Privacy policy

Effective date: [Dec 15, 2025]

This Privacy Policy (“Privacy Policy”) explains how AIR Health Inc. (“AIR Health”, “we”, “us”, or
“our”) collects, uses, stores, and shares information about you when you visit our website, use our mobile application, and access any related online services (collectively, the “Services”).

Please read this Privacy Policy carefully before using the Services. By accessing or using the
Services, you agree to this Privacy Policy, our Terms of Use (available at https://www.airhealth.co/terms-of-service), and all applicable laws, rules, and regulations
(“Applicable Law”). If you do not agree, you must not access or use the Services.

Please read this Privacy Policy carefully before using the Services. By accessing or using the
Services, you agree to this Privacy Policy, our Terms of Use (available at https://www.airhealth.co/terms-of-service), and all applicable laws, rules, and regulations (“Applicable Law”). If you do not agree, you must not access or use the Services.

What we collect

We may collect personal information about you in various ways. The main categories and examples include:

Contact information and profile data
Name, email address, username, password, and any photos or details you choose to add to
your profile.
User-generated information
Information you enter or create in the Services, such as exercise logs, wellness activities, movement history, self-reported symptoms, goals, and notes.
Health information
See “Third-Party Health Information” below.
Payment and transactional data
Information related to purchases or subscriptions made through the Services (e.g., transaction date, product purchased, amount). We do not have access to your full payment card number; payment details are collected and processed by our third-party payment processors under their own terms and privacy policies.
Interactions with AIR Health AI features
If you use our AI-enabled coaching or guidance features (for example, generative AI chat or guidance based on your activity and health data), we may collect and store your inputs and the system’s responses, as described further under “AIR Intelligence & Third-Party Artificial
Intelligence Technology.”
Device and usage information
Technical information about how you access and use the Services, such as device type, operating system, app version, IP address, pages viewed, and the time and date of your visits.
Geolocation data
General region or area from which you access the Services (e.g., city, state, country). We do not collect precise GPS locations unless you explicitly allow it.
Inferences
We may derive or infer information about your preferences, interests, engagement patterns, or
likely needs based on the information we collect and how you use the Services.

We may collect personal information about you in various ways. The main categories and examples include:

Contact information and profile data
Name, email address, username, password, and any photos or details you choose to add to your profile.
User-generated information
Information you enter or create in the Services, such as exercise logs, wellness activities, movement history, self-reported symptoms, goals, and notes.
Health information
See “Third-Party Health Information” below.
Payment and transactional data
Information related to purchases or subscriptions made through the Services (e.g., transaction date, product purchased, amount). We do not have access to your full payment card number; payment details are collected and processed by our third-party payment processors under their own terms and privacy policies.
Interactions with AIR Health AI features
If you use our AI-enabled coaching or guidance features (for example, generative AI chat or guidance based on your activity and health data), we may collect and store your inputs and the system’s responses, as described further under “AIR Intelligence & Third-Party Artificial Intelligence Technology.”
Device and usage information
Technical information about how you access and use the Services, such as device type, operating system, app version, IP address, pages viewed, and the time and date of your visits.
Geolocation data
General region or area from which you access the Services (e.g., city, state, country). We do not collect precise GPS locations unless you explicitly allow it.
Inferences
We may derive or infer information about your preferences, interests, engagement patterns, or likely needs based on the information we collect and how you use the Services.

Third-Party Health Information

With your permission, the Services may connect to third-party applications and services (“Third-Party Applications”), such as Apple Health, Google Fit, wearable devices, lab and testing services, or other health data sources that you authorize.

If you enable these connections, we may import certain health-related information about you,
which can include:

heart rate
sleep duration and quality
movement and exercise activity
step counts and cadence
blood oxygen levels and respiratory rate
height, weight, age, and similar metrics
lab or testing results (for example, blood test results) if you connect applicable services

The health-related data that you authorize us to access from Third-Party Applications, together with any similar data you enter directly into the Services, is called “Health Information” in this Privacy Policy.

Where and how Health Information is stored is described in “Where Your Information Is Stored” below.

How We Collect Your Personal Information

We collect personal information from several sources:

Directly from you
You may provide personal information when you create an account, update your profile, log activities or symptoms, interact with our AI coaching features, contact customer support, respond to surveys, or otherwise communicate with us.
When you authorize connections to Third-Party Applications, Health Information may be imported into the Services. By providing information to us or enabling these connections, you consent to our collection, use, disclosure, processing, and storage of that information consistent with this Privacy Policy.
From Third-Party Applications
If you permit us to access Third-Party Applications, we will import Health Information as allowed by your settings and the third-party’s terms. By default, we only import the categories of data needed to provide or improve the Services you use. You can adjust or revoke these permissions within the Third-Party Applications and/or within the Services.
Automatically through your use of the Services
We may automatically collect certain technical and usage information through cookies, SDKs, analytics tools, log files, and similar technologies when you visit our website or use our mobile application. This may include device identifiers, IP address, browser or app information, and usage patterns.

Where Your Information Is Stored

We use different storage approaches depending on the type of data and the features you enable.

Personal information and user-generated data
Contact information (name, email, login details, profile data) and non-biometric user-generated content (such as logged exercises, goals, and certain activity history) may be stored using secure third-party cloud hosting providers so that your information can sync across devices and support your use of the Services.
Health Information (biometric / sensor data)
Where feasible, imported biometric Health Information (such as heart rate, sleep metrics, and similar data from wearables or Third-Party Applications) is stored and processed locally on your device by default. Certain features, including basic real-time feedback and exercise form checks, may also be processed locally, depending on your device capabilities and settings.
AI and cloud-processed features
If you enable optional AI-powered features (for example, a generative AI coach we may refer to as “AIR Intelligence” or similar), then certain Health Information and usage information may be transmitted to and processed by our secure cloud hosting and AI technology partners in order to generate responses, guidance, and insights. Only the minimum information reasonably necessary to provide the feature is sent for processing. Some data may be temporarily stored
by those providers for security, debugging, or quality assurance, as further described below.
Location of processing
To provide the Services, we store and process your personal information in the United States, where AIR Health is based, and potentially in other countries where our service providers operate. By using the Services or providing information to us, you understand and consent to the transfer of your personal information to, and processing in, the United States and other jurisdictions that may have different data protection laws than your country of residence.

If you reside in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, any transfer of your personal information will be carried out in accordance with
applicable data protection laws, which may include the use of appropriate safeguards such as Standard Contractual Clauses.

We use different storage approaches depending on the type of data and the features you enable.

Personal information and user-generated data
Contact information (name, email, login details, profile data) and non-biometric user-generated content (such as logged exercises, goals, and certain activity history) may be stored using secure third-party cloud hosting providers so that your information can sync across devices and support your use of the Services.
Health Information (biometric / sensor data)
Where feasible, imported biometric Health Information (such as heart rate, sleep metrics, and similar data from wearables or Third-Party Applications) is stored and processed locally on your device by default. Certain features, including basic real-time feedback and exercise form checks, may also be processed locally, depending on your device capabilities and settings.
AI and cloud-processed features
If you enable optional AI-powered features (for example, a generative AI coach we may refer to as “AIR Intelligence” or similar), then certain Health Information and usage information may be transmitted to and processed by our secure cloud hosting and AI technology partners in order to generate responses, guidance, and insights. Only the minimum information reasonably necessary to provide the feature is sent for processing. Some data may be temporarily stored by those providers for security, debugging, or quality assurance, as further described below.
Location of processing
To provide the Services, we store and process your personal information in the United States, where AIR Health is based, and potentially in other countries where our service providers operate. By using the Services or providing information to us, you understand and consent to the transfer of your personal information to, and processing in, the United States and other jurisdictions that may have different data protection laws than your country of residence.

If you reside in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, any transfer of your personal information will be carried out in accordance with applicable data protection laws, which may include the use of appropriate safeguards such as Standard Contractual Clauses.

How We Use Collected Information

We may use your personal information for the following purposes:

To provide and operate the Services
We use personal information and Health Information to create and manage your account, enable exercise and wellness features, personalize your experience, provide real-time or near real-time feedback, and deliver content and tools that support your health and activity goals.
To perform analysis and improve insights
We may analyze Health Information and usage data to help you better understand your activity patterns, progress, and engagement. Where possible, we use de-identified or aggregated data to improve our algorithms, recommendations, and overall Service quality.
To provide and improve customer support
We use your contact information and communications to respond to your inquiries, troubleshoot issues, send important notices about changes to the Services or this Privacy Policy, and improve support processes.
For analytics, research, and product improvement
We may use aggregated and/or de-identified information about how users interact with the
Services to understand performance, identify trends, improve features, and develop new offerings. We may also use information to protect the security and integrity of the Services, detect and prevent fraud or misuse, and comply with applicable laws.
Marketing and communications (subject to your choices)
We may use your contact information to send you product updates, educational content, or promotional communications about AIR Health and related offerings, where permitted by law and your preferences. You can opt out of promotional emails as described under “Your
Choices.
Restrictions on marketing use of Health Information
We do not use Health Information for third-party advertising or cross-context behavioral advertising. Health Information is used only to provide and improve the Services and any AIR Health features you choose to enable.

We may use your personal information for the following purposes:

To provide and operate the Services
We use personal information and Health Information to create and manage your account, enable exercise and wellness features, personalize your experience, provide real-time or near real-time feedback, and deliver content and tools that support your health and activity goals.
To perform analysis and improve insights
We may analyze Health Information and usage data to help you better understand your activity patterns, progress, and engagement. Where possible, we use de-identified or aggregated data to improve our algorithms, recommendations, and overall Service quality.
To provide and improve customer support
We use your contact information and communications to respond to your inquiries, troubleshoot issues, send important notices about changes to the Services or this Privacy Policy, and improve support processes.
For analytics, research, and product improvement
We may use aggregated and/or de-identified information about how users interact with the Services to understand performance, identify trends, improve features, and develop new offerings. We may also use information to protect the security and integrity of the Services, detect and prevent fraud or misuse, and comply with applicable laws.
Marketing and communications (subject to your choices)
We may use your contact information to send you product updates, educational content, or promotional communications about AIR Health and related offerings, where permitted by law and your preferences. You can opt out of promotional emails as described under “Your
Choices.
Restrictions on marketing use of Health Information
We do not use Health Information for third-party advertising or cross-context behavioral advertising. Health Information is used only to provide and improve the Services and any AIR Health features you choose to enable.

To Whom We Share Your Personal Information

We may share your personal information in the following ways:

With service providers
We share information with trusted vendors and contractors who help us operate, maintain, and improve the Services. These may include cloud hosting providers, analytics providers, customer support platforms, email service providers, payment processors, and technology partners.
If you enable AI-powered features (e.g., AIR Intelligence), certain Health Information and other data relevant to generating responses may be shared with third-party AI technology providers and cloud hosting services solely for the purpose of providing those features. We limit this to the minimum information reasonably needed.
With research and development partners
We may share de-identified and/or aggregated information with third parties for research, analytics, and development of new tools or features. Information used for these purposes is intended not to identify you personally, and these partners are subject to confidentiality obligations.
With third parties at your direction
We may share your information with third parties when you ask or consent for us to do so, such as when you connect a Third-Party Application, enroll in a joint offering, or participate in a research or pilot program.
As required by law or to protect rights
We may disclose information to law enforcement, regulators, courts, or other third parties if we
believe disclosure is required by law or reasonably necessary to: (1) comply with legal obligations or valid legal requests; (2) protect our rights, privacy, safety, or property, or that of our users or others; or (3) detect, prevent, or address fraud, security, or technical issues.
In corporate transactions
If AIR Health is involved in a financing, merger, acquisition, reorganization, sale of assets, or similar transaction, your personal information may be transferred as part of that transaction, subject to confidentiality obligations and any applicable legal requirements.

We may share your personal information in the following ways:

With service providers
We share information with trusted vendors and contractors who help us operate, maintain, and improve the Services. These may include cloud hosting providers, analytics providers, customer support platforms, email service providers, payment processors, and technology partners.
If you enable AI-powered features (e.g., AIR Intelligence), certain Health Information and other data relevant to generating responses may be shared with third-party AI technology providers and cloud hosting services solely for the purpose of providing those features. We limit this to the minimum information reasonably needed.
With research and development partners
We may share de-identified and/or aggregated information with third parties for research, analytics, and development of new tools or features. Information used for these purposes is intended not to identify you personally, and these partners are subject to confidentiality obligations.
With third parties at your direction
We may share your information with third parties when you ask or consent for us to do so, such as when you connect a Third-Party Application, enroll in a joint offering, or participate in a research or pilot program.
As required by law or to protect rights
We may disclose information to law enforcement, regulators, courts, or other third parties if we believe disclosure is required by law or reasonably necessary to: (1) comply with legal obligations or valid legal requests; (2) protect our rights, privacy, safety, or property, or that of our users or others; or (3) detect, prevent, or address fraud, security, or technical issues.
In corporate transactions
If AIR Health is involved in a financing, merger, acquisition, reorganization, sale of assets, or similar transaction, your personal information may be transferred as part of that transaction, subject to confidentiality obligations and any applicable legal requirements.

How We Share Your Information (Additional Detail)

In addition to the categories above:

With your consent

We may share information with third parties based on your explicit consent, which may be given through in-app settings, click-through agreements, written permission, or other mechanisms.
With non-affiliated third parties for operational purposes
We may share information with non-affiliated third parties as needed to facilitate your use of the Services, such as internet service providers, data analytics providers, and other vendors that help us operate or secure the Services.
With subsidiaries and affiliates
We may share information with our subsidiaries or affiliates to help provide the Services or develop related services, in accordance with this Privacy Policy.

AIR Intelligence & Third-Party Artificial Intelligence Technology

We may offer an optional AI-enabled feature (for example, referred to as “AIR Intelligence”) designed to provide educational guidance, coaching-style responses, and insights based on your activity data and Health Information.

If you enable this feature:

Health Information you have authorized us to access, including biometric or activity data from Third-Party Applications, may be processed by third-party cloud hosting and AI technology providers to generate responses and insights.
We aim to avoid including directly identifying information in requests sent to AI providers
whenever reasonably possible.
Certain data used to generate AI responses (which may include elements of Health Information) may be temporarily retained by these providers for up to a limited period (for example, up to thirty (30) days) for security monitoring, abuse prevention, and quality assurance before being deleted from their systems.
We may retain a history of your conversations with AIR Intelligence within the Services so that you can review prior interactions and so future responses can incorporate context over time. You may request deletion of your stored conversation history as described below.

Important limitations
AIR Intelligence and other AI features do not provide medical advice, diagnosis, or treatment. Outputs may be inaccurate, incomplete, or not applicable to your situation. You should not rely on any AI-generated content as a substitute for professional medical advice. Always consult a qualified healthcare professional with questions about your health, symptoms, or treatment options.

We Do Not Sell Your Personal Information

We do not sell or rent your personal information. We only share personal information with service providers and partners as described in this Privacy Policy to operate, maintain, and improve the Services, provide partner offerings you choose to use, and run our business.

Third-Party Links and Websites

The Services may contain links to websites, apps, or services operated by third parties (“Third-Party Services”). We do not control and are not responsible for the content, privacy practices, or policies of these Third-Party Services. Your use of Third-Party Services is subject to their own
terms and privacy policies.

Our Content on Third-Party Services

Our Services or content may be hosted, embedded, or distributed through Third-Party Services (for example, app stores, social media, or partner platforms). Your use of such platforms is governed by their own terms and privacy policies. Any information you share directly with those
services is subject to their practices.

Some of these Third-Party Services may use cookies or other tracking technologies (including for remarketing or interest-based advertising) in accordance with their own policies. Please review their privacy notices to understand how they collect and use your information.

Your Choices

You have certain choices regarding how we collect and use your information:

Access and modification of personal information
You may review and update certain account and profile information directly in the app or via our website. If you need additional assistance, you can contact us at info@airhealth.co (or another contact email you choose to configure). We will make good-faith efforts to update our active records as quickly as reasonably possible.
Marketing communications
You may opt out of promotional emails by following the unsubscribe instructions in those messages or by contacting us at info@airhealth.co. We may still send non-promotional communications relating to your account or the Services (for example, administrative or
transactional emails).
AI features (AIR Intelligence)
You can choose whether to enable and use AIR Intelligence or similar AI features. We will only
send relevant Health Information to AI providers when you actively use those features. You can stop using the AI features at any time, and where available, you may disable them in your settings. Disabling the feature will stop new data from being sent, but will not necessarily
remove or retract information already processed by third-party providers.
Cookies and tracking technologies
Most browsers are set to accept cookies by default. You can usually choose to remove or reject browser cookies through your browser settings. Note that disabling cookies may affect the functionality and availability of some parts of the Services.
Ad choices and interest-based advertising
Some third-party advertising providers may collect information about your online activities over time and across different websites and apps to provide interest-based ads. You can learn more about such practices and how to opt out at www.aboutads.info and www.aboutads.info/choices, and via tools such as the AppChoices app (www.aboutads.info/appchoices). These choices are typically browser- or device-specific.
Not providing personal information
You may choose not to provide certain personal information; however, if you do, some features of the Services may not be available or may not function properly.

You have certain choices regarding how we collect and use your information:

Access and modification of personal information
You may review and update certain account and profile information directly in the app or via our website. If you need additional assistance, you can contact us at info@airhealth.co (or another contact email you choose to configure). We will make good-faith efforts to update our active records as quickly as reasonably possible.
Marketing communications
You may opt out of promotional emails by following the unsubscribe instructions in those messages or by contacting us at info@airhealth.co. We may still send non-promotional communications relating to your account or the Services (for example, administrative or transactional emails).
AI features (AIR Intelligence)
You can choose whether to enable and use AIR Intelligence or similar AI features. We will only send relevant Health Information to AI providers when you actively use those features. You can stop using the AI features at any time, and where available, you may disable them in your settings. Disabling the feature will stop new data from being sent, but will not necessarily remove or retract information already processed by third-party providers.
Cookies and tracking technologies
Most browsers are set to accept cookies by default. You can usually choose to remove or reject browser cookies through your browser settings. Note that disabling cookies may affect the functionality and availability of some parts of the Services.
Ad choices and interest-based advertising
Some third-party advertising providers may collect information about your online activities over time and across different websites and apps to provide interest-based ads. You can learn more about such practices and how to opt out at www.aboutads.info and www.aboutads.info/choices, and via tools such as the AppChoices app (www.aboutads.info/appchoices). These choices are typically browser- or device-specific.
Not providing personal information
You may choose not to provide certain personal information; however, if you do, some features of the Services may not be available or may not function properly.

Information Security

We use commercially reasonable technical, administrative, and physical safeguards designed to protect your personal information from unauthorized access, use, or disclosure. However, no system can be guaranteed to be completely secure. You are responsible for maintaining the
confidentiality of your account credentials and for any activity that occurs under your account.

How Long We Keep Your Information

We retain personal information for as long as reasonably necessary to:

provide the Services and maintain your account
fulfill the purposes outlined in this Privacy Policy
comply with our legal and regulatory obligations
resolve disputes and enforce our agreements

We may also retain aggregated or de-identified information that does not identify you for analytics, research, or business purposes.

Our Services Are Not Intended for Children

The Services are not directed to or intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have collected such information, we will take reasonable steps to delete it. If you believe we may have collected personal information from a child, please contact us at info@airhealth.co.

U.S. State-Specific Privacy Information

If you reside in certain U.S. states, you may have additional rights under state privacy laws (for example, in California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia).
These rights may include:

the right to know what categories of personal information we collect and from what sources
the right to access specific pieces of personal information we hold about you
the right to request deletion of certain personal information
the right to request correction of inaccurate personal information
the right to opt out of certain processing, such as “sale” or “sharing” for targeted advertising or certain profiling activities
the right to appeal if we deny your request

For the 12 months preceding the Last Updated date of this Privacy Policy, AIR Health has not sold personal information as defined under applicable state law.

You have the right to exercise these choices without being discriminated against for doing so.

Exercising Your Rights (If Applicable)

To exercise your privacy rights under applicable U.S. state law, you may:

Contact us at info@airhealth.co to request access to, correction of, or deletion of personal information collected about you through the Services.
Use any in-app tools or settings we may provide for managing your data, where available

Verification
We may need to verify your identity before fulfilling your request. This may involve asking you to confirm information we already have on file or providing limited additional information. If you authorize an agent to make a request on your behalf, we may ask for proof that the agent is
authorized, and we may require you to verify your identity directly with us as well.

Please note that we may deny or limit certain requests in accordance with applicable law (for example, when we are legally required to retain information or when we cannot verify your identity).

To exercise your privacy rights under applicable U.S. state law, you may:

Contact us at info@airhealth.co to request access to, correction of, or deletion of personal information collected about you through the Services.
Use any in-app tools or settings we may provide for managing your data, where available

Verification
We may need to verify your identity before fulfilling your request. This may involve asking you to confirm information we already have on file or providing limited additional information. If you authorize an agent to make a request on your behalf, we may ask for proof that the agent is authorized, and we may require you to verify your identity directly with us as well.

Please note that we may deny or limit certain requests in accordance with applicable law (for example, when we are legally required to retain information or when we cannot verify your identity).

California “Shine the Light” Notice

If you are a California resident, you may request information once per year about how we share certain categories of personal information with third parties for their own direct marketing purposes, if applicable. To make such a request, please contact us at info@airhealth.co with “Shine the Light Request” in the subject line.

“Do Not Track” (DNT)

Some browsers offer a “Do Not Track” (DNT) setting that signals to websites that you do not want to be tracked. The Services do not currently respond to DNT signals. Third-party services may have their own DNT responses. You should review their policies and your browser settings
for more information.

Information for European Economic Area (EEA), UK, and Swiss Residents

If you are located in the EEA, UK, or Switzerland, you have certain rights and protections under applicable data protection laws, including the GDPR.

Legal bases for processing
We will only process your personal information when we have a lawful basis to do so, including:

your consent (for example, when you enable certain features or sign up for marketing communications)
contractual necessity (to provide the Services and fulfill our agreement with you

Your rights
You may have the right to:

request access to the personal data we hold about you
request correction of inaccurate or incomplete data
request deletion of your personal data in certain circumstances
withdraw consent where processing is based on consent (without affecting the lawfulness of processing before the withdrawal)
request data portability in a structured, commonly used, machine-readable format
object to certain processing, including direct marketing
request restriction of processing under certain conditions
lodge a complaint with your local data protection authority

To exercise these rights, you may contact us at info@airhealth.co. We may need to verify your identity before acting on your request.

International transfers
If we transfer your personal data outside of the EEA, UK, or Switzerland, we will rely on appropriate safeguards (such as Standard Contractual Clauses) as required by applicable law.

You may request more information about these safeguards by contacting us.

If you are located in the EEA, UK, or Switzerland, you have certain rights and protections under applicable data protection laws, including the GDPR.

Legal bases for processing
We will only process your personal information when we have a lawful basis to do so, including:

your consent (for example, when you enable certain features or sign up for marketing communications)
contractual necessity (to provide the Services and fulfill our agreement with you

Your rights
You may have the right to:

request access to the personal data we hold about you
request correction of inaccurate or incomplete data
request deletion of your personal data in certain circumstances
withdraw consent where processing is based on consent (without affecting the lawfulness of processing before the withdrawal)
request data portability in a structured, commonly used, machine-readable format
object to certain processing, including direct marketing
request restriction of processing under certain conditions
lodge a complaint with your local data protection authority

To exercise these rights, you may contact us at info@airhealth.co. We may need to verify your identity before acting on your request.

Usage and Deletion of Personal Information

You may request information about the personal information we have collected, used, and disclosed about you, as well as the categories of third parties to whom it has been disclosed.
You may also request deletion of your personal information, subject to certain exceptions, including when the information is needed to:

complete a transaction or provide a service you requested
• detect or repair errors that impair existing functionality
• protect against fraud, illegal activity, or security incidents
• comply with legal obligations

If we delete your personal information, certain aspects of the Services may no longer be available or may not function as intended.

To submit a request regarding usage or deletion, contact us at info@airhealth.co.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last Updated” date at the top of this page. Your continued use of the Services after any changes become effective means you accept the updated Privacy Policy, subject to applicable law. We encourage you to review this Privacy Policy periodically.

How to Contact Us

If you have questions or concerns about this Privacy Policy or our privacy practices, you can contact us at:
Email: info@airhealth.co