OBJECTIVE, SCOPE AND APPLICABILITY

Nutritionalab Private Limited ("Company", "we", "our", "us") respects an individual's privacy and is committed to protecting the same. This Privacy Policy ("Policy") describes how we collect, use, disclose and transfer Personal Information (as defined below), through platforms controlled by the Company, viz. www.wellbeingnutrition.com and mobile sites/application (the "Platforms"), of the individuals who browse or access the Platform or provide information on or through the Platform, or whose information the Company otherwise collects, receives or processes in connection with the offer and sale of its products ("Products") (hereinafter collectively referred to as "Customers", "you", "your"), and ensure its compliance with applicable laws and regulations. This Policy does not apply to Personal Information collected from you offline (unless otherwise specified), to Company's websites that do not link to this Policy, to Customers of countries other than India, or to third-party websites to which the Platform may link.

By accessing and/or using our Platform and providing the information as explained in this Policy, you consent to the collection and use of the information you disclose on the Platform in accordance with this Policy, including but not limited to your consent for sharing your information as per this Policy. We encourage you to read this Policy regarding the collection, use, and disclosure of your information. If you are not comfortable with any of the terms or policies described in this Policy, you may choose to discontinue usage of the Platform.

Further, you agree and consent to receive all communications related to our services on the mobile number provided by you to the Company, even if such mobile number is registered under the DND/NCPR list under the Telecom Commercial Communications Customer Preference Regulations, 2018 ("TRAI Regulations"). Notwithstanding your registration with the National Do Not Call Registry (in Fully or Partly blocked category under the National Customer Preference Register set up under the Telecom Regulatory Authority of India), you hereby express your interest and accord informed consent to receive communications (including commercial communications) in relation to the Company's services. You further confirm that no communication to you from the Company or on behalf of the Company shall be construed as Unsolicited Commercial Communication under Regulation 2(bw) of the TRAI Regulations, and you have specifically opted to receive communications in this regard on the mobile number provided by you.

For the purpose of this Policy, the term "Personal Information" shall mean any information that relates to you, which, either directly or indirectly, in combination with other information available or likely to be available with the Company, is capable of identifying you, which is submitted to and/or collected over the Platform and maintained by the Company in an accessible form, provided that any information that is freely available or accessible in the public domain or furnished under the Right to Information Act, 2005 or any other law for the time being in force shall not be regarded as Personal Information for the purposes of this Policy.

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We communicate with you through a variety of means and channels, including our Platform, email, phone or text messaging on your mobile phone, although we do generally note that our preferred means of communication is email, which has the least impact on the environment. Such communications may involve giving information to you, as well as receiving information from you. We collect and receive the Personal Information in the following ways:

When you submit your Personal Information on our Platform: The Company collects and stores the Personal Information that you provide while using our Platform, including when you enter your Personal Information into data fields on the Platform as part of a voluntary registration process. We also collect and store your Personal Information through sponsored social media platforms, events, etc. For example, you may submit your name, postal address, e-mail address, and/or other information in order to register, place orders for the Products, receive information about various Products, register for newsletters, receive offers, contact Company's customer care service, or respond to the Company's surveys. To protect your privacy, you should not provide the Company with any information that is not specifically requested or that you do not wish to share. You can choose not to provide certain information, but then you might not be able to use our Platform or certain features of our Platform.

Automatic collection: We automatically collect and store certain types of information whenever you interact with us. Such information includes information about your use of the Platform and your interaction with content and services available through the Platform. Like many websites, unidentifiable information may be collected using various technologies, such as cookies, Internet tags, and web beacons. Your Internet browser automatically transmits to the Platform some of this unidentifiable information, such as the URL of the website you just visited and the browser version your computer is operating. Passive information collection technologies can make your use of the Platform easier by allowing the Company to provide better service, customize sites based on consumer preferences, compile statistics, analyze trends, and otherwise administer and improve the Platform. Certain features of the Platform may not work without use of passive information collection technologies. Information collected by these technologies cannot be used to identify you without additional identifiable information. We may also receive/store information about your location and your mobile device, including a unique identifier for your device.

Other sources: We might receive information about you from other sources, such as updated delivery and address information from third parties, which we use to correct our records and deliver your next purchase more easily. Further, we may receive information about you from third parties that feature our Products or promotional offers if you opt in to receive information from us. You may also choose to participate in a third-party application or social media site through which you allow us to collect (or the third party to share) Personal Information about you, including usage information. We may also receive information, such as marketing-related or demographic information about you, from third parties to enhance our ability to tailor our content and offer you the Products that we believe may be of interest to you. The Company is not responsible for the privacy practices of such third-party websites which it does not own, manage or control.

WHAT PERSONAL INFORMATION DO WE COLLECT?

The Company limits itself to collecting information which is necessary to ensure accurate services, is required to process your order of the Product or provide a refund, and to continually improve our Products and services.

Following are the categories of Personal Information that are collected and processed by us:

• Your name, e-mail and postal addresses, phone number(s), country;
• Date of birth, language preference, location;
• Any open data and public records, such as information about you that is openly available on the Internet;
• Names of people to whom purchases have been shipped, including address and telephone numbers, IP addresses;
• Product interest information and, in certain circumstances, your opinions and individual preferences, etc.;
• You may also provide us with information like financial information such as bank account or credit card or debit card or other payment instrument details, and password for availing the Products at our Platform;
• We may also maintain a record of your Product interests and acquire information about you from our future affiliates;
• Phone numbers used to call our customer service number.

We may collect and use technical data and related information, including but not limited to technical information about your device, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and other services to you (if any) related to the Platform.

WHAT IS THE PURPOSE FOR WHICH THE PERSONAL INFORMATION IS COLLECTED?

The Company may use your Personal Information to:

• Verify your identity;
• Fulfil the Product purchases and transactions;
• Communicate with you about your account and activities on the Platform;
• Sign up for our newsletter, respond to a survey or marketing communication;
• Allow us to better serve you in responding to your requests;
• Respond to reviews, comments, or other feedback provided to us;
• Administer a contest, promotion, survey or other site feature;
• Ask for ratings and reviews of the Products;
• Follow up with you after correspondence (live chat, email or phone inquiries);
• Allow you to log in with a social media account and share activities on your social media pages;
• Comply with our legal obligations, policies and procedures, including compliance with relevant industry standards and the enforcement of our terms and conditions;
• Help us learn more about your shopping preferences;
• Conduct marketing and performance research to assist us in measuring our customer services, benchmarking our performance and helping us improve your shopping experiences and Product offerings;
• Send communication related to order updates and offers through e-mail, SMS and social media channels;
• Do internal research on our Customers' demographics, interests, and behaviour to better understand and serve you;
• Provide you with exclusive offers on the Platform, tailor content and advertisements we provide you, and improve the Platform and/or for internal business purposes;
• Analyze trends, track Customers' web page movements, and help identify you and your shopping cart for aggregate use;
• Determine which of the store locations containing our Products may be closest to you, provide promotional offers, and offer Products to you;
• Prevent, detect, investigate and take action against crimes (including but not limited to fraud and other financial crimes), any other illegal activities, suspected fraud, or violations of Company's terms and conditions in any jurisdiction;
• Establish, exercise or defend legal rights in connection with legal proceedings (including any prospective legal proceedings) and seek professional or legal advice in relation to such legal proceedings; and
• Comply with any applicable law, regulation, legal process or enforceable governmental request.

THE LEGAL BASIS ON WHICH WE COLLECT YOUR PERSONAL INFORMATION

Performance of a Contract: Some of the Personal Information is processed on the basis that it is necessary for the performance of our agreement with you. An example of this would be where we process your Personal Information for delivering the Products ordered by you on our Platform.

Legitimate Interest: Legitimate interests will include where we send you marketing information about our Products and communicate with you in order to serve you better.

Compliance with a Legal Obligation: For certain types of processing, it is necessary in order to allow us to comply with a legal obligation. An example of this would be where we are required to retain business records for fixed periods of time in order to comply with local legal requirements.

Consent: Finally, in certain limited situations, we rely on your consent in order to process your Personal Information. Where we require your consent in order to collect and process certain Personal Information, we seek your consent at the time of provision, and such processing will only be performed where consent is secured. You can withdraw your consent, as per this Policy where applicable, by sending an email to care@wellbeingnutrition.com.

We may also collect and/or generate anonymized and aggregated information from your use of the Platform. The anonymized or aggregated information is not Personal Information since we are not able to re-identify you using any means available to us from that anonymized or aggregated information. The anonymized and aggregated information is used for a variety of functions, including to help us identify and remediate any bugs and to improve the performance of our Platform. The Company may use such information in a number of ways, including internal analysis, analytics and research. We may share this information with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

We maintain a social media presence, such as Facebook, Instagram, LinkedIn and a Twitter feed. You can interact with us through social media, such as by entering our contests, posting content, sharing material from our Platform, and using our social media plug-ins. When you interact with us using social media, we may receive information such as your user ID, your profile picture, photos you post, and similar information, which is often determined by your privacy settings at the relevant social media sites. We may use the information for the purposes we have described throughout this Policy. Your use of social media sites is primarily governed by the site operators' privacy policies and terms of service, and the information you share with us and with others is largely controlled by the privacy settings you have established at those sites.

Payment Information: You may provide payment information when you use the Platform to buy our Products, including credit card numbers and billing information, using third-party intermediary PCI-DSS compliant service providers. The payment information is provided directly by you, via the Platform, into the PCI-DSS compliant payment processing service to which the Company subscribes, and the Company does not itself process or store the payment information, except as stated herein. Further, these intermediaries are not permitted to store, retain, or use your billing information for any purpose except for payment processing on our behalf.

If you use the Platform, you are responsible for maintaining the confidentiality of your access information and password. You are responsible for restricting access to your computer, mobile device, etc., and you agree to accept responsibility for all activities that occur under your password. We cannot secure any information that you release on your own, that you request us to release, or that is released through another third party to whom you have given access.

In the case of our customer care support, we may record calls for quality and training purposes.

HOW DO WE SHARE THE PERSONAL INFORMATION?

Only the persons authorized by us shall have access to your Personal Information. We may share your Personal Information only with those mentioned below, and they are either subject to this Policy or follow practices at least as protective as those described in this Policy:

• Our affiliates and third parties;
• Service providers who perform services on our behalf based on our instructions, which inter alia include beauty partners providing beauty services to the Customers. However, these service providers will not be authorized to use or disclose such information except as necessary to perform services on our behalf or comply with legal requirements.

We do not rent or sell your Personal Information to any third party.

Should we plan to merge/sell all or substantially all of our business to another business entity, or enter into a similar transaction, or be required by that business entity, we may transfer or disclose your Personal Information to that business entity, who may collect, use or disclose such information for the purposes of evaluating the proposed transaction, operating and managing the affairs of the acquired business, or for other purposes identified in this Policy.

We may share Personal Information with our other corporate entities, who may use the said information in accordance with this Policy to help detect and prevent identity theft, fraud, and other potentially illegal acts, and correlate related or multiple accounts to prevent abuse of our Platform. If you have any objection to such sharing, we request that you do not provide us with any information.

We may retain other companies and individuals to perform functions on our behalf consistent with this Policy. Examples include order processing companies, courier companies, data analysis firms, customer support specialists, email vendors, web-hosting companies and fulfilment companies (e.g., companies that coordinate mailings). Such third parties may be provided with access to Personal Information needed to perform their functions but may not use such information other than on our behalf and in accordance with this Policy.

In addition, in some instances, you may be offered the opportunity to consent to the sharing of your information with a third party, such as an event or promotion co-sponsor. If you consent, we will share your information with such third party, and the information you provide may be used by such third party for their own purposes and in accordance with their own policies.

Notwithstanding anything contained in this Policy, we may disclose Personal Information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to any court orders or other legal processes. We may disclose Personal Information to law enforcement offices, third-party rights owners, or others in the good faith belief that such disclosure is reasonably necessary to: enforce our Terms and Conditions or Policy; respond to claims that an advertisement, posting or other content violates the rights of a third party; or protect the rights, property or personal safety of our Customers or the general public.

RETENTION OF PERSONAL INFORMATION

We will retain your Personal Information only as long as it is reasonably required or otherwise permitted or required by applicable law or regulatory requirements. We may also retain your Personal Information so long as it is necessary to fulfil the purposes for which it was collected (including for purposes of meeting any legal, administrative, accounting, or other reporting requirements). Your Personal Information is safeguarded against inappropriate access and disclosure, as per this Policy.

We also maintain appropriate and adequate administrative, technical and physical safeguards designed to protect your Personal Information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

OPTING OUT

The Platform provides an option to all Customers to opt out of receiving any promotional or marketing communications from us. If you do not wish to receive any promotional or marketing communications from us, you can contact us at the address provided below.

Your Choices to Opt Out

You have the following choices regarding how your Personal Information is used:

Updating your Personal Information in relation to your account
You can update or correct your name, e-mail address, security questions, and other preferences by logging into your account and clicking on the "My Account" page, or by calling a customer care executive.

Receiving newsletters and promotional e-mails
You can click on the "unsubscribe" link at the bottom of any promotional e-mail that you receive. Alternatively, you may edit your e-mail preferences on your "My Account" page or call a customer care executive to discontinue receiving any promotional materials by mail/e-mail.

Removing content from Customer reviews
You can remove content that you posted in a public space, such as part of a rating and review, by e-mailing details to care@wellbeingnutrition.com Please note that we will endeavour to honour your request to remove information; however, our removal of your information does not completely erase that information from the internet, viz. historical copies or "caches" may remain.

WITHDRAWAL OF CONSENT

If you have consented to the collection, use and/or disclosure of your Personal Information as identified in this Policy, you have the right to withdraw this consent at any time by writing to us at  care@wellbeingnutrition.com Where you are providing location information via a mobile app, you may turn off location services on your device at any time. Please note that any processing that we have carried out before the withdrawal of your consent remains lawful. Provided that, notwithstanding such request, this information may be retained to comply with our legal obligations, resolve disputes and enforce our agreements.

HOW WE STORE YOUR PERSONAL INFORMATION

We may store Personal Information using our own secure on-site servers or other internally hosted technology. Your Personal Information may also be stored by third parties, via cloud services or other technology, with whom the Company has contracted to support the Company's business operations.

These third parties do not use or have access to your Personal Information other than for cloud storage and retrieval, and the Company requires such parties to employ at least the same level of security that we use to protect your Personal Information.

DISPOSAL OF PERSONAL INFORMATION

We will only use your Personal Information for the purposes stated and will make sure that your privacy is protected. We shall take reasonable steps to delete or permanently de-identify Personal Information that is no longer needed.

DO WE USE "COOKIES"?

We may track your preferences and activities on the Platform. "Cookies" are small data files transferred to your computer's hard drive by a website while using a web browser (if you allow). They keep a record of your activities on the Platform, making your subsequent visits to the site more efficient. Cookies may store a variety of information, including the number of times that you access the Platform, registration information, and the number of times that you view a particular page or other item on the Platform. The use of cookies is a common practice adopted by most major sites to better serve their clients. Most browsers are designed to accept cookies, but they can be easily modified to block cookies.

By continuing to use the Platform, you are agreeing to our use of cookies. If you do not agree to our use of cookies, you can block them in your browser settings, but you may lose some functionality on the Platform.

We use cookies to:

• Understand and save Customers' preferences for future visits;
• Keep track of advertisements;
• Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. You may look at your browser's help menu to learn the correct way to modify your cookies.

If you turn cookies off, some features that make your site experience more efficient will be disabled and may not function properly. However, you will still be able to place orders.

CUSTOMER COMMENTS AND CONTENT

If you post any comments or content on our Platform, you should be aware that any information you choose to provide there may be read, collected, or used by third parties. We are not responsible for the information you choose to submit, and we cannot guarantee that third parties have not made copies of or will not use such information in any way.

LINKS TO THIRD-PARTY ADVERTISEMENTS OR SITES

We may display links to websites that are owned or operated by third parties on our Platform. Please understand that these websites are independent of the Company, and the Company has no control over the content on those websites, even if the Company provides information or Products to the owner of that website. The Company is not making any representations about, endorsing, or accepting any responsibility for the content or the use of such websites. Further, we are not responsible or liable for any damage or loss related to the use of any third-party website. You should always read the terms and conditions and the privacy policy of a third-party website before accessing or using it.

THIRD-PARTY ANALYTICS

We use third-party analytics services to evaluate your use of the Platform, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Platform and mobile and internet usage. These third parties use cookies and other technologies to help analyze and provide us the information and, in some cases, connect such information with other data held by our, or third-party, environments. You consent to the processing of information about you by these analytics providers in the manner and for the purposes set out in this Policy.

At present, we work with the following analytics partner:

• Google

Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for Customers. We use Google AdSense Advertising on our Platform. Google, as a third-party vendor, uses cookies to serve ads on our Platform. Google's use of the DART cookie enables it to serve ads to our Customers based on previous visits to our Platform and other sites on the Internet. Customers may opt out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

We have implemented the following:

• Remarketing with Google AdSense
• Google Display Network Impression Reporting
• Demographics and Interests Reporting
• DoubleClick Platform Integration

We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding Customer interactions with ad impressions and other ad service functions as they relate to our Platform.

Customers can set preferences for how Google advertises to them using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt-Out page or by using the Google Analytics Opt-Out Browser Add-on.

EMPLOYMENT OPPORTUNITIES

We provide you with a means for submitting your resume or other information through our Platform for consideration for employment opportunities at the Company. Information received through resume submissions will be kept confidential. We may contact you for additional information to supplement your resume, and we may use your information within the Company or keep it on file for future use as we make our hiring decisions.

CHILDREN

Our Platform is not designed for individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from anyone under the age of eighteen (18). If you are under eighteen (18) years of age, you may browse our Platform, but please do not provide your Personal Information to us. For example, you cannot register. If we become aware that we have inadvertently received Personal Information from a visitor under the age of eighteen (18) on the Platform, we will delete the information from our records.

SECURITY

We endeavour to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, with security safeguards appropriate to the sensitivity of the Personal Information, regardless of the format in which it is held. We use various methods to safeguard Personal Information. They include:

• Physical measures: locked filing cabinets, restriction of access to offices, and alarm systems.
• Technical tools: passwords and encryption, using generally accepted industry best practices.
• Organizational controls: confidentiality agreements, limiting access on a need-to-know basis, staff training and security clearances.

Online security is also a priority. We incorporate security measures such as encryption and authentication tools to protect your Personal Information from unauthorized use. Firewalls are utilized to protect our servers and network from unauthorized users accessing and tampering with files and other information that we store.

Further, we attempt to keep your Personal Information up to date and accurate in the best possible manner, as may be necessary for the purpose for which it was collected. We value the importance you attach to the Personal Information given to us, and therefore we have (i) taken all reasonable measures and precautions to keep such information safe and secure and to prevent any unauthorized access to or misuse of the same; and (ii) enabled you to review and edit the same.

We use regular malware scanning.

Your Personal Information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a Customer enters, submits, or accesses their information to maintain the safety of your Personal Information.

However, we shall not be liable to any Customer for any loss, damage (whether direct, indirect, consequential or incidental) or harm caused to the Customer due to unauthorized access or misuse of the Personal Information by any third party.

POLICY REVIEW

Please note that we review and may make changes to this Policy from time to time. When changes are made, the Policy link will include a notation "Revised (date)", indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. By accessing the Platform after any changes have been made, you signify your agreement on a prospective basis to the modified Policy and any changes contained therein.

PRIVACY CONCERNS

If you are concerned about the handling of your Personal Information, or if you have any complaints or queries related to your Personal Information or our Policy, please contact:

Grievance Redressal

Any complaints, abuse or concerns with regard to content and/or comments or breach of these terms shall be immediately informed to the Customer Redressal Officer mentioned below via mail, email or phone.

Customer Redressal Officer
Ashutosh Das
Email: escalations@wellbeingnutrition.com

Address:
Nutritionalab Pvt. Ltd.
602, Orion Building, Nehru Rd,
Madhuvan Society, Sen Nagar,
Santacruz East, Mumbai,
Maharashtra 400055, India

The Grievance Officer is identified above pursuant to the provisions of applicable laws, including but not limited to the Information Technology Act, 2000 and the Consumer Protection Act, 2019, and the rules enacted under those laws.

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PLEASE BEWARE

It has recently come to our attention that a scam is circulating within our industry, targeting B2B customers with fraudulent offers of substantial discounts and enticing freebies, such as free laptops against minimum purchase orders. These offers are often accompanied by forged documents that appear genuine but contain fraudulent bank account details.

To protect yourself, please verify the authenticity of any offer for Wellbeing Nutrition products before making a purchase. For verification, you can contact our support team at +91 93269 13433 or write to us at care@wellbeingnutrition.com before placing your order. Our team will confirm whether the offer you have received for Wellbeing Nutrition products is genuine.

We care about the safety of your business and urge you to be cautious to prevent falling victim to these scams.

If you need further assistance or wish to report suspicious activities concerning Wellbeing Nutrition products, please contact our support team using the details provided above.

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WEARABLE & HEALTH DATA PRIVACY NOTICE

1. SCOPE OF THIS NOTICE

This notice supplements the Wellbeing Nutrition Privacy Policy and applies specifically to the health, fitness, and wellness data you choose to share with us by connecting a wearable device or health app to the Wellbeing Nutrition mobile application (the "App"). It describes what we collect, how, why, who we share it with, how long we keep it, and the choices available to you. Where this notice is silent, the general Wellbeing Nutrition Privacy Policy applies.

By connecting your wearable or health app data to the App, you consent to the collection, use, and disclosure of this data as described below. This is separate from, and in addition to, any consent you provide elsewhere on our Platform.

2. WHAT WE COLLECT

When you choose to connect a wearable or health app, we collect the following categories of information:

• Health and fitness data specifically requested by the App through Apple Health on iOS or Health Connect on Android. On iOS, the App currently requests access to the following health and fitness data types:

1. Steps (daily_steps) — used for activity tracking and Readiness-related calculations.
2. Sleep (sleep) — used for sleep duration/stages and Readiness-related calculations.
3. Workouts / Exercise (exercise) — used for exercise duration/intensity and Readiness-related calculations.
4. Heart Rate (heart_rate) — used for heart-rate biomarkers and data logs.
5. Resting Heart Rate (resting_heart_rate) — used for resting-heart-rate biomarkers and Readiness-related calculations.
6. Heart Rate Variability (SDNN) (heart_rate_variability_sdnn) — used for HRV biomarkers and Readiness-related calculations.
7. Walking Heart Rate Average (walking_heart_rate_average) — used for walking heart-rate data.
8. Respiratory Rate (respiratory_rate) — used as a respiratory-rate biomarker.
9. Blood Oxygen / Oxygen Saturation (oxygen_saturation) — used as an SpO₂ biomarker.
10. Cardio Fitness / VO₂ Max (vo2_max) — used as a VO₂ Max biomarker.
11. Active Energy Burned (active_energy_burned) — used as an activity/energy biomarker.

• These data points are used to calculate and display your Wellbeing Score and related wellness/readiness insights, analyse health and fitness trends, and provide personalised wellness recommendations.

• Scores and insights we generate from that data, including your Wellbeing Score, individual pillar scores (Sleep, Activity, Mind & Stress, Longevity/Nutrition, and Readiness where applicable), trend comparisons, and lifestyle classification we derive from your patterns of wearable data over time. These are inferences we create; they are not information you enter yourself.

• We only receive and process the specific health and fitness data types listed above that are authorised by you and required for the functionality described in this notice. We do not request or collect additional Apple Health data types that are not required for this functionality.

• Device and app interaction data relevant to this feature, including your Health app connection and sync status, and, on iOS, your App Tracking Transparency choice.

We do not collect data directly from your wearable device or its manufacturer. We only receive data that your device has already made available through Apple Health or Health Connect, via our data processor, Sahha.

3. HOW WE COLLECT IT

The data flow works as follows: your wearable syncs to its own manufacturer app, which writes to your phone's Apple Health or Health Connect store; our processor, Sahha, reads the specific health and fitness data types listed in Section 2 from that store with your permission; Sahha resolves and normalises this into a single data set per person; and our backend receives that data set from Sahha. We do not integrate with, or receive data directly from, individual wearable brands.

We request your permission for this in two steps: first, an in-app consent screen describing what we collect and why; second, the native operating system permission prompt for Apple Health or Health Connect access. On iOS, you will also see the separate App Tracking Transparency prompt, which governs cross-app/cross-company tracking and is independent of your health data decision.

4. WHY WE PROCESS THIS DATA

We use your wearable and health data to:

• Calculate and display your Wellbeing Score and pillar scores.
• Generate personalised insights.
• Generate personalised product recommendations based on trends in your data (for example, where a tracked marker is declining).
• Improve and validate this feature through internal analytics and research.
• Where you have separately consented, train or improve AI-driven features that personalise your experience.

We do not use your health data to serve third-party advertisements, and we do not sell, rent, or share your health data with data brokers or advertisers.

5. CONSENT

Processing of your wearable and health data is based on your explicit, informed consent, which we obtain through a dedicated consent screen before any such data is requested. That screen itemises each purpose separately — including data tracking and display, personalised insights and protocol adjustments, personalised product recommendations, and any future AI-related use — so that you can understand and agree to each use individually. Consent is captured once per account and is not required again for routine reconnection, unless we materially change how we use your data, in which case we will seek fresh consent.

You may withdraw this consent at any time, as described in Section 7 below. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

6. HOW WE SHARE THIS DATA

We share your wearable and health data only as follows:

• With Sahha, our wearable-data processor, which reads your Apple Health/Health Connect data on our behalf and provides it to us in normalised form. Sahha's own handling of this data before it reaches us is governed by Sahha's end-user privacy policy. docs.sahha.ai/docs/legal/end-user-privacy-policy.

• With service providers who support our backend infrastructure (such as hosting and storage providers), solely to store and process this data on our behalf, under confidentiality and security obligations at least as protective as those in this notice.

• Where required by law, including in response to a valid legal process or to protect the rights, safety, or property of our users or the public.

We do not sell your wearable or health data. We do not share it with third parties for their own marketing or advertising purposes.

Some or all of the above processors may store or process data outside India. Where this occurs, we take steps to ensure such transfers are permitted under applicable Indian data protection law and are not made to any country restricted by the Government of India. [TBC: confirm Sahha's data hosting region(s) and include specifically.]

7. YOUR CHOICES AND CONTROLS

You have the following controls over your wearable and health data, each with a distinct effect:

• Pause Health Data: Available in-app under Health Access settings. This stops the App from displaying or using your health data — it does not stop new data from being received and stored on our backend. Use this if you want to temporarily stop seeing wearable-based content without losing your history.

• Manage permissions at the operating system level: You can adjust exactly which data types you share, or disconnect entirely, from your device's Health app (iOS) or Health Connect settings (Android) at any time. We detect this change and reflect it in the App.

• Delete All My Data (reset): Available in-app under Health Access settings. This clears your dashboard back to a no-data state. This is a reversible reset, not permanent deletion — we continue to retain the underlying data as described in Section 8, unless you separately submit an Erasure Request.

• Erasure Request: Available in-app under Health Access settings. This is a permanent deletion request: once confirmed, we delete your wearable and health data and it cannot be recovered. This is distinct from, and independent of, the reset described above.

You may also withdraw your consent to this feature entirely at any time by writing to us at the contact details in Section 12, or by using the in-app controls above.

8. DATA RETENTION

We retain your wearable and health data for one (1) year from the date it is collected, for as long as your health data connection remains active and continues to generate new data. If you disconnect or your connection lapses, previously collected data is retained only until the applicable one-year period from its collection date has elapsed, after which it is deleted, unless we are required to retain it for longer to comply with law or resolve a dispute. You may request permanent deletion earlier at any time via an Erasure Request (Section 7).

9. SECURITY

We apply administrative, technical, and physical safeguards to protect your wearable and health data, including encryption in transit and at rest, access restricted to personnel on a need-to-know basis, and audit logging of backend access. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. AUTOMATED INSIGHTS, AI USE, AND HEALTH DISCLAIMER

Your Wellbeing Score, pillar scores, insights, and product recommendations are generated automatically from your wearable data using our scoring logic. These features are intended for general wellness purposes only. They are not medical advice, not a medical diagnosis, and not a substitute for consultation with a qualified healthcare professional. If you have health concerns, please speak to your doctor.

11. CHILDREN

This feature is not intended for, and we do not knowingly collect wearable or health data from, individuals under the age of 18. If we become aware that we have inadvertently collected such data from a person under 18, we will delete it. We do not direct behavioural tracking, profiling, or targeted advertising based on health data at children.

12. YOUR RIGHTS AND HOW TO REACH US

Subject to applicable law, you have the right to seek access to a summary of your wearable and health data and how it is processed, request correction of inaccurate data, request erasure, withdraw consent, and lodge a grievance regarding our handling of your data. You may also nominate another individual to exercise these rights on your behalf in the event of your death or incapacity.

To exercise any of these rights, or with any questions or complaints about this notice, please contact:

Grievance Redressal
Ashutosh Das
Email: escalations@wellbeingnutrition.com

Nutritionalab Pvt. Ltd.
602, Orion Building, Nehru Rd,
Madhuvan Society, Sen Nagar,
Santacruz East, Mumbai,
Maharashtra 400055, India

If you are not satisfied with our response, you may also have the right to approach the Data Protection Board of India. [TBC: confirm designated contact point/DPO if required by applicable thresholds.]

13. DATA BREACH NOTIFICATION

In the event of a personal data breach affecting your wearable or health data, we will notify the Data Protection Board of India and affected users as required under applicable law.

14. CHANGES TO THIS NOTICE

We may update this notice from time to time to reflect changes in this feature or applicable law. Material changes will be notified in-app or by other reasonable means, and where required, we will seek your fresh consent before continuing to process your data under the updated terms.