ACCELIOS Consumer Health Data Privacy Notice

ACCELIOS CONSUMER HEALTH DATA PRIVACY NOTICE Document Version: 1.0 Provider: Alexander Cruz Limcuando Jr., doing business as ACCELIOS Contact: aj@accelios.ai Effective Date: Recorded automatically when this document version is published General Privacy Policy: /privacy 1. CONSUMER HEALTH DATA ACCELIOS MAY COLLECT ACCELIOS may collect or derive the following consumer health data when you choose to provide it or use related features: • Fitness goals, exercise history, workout plans, and completed workouts • Calorie, macronutrient, food, and nutrition information • Body weight, measurements, body-composition information, and progress trends • Progress photos and before-and-after comparisons • Sleep, recovery, soreness, energy, stress, and habit information • Injuries, limitations, pregnancy or postpartum status, medications, allergies, intolerances, or other health-related information you choose to disclose • Messages, check-ins, Daily Logs, coaching notes, and Game Plans that reveal or infer physical or mental health status • Information inferred from the categories above, including trends, summaries, readiness indicators, and AI-assisted recommendations 2. WHY ACCELIOS COLLECTS AND USES CONSUMER HEALTH DATA ACCELIOS may collect and use consumer health data to: • Provide fitness, nutrition, habit, and wellness coaching • Personalize workouts, goals, guidance, and Game Plans • Track progress and display trends • Support check-ins and coaching communications • Operate progress-photo and reporting features • Identify possible inconsistencies or concerns for review • Generate AI-assisted summaries and recommendations • Maintain security, prevent misuse, and troubleshoot technical issues • Comply with legal obligations and establish or defend legal rights • Carry out another purpose disclosed at collection and authorized by you ACCELIOS does not use consumer health data for targeted advertising. 3. SOURCES OF CONSUMER HEALTH DATA ACCELIOS may collect consumer health data: • Directly from you • From coaches or administrators based on your communications or use of the Services • From content you upload • From services or integrations you choose to connect • From automated analysis or inferences based on the information above 4. WHO MAY RECEIVE CONSUMER HEALTH DATA ACCELIOS may disclose consumer health data to: • Authorized ACCELIOS coaches and administrators who need it to provide or support the Services • Cloud hosting, database, storage, authentication, security, and backup providers • AI service providers used to generate summaries or recommendations • Email, support, logging, and technical service providers when needed to operate the Services • Legal, accounting, insurance, or professional advisors • Governmental or legal recipients when required by law • A buyer or successor in a business transaction, subject to applicable law • Other recipients at your direction or with your consent 5. SALE OF CONSUMER HEALTH DATA ACCELIOS does not sell consumer health data or exchange it for money or other valuable consideration. ACCELIOS will not begin selling consumer health data without updating this notice and obtaining any authorization required by law. 6. MEMBER CONSENT During onboarding, ACCELIOS requests the following affirmative consent: “I consent to ACCELIOS collecting and processing the fitness, nutrition, body measurement, progress-photo, recovery, and related wellness information I choose to provide so ACCELIOS can deliver and personalize the Services as described in the Consumer Health Data Privacy Notice.” This consent does not authorize: • Sale of consumer health data • Targeted advertising using consumer health data • Blanket promotional use of progress photos or testimonials • Uses materially different from those disclosed here Separate consent or authorization should be requested where required for a materially different purpose. 7. WITHDRAWING CONSENT You may withdraw consent by emailing aj@accelios.ai with the subject “Withdraw Health Data Consent.” Withdrawal applies prospectively. ACCELIOS may continue retaining or processing information where permitted or required for legal compliance, security, fraud prevention, transactions, signed agreements, disputes, or other lawful grounds. Because consumer health data is central to personalized coaching, withdrawing consent may limit or prevent ACCELIOS from continuing to provide some or all Services. 8. YOUR RIGHTS Depending on applicable law, you may have rights to: • Confirm whether ACCELIOS collects, shares, or sells consumer health data • Access consumer health data • Obtain information about recipients • Correct inaccurate consumer health data • Delete consumer health data • Withdraw consent • Appeal a denied request • Obtain a portable copy where required Submit requests to aj@accelios.ai with the subject “Consumer Health Data Request.” 9. DELETION Subject to applicable exceptions, ACCELIOS will delete consumer health data from active systems and direct applicable processors to delete it when required. Deletion from backups may occur through ordinary backup rotation. ACCELIOS may retain limited information where permitted or required for legal compliance, security, fraud prevention, signed agreements, transactions, disputes, or legal claims. 10. SECURITY ACCELIOS uses safeguards designed to protect consumer health data, including access controls, authentication, encryption in transit, logging, and restricted administrative access. No system is completely secure. 11. CHANGES The Effective Date should be recorded when this version is published. If ACCELIOS materially changes the categories of consumer health data, purposes, or recipients, it should update this notice and obtain new consent where required. 12. CONTACT Alexander Cruz Limcuando Jr., doing business as ACCELIOS Email: aj@accelios.ai