ACCELIOS Privacy Policy

ACCELIOS PRIVACY POLICY 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 Last Updated: Recorded automatically when this document version is published Terms of Service: /terms Consumer Health Data Privacy Notice: /consumer-health-data 1. SCOPE This Privacy Policy explains how ACCELIOS collects, uses, discloses, retains, and protects personal information when you use the ACCELIOS website, application, coaching services, communications, and related features (collectively, the “Services”). Fitness, nutrition, body measurement, progress-photo, recovery, and related wellness information is also addressed in the separate ACCELIOS Consumer Health Data Privacy Notice. 2. INFORMATION ACCELIOS COLLECTS ACCELIOS may collect: • Account and contact information, including name, email, login records, account role, access status, preferences, and support communications. • Subscription and transaction information, including plan, billing interval, access status, payment dates, transaction identifiers, refunds, cancellations, and disputes. • Fitness and wellness information, including goals, training history, workouts, nutrition logs, calories, macronutrients, food entries, body weight, measurements, recovery, sleep, energy, soreness, stress, habits, injuries, limitations, pregnancy or postpartum information, medications, allergies, intolerances, progress photos, Daily Logs, Game Plans, coaching notes, and related messages. • Communications and content, including messages, files, feedback, testimonials, and uploaded media. • Device, usage, and security information, including IP address, browser and device type, operating system, app interactions, authentication records, error logs, approximate location derived from IP address, and fraud-prevention signals. • Inferences and automated outputs, including patterns, summaries, readiness indicators, progress trends, and AI-assisted recommendations. Some information may qualify as sensitive personal information or consumer health data under applicable law. 3. SOURCES OF INFORMATION ACCELIOS may collect information directly from you; from coaches or administrators; automatically from your device or use of the Services; from payment, authentication, email, hosting, analytics, security, and support providers; from integrations you choose to connect; and from public sources where permitted by law. 4. HOW ACCELIOS USES INFORMATION ACCELIOS may use information to: • Create, authenticate, secure, and administer accounts. • Provide and personalize coaching, workouts, nutrition guidance, progress tracking, Daily Logs, progress photos, reports, and Game Plans. • Process subscriptions, payments, refunds, cancellations, and access status. • Communicate about accounts, coaching, service changes, security, and support. • Generate AI-assisted summaries, patterns, and recommendations. • Detect fraud, abuse, security incidents, and technical errors. • Maintain, analyze, debug, and improve the Services. • Enforce agreements and protect legal rights. • Comply with legal, regulatory, tax, accounting, and reporting obligations. • Carry out other purposes disclosed at collection or authorized by you. ACCELIOS does not use consumer health data for targeted advertising. 5. ARTIFICIAL INTELLIGENCE AND AUTOMATED PROCESSING ACCELIOS may use artificial intelligence and automated systems to organize member information, identify patterns, prepare summaries, and help generate Game Plans or recommendations. Automated output may be inaccurate, incomplete, or inappropriate. ACCELIOS does not use AI output as medical diagnosis or treatment. ACCELIOS evaluates the data-use, retention, and security practices of artificial-intelligence service providers used to operate the Services. 6. HOW ACCELIOS DISCLOSES INFORMATION ACCELIOS may disclose information to: • Service providers for cloud hosting, database, storage, authentication, payments, email, AI processing, analytics, logging, security, support, nutrition data, and professional services. • Authorized coaches and administrators who need information to provide the Services. • Legal and safety recipients when reasonably necessary to comply with law, protect rights or safety, investigate misuse, or enforce agreements. • Parties involved in a financing, merger, acquisition, restructuring, sale of assets, or similar transaction, subject to applicable law. • Other recipients at your direction or with your consent. 7. SALE, SHARING, AND TARGETED ADVERTISING ACCELIOS does not sell personal information or consumer health data for money or other valuable consideration. ACCELIOS does not share personal information for cross-context behavioral advertising and does not use consumer health data for targeted advertising. If these practices change, ACCELIOS must update this policy and implement legally required notice, consent, or opt-out controls before the change takes effect. 8. CONSUMER HEALTH DATA Fitness, nutrition, body measurement, progress-photo, recovery, and related information may qualify as consumer health data. The separate ACCELIOS Consumer Health Data Privacy Notice explains the categories collected, purposes, sources, recipients, consent, rights, withdrawal, and deletion practices. 9. DATA RETENTION ACCELIOS retains information only as long as reasonably necessary for the purposes described in this policy, including legal, security, dispute, tax, accounting, and backup requirements. Intended criteria: • Account and profile information: while active and for up to three years after closure unless longer retention is required. • Coaching, workout, nutrition, progress, and wellness records: while needed to provide the Services and until deletion or closure, subject to legal and backup periods. • Progress photos: until deleted, account closure, or a valid deletion request, subject to legal holds and backup rotation. • Signed agreements and consent records: at least seven years after the relationship ends, or longer where reasonably needed to establish or defend legal rights. • Billing records: generally seven years. • Security and system logs: generally 12 to 24 months unless needed longer. • Backups: ordinarily overwritten within 90 days unless preserved for security or legal reasons. 10. SECURITY ACCELIOS uses safeguards designed to protect information, including access controls, encryption in transit, authentication controls, logging, backups, and restricted administrative access. No system is completely secure. 11. PRIVACY RIGHTS Depending on where you live and applicable law, you may have rights to access, correct, delete, obtain a portable copy, withdraw consent, opt out of certain uses, appeal a denied request, and avoid unlawful discrimination for exercising privacy rights. To submit a request, email aj@accelios.ai with the subject “Privacy Request.” ACCELIOS may verify your identity. Certain information may be retained where permitted or required by law. 12. CALIFORNIA PRIVACY NOTICE Where the California Consumer Privacy Act applies, California residents may have rights to know, access, correct, delete, and obtain information about collection, use, disclosure, sale, or sharing. ACCELIOS does not sell personal information and does not share personal information for cross-context behavioral advertising. A concise Notice at Collection should be displayed at or before personal information is collected and should link to this Privacy Policy. 13. OTHER U.S. STATE RIGHTS Residents of certain states may have additional rights regarding personal information or consumer health data. ACCELIOS will honor applicable rights and provide appeal or consent mechanisms where required. 14. CHILDREN ACCELIOS is intended for adults age 18 and older. ACCELIOS does not knowingly permit minors to use the adult onboarding process. 15. THIRD-PARTY SERVICES The Services may link to or depend on third-party services. Their privacy practices are governed by their own policies. 16. CHANGES TO THIS POLICY ACCELIOS may update this policy. The Effective Date and Last Updated date should be recorded automatically when a new version is published. Material changes may require renewed acknowledgment or consent. 17. CONTACT Alexander Cruz Limcuando Jr., doing business as ACCELIOS Email: aj@accelios.ai