terms you must leave the Website immediately. We will keep a record of your consent in this regard. If you no longer consent to our processing of your personal data, you may request that we cease such processing by contacting us via the ‘How to contact us’ facility referred to below.

We will handle your Personal Data in accordance with Data Protection Legislation. "Data Protection Legislation" refers to the UK Data Protection Act 2018, the UK General Data Protection Regulation (UK GDPR), and any other applicable law or regulation relating to the processing of Personal Data and to privacy, including the Privacy and Electronic Communications (EC Directive) Regulations 2003, as such legislation may be supplemented, amended, revised or replaced from time to time.

We are a controller (as defined in Data Protection Legislation) in relation to any Personal Data which we collect from you through your or any other user's use of the Service and the setup of your Account. This Policy sets out the basis on which any such Personal Data will be processed by us. You may be a data subject (as defined in Data Protection Legislation) or you may be a controller. When you are a controller in respect of the Personal Data of other data subjects, then you must comply with all your controller obligations under Data Protection Legislation. When you are a controller, we and you act as independent controllers, unless agreed otherwise.

2. Information we gather from you

We fully respect your right to privacy in relation to your interactions with the Service and endeavour to be transparent in our dealings with you as to what information we will collect and how we will use your information. Also, we only collect and use an individual’s information where we are legally entitled to do so. Information in relation to Personal Data collected by UK entities is available on www.ico.org.uk, the website of the UK Information Commissioner's Office (ICO)

[We may collect and process the following data about you that may, in certain circumstances, constitute personal data and/or sensitive personal data:

• first and last name (including prefix or title);
• e-mail address;
• password;
• phone number(s);
• postal address;
• date of birth;
• gender;
• bank account or credit card details for payment processing purposes;
• information you put into apps, forms or surveys on our Website at any time (including sensitive personal wellness data);
• a record of any correspondence between us;
• details of transactions you carry out through our Website;
• details of your visits to our Website and the resources you use;
• technical information, such as information from your visits to our Website or applications (including internet protocol (IP) address and login data, browser or client application information, language preference, operating system and application version, device type and ID, and device model and manufacturer, and other technology on the devices you use to access the Website or applications) or in relation to materials and communications we send to you electronically for system administration and to report aggregate information to our advertisers; and any other information relating to you which you may provide to us.

Any Personal Data that we collect from you for the purposes described in this Policy is hereinafter referred to together as “Your Data”.

We endeavour to keep Your Data accurate and up-to-date. As such, you must tell us about any changes to such information that you are aware of as soon as possible. You can change your stated interests in respect of whether or not you wish to receive direct marketing from us by clicking ‘unsubscribe’ on any direct marketing electronic communication which you receive from us.

If you are aged under 18, please get your parent/guardian’s permission before you provide Your Data to us/use the Service.

3. Why we collect/have access to your information

We may collect information from you as necessary in the course of providing our Service. We may collect your personal information while monitoring our technology tools and services, including our Website, and email communications sent to and from us. We gather information about you when you provide it to us, or interact with us directly.

We may use your Personal Data on any one or more of the following legal bases: (i) to perform a contract with you; (ii) for our legitimate business purposes in providing the Service to you (in which case, our legitimate interests will not override your fundamental privacy rights); and/or (iii) in limited circumstances, where you have given us your express consent.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

Note that we may process your Personal Data for more than one legal basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your Personal Data where more than one ground has been set out in the table below.

Where we wish to use Your Data in any other way, we will ensure that we notify you and get your consent first. You will be given the opportunity to withhold or withdraw your consent for the use of Your Data for purposes other than those listed in this Policy.

4. Cookies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a better experience when you browse our Website and also allows us to improve the Website. They also help us to improve our Service and to deliver many of the functions that make your browser experience more user-friendly. A cookie is a small text file that is placed on your device by a web server that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following types of cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.
• Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or location) and remember if we have already asked you for feedback or to complete a survey.

We do not use analytics, advertising or targeting cookies, and we do not share cookie data with advertising networks. The Website links to third-party sites and social platforms, including Instagram and LinkedIn, and loads fonts and icon files from third-party content delivery networks. Those third parties have their own cookies and privacy practices, which are controlled by them and over which we have no control.

The ‘Help Menu’ on the menu bar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether. You can also disable or delete similar data used by browser add-ons, such as flash cookies, by changing the add-on’s settings or visiting the website of its manufacturer.

For more information about cookies and managing them including how to turn them off, please visit www.cookiecentral.com. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. If you use your browser settings to block all cookies (including essential cookies), you may not be able to fully experience the interactive features of our Website.

5. Are there cases where we may use your information to contact you

We may contact you:

• for administration reasons related to the Service (e.g. to provide you with password reminders or to notify you that a particular service, activity or online content has been suspended for maintenance, or in response to a question that you ask us;
• to provide you with information about our Service, activities or online content, including sending e-newsletters or similar correspondence and updates or responding to any contact you have made with us (e.g. on our Website, by email or via the ‘How To Contact Us’ facility referred to in Section 15 below);
• to invite you to participate in surveys about our services (participation is always voluntary).
• for direct marketing purposes.

6. What rights do you have

As a data subject, you have the following rights under Data Protection Legislation, and we, as the controller in respect of Your Data, will comply with such rights in respect of Your Data:

• The right of access to Personal Data relating to you;
• The right to correct any mistakes in your Personal Data;
• The right to ask us to stop contacting you with direct marketing;
• Rights in relation to automated decision making;
• The right to restrict or prevent your Personal Data being processed;
• The right to have your Personal Data ported to another data controller;
• The right to erasure; and
• The right to lodge a complaint with the ICO (Information Commissioner's Office) if you believe we have not handled your Personal Data in accordance with Data Protection Legislation.

These rights are explained in more detail below, but if you have any comments, concerns or complaints about our use of your Personal Data, please contact us (see 'How To Contact Us' in Section 15 below). We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond). Where a response is required from us within a particular time period pursuant to Data Protection Legislation, we will respond within that time period.

6.1 Right of access to Personal Data relating to you

You may ask to see what Personal Data we hold about you and be provided with:

• A summary of such Personal Data and the categories of Personal Data held (see Sections 2 and 3 above);
• Details of the purpose for which it is being or is to be processed (see Section 3 above);
• Details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those overseas transfers (see Section 9 below);
• Details of the period for which it is held or the criteria we use to determine how long it is held (see Section 13 below);
• Details of your rights, including the rights to rectification, erasure, restriction or objection to the processing (set out in this Section 6);
• Any information available about the source of that data (see Section 2 above);
• Whether or not we carry out automated decision-making, or profiling, and where we do, information about the logic involved and the envisaged outcome or consequences of that decision making or profiling (see Section 6.4 below); and
• Where your Personal Data are transferred out of the UK, what safeguards are in place (see Section 9 below).

Details in respect of the above points are all set out in this Policy; however, if you need further clarification, please contact us (see 'How to Contact Us' below).

Requests for your Personal Data must be made to us (see 'How To Contact Us' below) specifying what Personal Data you need access to, and a copy of such request may be kept by us for our legitimate purposes in managing the Service. To help us find the information easily, please give us as much information as possible about the type of information you would like to see. If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.

There are certain types of data which we are not obliged to disclose to you, which include Personal Data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations. We are also entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the Personal Data requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Legislation.

6.2 Right to update your Personal Data or correct any mistakes in your Personal Data

You can require us to correct any mistakes in your Personal Data which we hold free of charge. If you would like to do this, please:

• email or write to us (see ‘How can you contact us’ at Section 15 below);
• let us have enough information to identify you (e.g. name, registration details); and
• let us know the information that is incorrect and what it should be replaced with.

If we are required to update your Personal Data, we will inform recipients to whom that Personal Data have been disclosed (if any), unless this proves impossible or has a disproportionate effort.

It is your responsibility that all of the Personal Data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How to Contact Us’ at Section 15 below).

6.3 Right to ask us to stop contacting you with direct marketing

We have a legitimate interest to send you electronic communications in connection with the Service and related matters (which may include but shall not be limited to newsletters, announcement of new features etc. and which may also appear on social media platforms such as Facebook, LinkedIn, Twitter or Instagram.). We may also ask you for your consent to send you direct marketing from time to time. You may be able to select your preferences with respect to direct marketing when registering Your Account. We may also ask you different questions for different services, including competitions. We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please:

• Click on ‘unsubscribe’ on an email (this will be instantaneous);
• Respond ‘stop’ on an SMS (this will be instantaneous) to a number notified to you; or
• Send an email via ‘How To Contact Us’ below (this can take up to 5 working days).

We will provide you with information on action taken on a request to stop direct marketing – this may be in the form of a response email confirming that you have ‘unsubscribed’. Unsubscribing from direct marketing does not unsubscribe you from essential electronic communications in respect of the administration of Your Account.

6.4 Rights in relation to automated decision taking

You may ask us to ensure that, if we are evaluating you, we don’t base any decisions solely on an automated process and have any decision reviewed by a member of staff. We do not profile you for advertising purposes. These rights will not apply in all circumstances, for example where the decision is (i) authorised or required by law, (ii) necessary for the performance of a contract between you and us, or (ii) is based on your explicit consent. In all cases, we will endeavour that steps have been taken to safeguard your interests.

6.5 Right to restrict or prevent processing of Personal Data

In accordance with Data Processing Legislation, you may request that we stop processing your Personal Data temporarily if:

• you do not think that your Personal Data is accurate (but we may start processing again once we have checked and confirmed that it is accurate);
• the processing is unlawful but you do not want us to erase your Personal Data;
• we no longer need the Personal Data for our processing; or
• you have objected to processing because you believe that your interests should override the basis upon which we process your Personal Data.

If you exercise your right to restrict us from processing your Personal Data, we will continue to process the Personal Data if:

• you consent to such processing;
• the processing is necessary for the exercise or defence of legal claims;
• the processing is necessary for the protection of the rights of other individuals or legal persons; or
• the processing is necessary for public interest reasons.

6.6 Right to data portability

In accordance with Data Protection Legislation, you may ask for an electronic copy of your Personal Data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to Personal Data that you have provided to us – it does not extend to data generated by us. In addition, the right to data portability also only applies where:

• the processing is based on your consent or for the performance of a contract; and
• the processing is carried out by automated means.

6.7 Right to erasure

In accordance with Data Protection Legislation, you can ask us (please see 'How To Contact Us' below) to erase your Personal Data where:

• You do not believe that we need your Personal Data in order to process it for the purposes set out in this Policy;
• If you had given us consent to process your Personal Data, you withdraw that consent and we cannot otherwise legally process your Personal Data;
• You object to our processing and we do not have any legal basis for continuing to process your Personal Data;
• Your Personal Data has been processed unlawfully or have not been erased when it should have been; or
• Personal Data has to be erased to comply with law.

We may continue to process your Personal Data in certain circumstances in accordance with Data Protection Legislation (i.e., where we have a legal justification to continue to hold such Personal Data, such as it being within our legitimate business interest to do so (e.g., retaining evidence of billing information etc.). Where you have requested the erasure of your Personal Data, we will inform recipients to whom that Personal Data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.

7. Right to complain to the ICO

If you do not think that we have processed your Personal Data in accordance with this Policy, please contact us in the first instance (see ‘How to Contact Us’ facility below). If you are not satisfied, you can complain to the ICO (Information Commissioner's Office) or exercise any of your other rights pursuant to Data Protection Legislation. Information about how to do this is available on the ICO website at https://www.ico.org.uk

8. Withdrawal of Consent

If you no longer consent to our processing of Your Data (in respect of any matter referred to in this Policy as requiring your consent), you may request that we cease such processing by contacting us via the ‘How To Contact Us’ facility referred to in Section 15 below. Please note that if you withdraw your consent to such processing, it may not be possible for us to provide all/part of the Service to you.

9. Who we share your information with

We will not share Your Data without your consent or unless required by law (except as set out in this Policy). If we become involved in a merger, acquisition, or any form of sale of some of all of its assets, Your Data will not be transferred to any third party unless there are adequate safeguards in place with the recipient in respect of the security of Your Data.

We restrict access to Your Data to employees, contractors, and agents who need such access in order to operate, develop, or improve our Service. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, civil litigation and/or criminal prosecution, if they fail to meet these obligations. We may also share Your Data with our third party suppliers who assist us in the provision of the Service.

We also share Your Data with various third parties (subject to having appropriate contracts in place with such third parties).

Your Data may be transferred to, stored at, or accessed from a destination outside the United Kingdom (“UK”) for the purposes of us providing the Service. It may also be processed by staff operating outside the UK who work for us, another corporate entity within our group, or any of our suppliers. By submitting Your Data, you explicitly consent to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that Your Data is treated securely and in accordance with this Policy. The safeguards in place with regard to the transfer of Your Data outside of the UK to third parties shall include (but shall not be limited to) the entry by us into appropriate contracts with all transferees of such data.

All information you provide to us is stored on our (or contracted third party) secure servers. Where we have given you (or where you have chosen) a password which enables you to access any part of our Service, you are responsible for keeping this password confidential. We ask you not to share a password with any person not authorised to use the Service.

10. Wellness Data Integrations and AI Processing

10.1 Wellness Data from Connected Devices and Platforms

With your explicit consent, you may choose to connect your account to third-party longevity and wearable platforms. Where you do so, we may access certain wellness and activity data made available through those platforms in order to provide the Service.

Depending on the integrations you enable, we may collect and process the following categories of data:

Apple Health (including Apple Watch)

• Activity and energy data (steps; walking/running, cycling and swimming distance; flights climbed; active and resting energy; exercise and stand minutes; and workouts)
• Heart data (heart rate, resting heart rate, walking heart rate and heart rate variability)
• Respiratory data (respiratory rate and blood oxygen)
• Body measurements (weight, body mass index, body fat percentage, lean body mass, height and body temperature)
• Vitals (blood pressure and blood glucose)
• Sleep analysis and mindful minutes

Google Health Connect (Android)

• Step count data
• Heart rate data
• Sleep data

Where you grant the corresponding permission, Aion may read this Health Connect data in the background — that is, while the app is closed or not actively in use — so that your daily vitality and sleep insights, and any related notifications, are up to date when you next open the app. Aion only ever reads from Health Connect and never writes to or modifies your Health Connect data. You can review or revoke Aion's access at any time from the Health Connect settings on your device.

WHOOP

• Recovery data
• Sleep data and sleep cycle data
• Workout data
• Body measurements

Oura

• Demographic data (age, sex, height, weight)
• Sleep data
• Readiness data
• Activity data
• Heart rate data
• Workout data
• Tag data
• Session data
• SpO₂ data
• Cardiovascular metrics, including VO₂ max and cardiovascular age

Withings

• Metrics data
• Activity data
• Sleep data

This information may constitute wellness data, which is classified as special category data under Data Protection Legislation.

We only access this data where:

• You have chosen to connect the relevant device or platform; and
• You have granted the necessary permissions via the relevant provider and within our Service.

We do not access wellness data unless you actively enable the integration.

10.2 Purpose of Processing Wellness Data

• To provide personalised wellness insights and recommendations
• To generate analytics and performance summaries
• To improve and personalise your experience of the Service
• To support your wellness membership features
• To enable AI-powered longevity analysis (where enabled)

We do not sell your wellness data.
We do not use your wellness data for advertising purposes.

10.3 AI Processing – Microsoft Azure OpenAI Service

To generate personalised insights and analysis, we use Microsoft Azure OpenAI Service, provided by Microsoft Corporation.

Where AI-powered features are enabled, limited wellness and activity data may be securely transmitted to Microsoft Azure OpenAI Service for processing strictly for the purpose of generating insights within the Service.

Such data may include (depending on the integrations and features you enable): (i) selected wellness and activity metrics (e.g. sleep, readiness/recovery, activity, heart rate, workouts, SpO₂ and other cardiovascular metrics), including associated timestamps/date ranges where required to generate the requested insight; (ii) limited demographic data made available through connected platforms (e.g. age, sex, height, weight); (iii) other content you provide in the app where you choose to use AI-enabled analysis features, such as photographs uploaded for the calorie tracker or for reading a lab report, photographs you attach to a question, and the questions you type or speak to the in-app assistant; and (iv) audio you record, when you choose to speak instead of typing or to attach a voice note, which is transcribed to text, and the text of an answer where you ask for it to be read aloud.

This processing:

• Is limited to data necessary to generate the requested insight
• Is performed under Microsoft’s enterprise data protection terms
• Is not used to train public AI models
• Is not used by Microsoft for its own independent purposes
• Is subject to contractual safeguards and confidentiality obligations

We do not sell or license your wellness data to Microsoft or any other third party.

AI processing only occurs where you have provided explicit consent.

You may withdraw your consent at any time by contacting us using the details set out in Section 16 (How to contact us). You can also disconnect any connected device or platform in My devices at any time, which stops further syncing from that source.

Withdrawal of consent may limit certain features of the Service.

10.4 Legal Basis for Processing Wellness Data

• Your explicit consent (Article 9(2)(a) UK GDPR); and
• Performance of a contract, where processing is necessary to provide the Service you have requested.

You are not required to connect any third-party longevity platform. If you choose not to provide wellness data, certain personalised features may not be available.

You may withdraw your consent at any time.

10.5 International Transfers

AI processing (Section 10.3) runs on Microsoft Azure OpenAI Service. Our Azure resource is hosted in the Sweden Central region, and everything the models store stays in that region. Where the data is processed depends on the model. The models that answer your questions and write your plan run on Microsoft's EU Data Zone, so that processing stays within the European Union, which the UK Government has found to provide an adequate level of protection for Personal Data. A few smaller models are only offered by Microsoft on a global basis — today these are the ones that turn speech into text, read an answer out loud, and generate images — and for those, processing may take place outside the European Union, while storage remains in Sweden. All of it stays inside Microsoft's service under our own agreement with Microsoft: it is not sent to OpenAI, and it is never used to train anyone's models.

Where any other supplier processes Your Data outside the United Kingdom, the safeguards we rely on include:

• UK International Data Transfer Addendum;
• Standard Contractual Clauses; and/or
• Other lawful transfer mechanisms.

We take reasonable steps to ensure that your data is treated securely and in accordance with this Policy.

10.6 Data Minimisation

We only transmit data necessary for the specific functionality requested. We do not transmit more wellness data than is required to generate the relevant insight.

Where possible, data may be aggregated or summarised before processing.

10.7 Sharing Wellbeing Data with Your Chosen Experts

The Service allows you to voluntarily connect with vetted trainers and longevity professionals ("Experts"). If you send a connection request to an Expert and the Expert accepts it, that Expert will be able to view certain of Your Data on a read-only basis, namely: your vital signs, sleep, activity and wearable data, trends, forecasts, laboratory results, and the guidance the Service generates for you. Your diary entries, community chat history, daily check-in notes and uploaded medical documents are never shared with Experts.

This sharing is entirely consent-based: it begins only when the Expert accepts your request and ends immediately when either you or the Expert ends the connection, which you may do at any time within the app. We retain a record of when such access was granted and ended for accountability purposes. Experts are approved by us before appearing in the directory and are permitted to use Your Data solely for the purpose of providing their services to you.

10.8 Messaging and Video Calls with Experts

When connected with an Expert, you may exchange private messages within the Service. These messages are stored on our servers and are visible only to you and the connected Expert. Video calls with Experts are conducted using the Jitsi Meet video-conferencing service operated by a third party; call rooms are private to you and your Expert and we do not record calls. Audio and video streams during a call are processed by the Jitsi service provider and are subject to that provider's privacy practices.

10.9 Calendar integrations

Connecting a calendar is never required to use the Service. You choose it yourself, and you can disconnect it at any time in the app. What a connection does depends on which app you are using.

Putting your plan into a calendar. There are two ways, and both are things you start yourself.

• Add-to-calendar links. Each action offers an "Add to calendar" option. The single event you chose (its title, a short description and its time) is handed to your own device's calendar or to your calendar provider, which stores it under that provider's privacy policy. No connection is created and we store nothing further on our side.
• Private calendar feed. You can create a private feed link and subscribe to it from any calendar app. The link itself is the only credential: anyone who holds it can read what it publishes (the titles, short descriptions and times of your upcoming actions), so treat it like a password and do not share it. We do not write the link to our server logs. You can reset or remove it at any time from My devices. A reset or removed link stops publishing immediately; the old address returns an empty calendar for up to 30 days so that subscribed apps clear their copies, and then stops working altogether.

Your plan can include health-related items you or the app wrote. If you publish a feed, their titles, short descriptions and times leave our systems and are stored by whichever calendar app subscribes to it. Do not put anything in a manual action that you would not want in your calendar.

Our use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements. Specifically: we use Google Calendar data only to provide the features described above, we do not transfer it to others except as needed to provide those features or as required by law, we do not use it for advertising, and no human reads it except where you ask us to for support, where it is necessary for security, or where the law requires it.

10.10 Camera, microphone and the things you record in the app

Some features use your device's camera or microphone. Each one asks your permission first, each is optional, and none of them runs in the background.

• The pulse scan. The scan reads your pulse from your face using your camera. The video is processed on your own device and is never uploaded: no photograph and no video of you leaves your phone. What reaches our servers is two numbers, your estimated beats per minute and a measure of how clear the signal was. It is an estimate from a camera and not a medical measurement.
• Photographs you take or upload. Photographs of meals, of lab reports, and photographs you attach to a chat message or to an item in your plan are uploaded to our storage and kept with the entry they belong to until you delete that entry or your account. Where a feature reads a photograph for you — estimating calories, reading a lab report, or answering a question about it — it is sent to Microsoft Azure OpenAI Service as described in Section 10.3.
• Voice notes and dictation. When you record a voice note, or speak instead of typing, the recording is sent to Microsoft Azure OpenAI Service to be turned into text, under the same terms as Section 10.3. A recording you attach to an item in your plan is stored with that item, together with its transcript, until you delete it. A recording you dictate into a text box is transcribed and not kept afterwards. The words come back for you to read and edit before anything is sent.
• Answers read aloud. If you ask the app to read an answer out, the text of that answer is sent to Microsoft Azure OpenAI Service to be turned into speech, under the same terms as Section 10.3. The audio is played to you and not kept. If no voice is available on our side, your own device reads the text aloud and nothing leaves your phone.

11. Third Party Websites

This Policy applies to websites and services that are owned and operated by us. We do not exercise control over the sites/applications that may be linked from the Service. These other sites/applications may place their own cookies or other files on your computer, collect data or solicit personal information from you. You acknowledge that the Service that we provide may enable or assist you to access the website content of, correspond with, and purchase goods and services from, third parties via third-party websites and that you do so solely at your own risk. We make no representation or commitment and shall have no liability or obligation whatsoever in relation to the content or use of, or correspondence with, any such third-party website, or any transactions completed, and any contract entered into by you, with any such third party and the use by any such third-party of your Personal Data. We do not endorse or approve any third-party website nor the content of any of the third-party websites made available via the Service. We encourage you to carefully familiarise yourself with the terms of use and privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.

12. How do we protect your personal information

We do our utmost to protect user privacy through the appropriate use of security technology. We restrict access to Your Data to employees, contractors and agents who need to know Your Data in order to operate, develop or improve the services that we provide. We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place. However, our Website may contain hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.

We will implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks that are presented by the processing of Your Data. In particular, we will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Your Data transmitted, stored or otherwise processed.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Your Data, we cannot guarantee the security of any data transmitted to us and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. To the extent permitted by law, we are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that our Service may be subject to limitations, delays and other problems inherent in the use of such communications facilities. You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorised disclosure, loss or destruction of Your Data arising from such risks.

13. Breach Reporting

We will notify serious data breaches in respect of Your Data to the ICO (Information Commissioner's Office) without undue delay, and where feasible, not later than 72 hours after having become aware of the same. If notification is not made after 72 hours, we will record a reasoned justification for the delay; however, it is not necessary to notify the ICO where the Personal Data breach is unlikely to result in a risk to the rights and freedoms of natural persons. A Personal Data breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.

We will keep a record of any data breaches, including their effects and the remedial action taken, and will notify you of any data breach affecting your Personal Data (which poses a high risk to you) when we are required to do so under Data Protection Legislation. We will not be required to notify you of a data breach where:

• We have implemented appropriate technical and organisational measures that render the Personal Data unintelligible to anyone not authorised to access it, such as encryption; or
• We have taken subsequent measures which ensure that the high risk to data subjects is not likely to materialise; or
• It would involve disproportionate effort, in which case we may make a public communication instead.

14. Retention of Personal Data

Your Data will be kept and stored for such a period of time as we deem necessary taking into account the purpose for which it was collected in the first instance. This may include retaining Your Data as necessary to administer Your Account, comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Service.

Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Service, not to specifically analyse personal characteristics about you.

Wellness data obtained through connected platforms, including Google Health Connect, is retained only while your Aion account is active and is permanently deleted when you delete your Aion account. You can also disconnect any integration at any time to stop further syncing.

15. Amendments to Policy

We may change our Policy from time to time and at our sole discretion. The date of the most recent revisions will appear on the top of this Policy. If you do not agree to these changes, please do not continue to use the Service to submit Your Data. If material changes are made to the Policy, we will notify you by placing a prominent notice on our Service or by sending you a notification in relation to this. We will not process Your Data in a manner not contemplated by this Policy without your consent.

16. How to contact Us

If you need to contact us with regard to any of your rights as set out in this Policy, all such requests should be made in writing by email to [[email protected]].