SynchNeuro Cardiometabolic Advisor Privacy Policy

I. Who this policy applies to

The App is available only to individuals enrolled in the Study. It is distributed through limited-access channels and is not intended for use by the general public.

II. Personal information we collect

We collect personal information that you provide to us, personal information we collect automatically when you use the App, and personal information from third-party sources, as described below.

A. Personal information you provide to us directly

We may collect personal information that you provide to us.

1. Wearable sensor data

We collect data from study devices, including:

• EEG (electroencephalogram) signals collected by the SynchNeuro behind-ear EEG sensor
• Accelerometer data from the SynchNeuro sensor
• Continuous glucose monitor (CGM) data from the Stelo CGM
• Heart rate and physiological monitoring data from the Polar Verity Sense monitor
• Related device-generated measurements and derived metrics

2. Health platform data

If you choose to grant permission, we may read selected health information from Apple Health or Android Health Connect, including:

• Blood glucose
• Sleep data
• Heart rate
• Resting heart rate
• Heart rate variability
• Steps
• Blood pressure
• Body weight
• Cardiorespiratory fitness (VO₂ max)
• Workout information
• Active energy expenditure

We only read data that you authorize and we do not write to, modify, or delete information in Apple Health or Android Health Connect.

3. Personal information you provide through the App

We may collect information you provide through the App, including:

• Demographic information
• Baseline health and lifestyle questionnaires
• Daily surveys regarding stress, sleep, lifestyle, and wellness
• Meal logs and food-related information
• Physical activity logs
• Active task results (such as meditation or alertness tasks)
• Device check-ins and study feedback
• Enrollment and consent-related information

4. Optional food photos

If you choose to log meals using photographs, the image may be transmitted to January AI for food recognition and nutritional analysis. Meal photos are used solely to perform nutritional analysis and are not retained in the Study database after processing.

B. Personal information collected automatically

We may collect personal information automatically when you use the App.

1. Device information

We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, Internet service provider, and location information (including, as applicable, an approximate location derived from the IP address and precise geo-location information).

2. Usage information

We may collect personal information about your use of the App, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the App.

3. Cookie notice (and other technologies)

We, as well as third parties, may use cookies, pixel tags, and other technologies ("Technologies") to automatically collect personal information through your use of the App.

• Cookies. Cookies are small text files stored in device browsers.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the App that collects personal information about use of or engagement with the App. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded.

C. Personal information collected from third parties

We may collect personal information about you from third parties. For example, if you access the App using a third-party website, application, service, products, or technology (each a "Third-Party Service"), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, we may collect health information from Apple Health or Android Health Connect if you choose to grant us permission.

III. How we use personal information

We use personal information for a variety of business purposes, including to provide the App and conduct the Study, for administrative purposes, and to provide you with marketing materials, as described below.

A. Provide the App and conduct the Study

We use personal information to provide the App and conduct the Study, such as:

• Operating and supporting the App
• Conducting the Study
• Analyzing relationships among EEG signals, glucose measurements, physiological signals, behavioral information, and participant-reported information
• Improving participant experience and study operations
• Supporting future scientific, clinical, regulatory, research, product development, and commercial activities consistent with participant consent

B. Improve the App and develop new products and services

We use personal information to improve the App and the Study, and to develop new products and services, such as:

• Developing, validating, testing, and improving algorithms, machine learning models, artificial intelligence systems, and other computational methods; and
• Improving, upgrading, or enhancing the App and the Study.

C. Operate our business

We use personal information to operate our business, such as:

• Carrying out analytics;
• Creating de-identified and/or aggregated information. Where feasible, personal identifiers are removed and replaced with study codes before research analysis;
• Enforcing our agreements and policies; and
• Carrying out activities that are required to comply with our legal obligations.

D. Marketing

We may use personal information in connection with our marketing activities including to tailor and provide you with marketing communications. For clarity, we do not use Study data for advertising purposes.

E. Future research, artificial intelligence, and commercial use

As described in the informed consent form, coded or de-identified data collected during the Study may be used in future research projects that are not specifically known at the time of enrollment. This may include:

• Development and validation of machine learning and artificial intelligence systems
• Development of large-scale computational or "foundation" models
• Research involving brain signals, physiological signals, behavioral information, and health-related information
• Product development and improvement
• Clinical decision-support technologies
• Wellness applications
• Regulatory and scientific activities

Collected coded data, including processed signals, extracted features, statistical representations, embeddings, model inputs and outputs, trained algorithms, model weights, and other derived information, may be used by SynchNeuro and may be shared with, licensed to, transferred to, sold to, or otherwise provided to third parties for lawful research, development, validation, regulatory, artificial intelligence training, commercial, or business purposes.

Third parties may combine coded data with other data sources and may develop commercial products or services using such information. SynchNeuro and its collaborators may receive financial or commercial benefit from these activities.

Participants will not receive ownership rights, intellectual property rights, royalties, revenue sharing, or other compensation arising from future discoveries, algorithms, artificial intelligence systems, products, services, or commercial uses developed using Study data.

IV. How we share personal information

We may share information with third parties for a variety of business purposes, including to provide the App and conduct the Study, to protect us or others, or in connection with a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to provide the App and conduct the Study

1. Study personnel

We may share personal information with the Principal Investigator and Study staff.

2. Service providers and contractors

We may share personal information with service providers that assist us with provision of the App and the Study. This may include, but is not limited to, service providers that provide us with hosting services, customer service, AI or machine learning services, analytics, marketing services, IT support, and related services. Some of the service providers we may use include:

• Amazon Web Services (AWS) for cloud hosting and storage
• January AI for meal-photo and nutrition analysis
• Curavit or other clinical research organizations assisting with study operations
• Vendors providing technical, analytics, regulatory, or operational support

3. Regulatory and oversight bodies

We may share personal information with regulatory and oversight bodies, which may include:

• Institutional Review Boards (IRBs)
• Government agencies, including the U.S. Food and Drug Administration (FDA), Office for Human Research Protections (OHRP), and other regulatory authorities as required by law

4. Research, academic, and commercial partners

As described in the informed consent form, we may share coded or de-identified data with academic collaborators, research institutions, commercial organizations, data partners, investors, and other third parties (collectively, "Business Partners") for research, development, validation, artificial intelligence training, commercial, regulatory, or business purposes.

Once your personal information is shared with our Business Partner, it will also be subject to our Business Partner's privacy policy. We are not responsible for the processing of personal information by our Business Partners.

5. Affiliates

We may share your personal information with our corporate affiliates.

B. Disclosures to protect us or others

We may share your personal information and related information with external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement requests, national security requests, or other government requests; comply with legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual unauthorized or illegal activity.

C. Disclosure in the event of merger, sale, or other asset transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be shared, sold, or transferred as part of such a transaction.

V. Data retention

We may retain coded Study data for up to 30 years to support research, regulatory, legal, scientific, artificial intelligence development, and commercial purposes.

VI. Withdrawal from the Study

Participation is voluntary. You may withdraw from the Study at any time by contacting us as described in the "Contact Us" section below.

Withdrawal will stop future collection of Study information where feasible. However:

• Information collected before withdrawal may continue to be retained and used.
• Previously collected information may continue to be analyzed, combined with other data, incorporated into artificial intelligence systems, algorithms, and research datasets, and used for research and commercial purposes.
• Once data has been incorporated into analyses, aggregated datasets, publications, trained models, or algorithms, it may not be possible to locate, remove, or delete it.

VII. Your privacy choices

A. Email communications

If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will not be able to opt out of certain communications (e.g., communications regarding the App or Study, or updates to this Privacy Policy).

B. Health data permissions

You control which Apple Health or Android Health Connect data types the App can access. You may change or revoke permissions at any time through your device settings.

C. Mobile devices

We may send you push notifications through our mobile application. You may manage most App notifications through your device settings. Certain study-related reminders may be important for participation and data collection. To request deletion of your account, please use the standard deletion functionality available via the App or contact us using the information set forth in "Contact Us" below.

D. "Do Not Track"

Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

E. Cookies

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the App may not work properly.

Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt out of certain tracking on some mobile applications by following the instructions for Android, iOS, and other mobile operating systems.

VIII. International transfers of personal information

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

IX. Children's privacy

The App is not directed to children under 13 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe that your child has uploaded personal information to the App in violation of applicable law, you may contact us as described in the "Contact Us" section below.

X. Changes to this privacy policy

We may update this Privacy Policy from time to time in our sole discretion. If we do, we'll let you know by posting the updated Privacy Policy on our App and revising the "Last Updated" date above. Material changes will be communicated as required by applicable law, Study procedures, or IRB requirements.

XI. Contact us

Study Sponsor

SynchNeuro, Inc.
Emily Mirro, President
support@synchneuro.com

Institutional Review Board (IRB)

WCG IRB
Phone: 855-818-2289
Email: clientcare@wcgclinical.com

Annex A — Supplemental Consumer Health Data Privacy Statement

This Supplemental Consumer Health Data Privacy Statement ("Consumer Health Data Privacy Statement") supplements our Privacy Policy.

This Supplemental Consumer Health Data Privacy Statement only applies to personal information we process that is "consumer health data" subject to the Connecticut Data Privacy Act, as amended ("CTDPA"), Washington My Health My Data Act ("MHMDA"), Nevada's Consumer Health Data Privacy Law ("NVCHDPL"), or other states with consumer health data privacy laws (as applicable).

Terms used in this Supplemental Consumer Health Data Privacy Statement that are defined in MHMDA, NVCHDPL, or CTDPA will have the meaning set forth in those laws to the extent such laws are applicable.

Under the MHMDA, "consumer health data" is defined as "personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status."

Under NVCHDPL, "consumer health data" is defined as "personally identifiable information that is linked or reasonably capable of being linked to a consumer and that a regulated entity uses to identify the past, present or future health status of the consumer."

Under CTDPA, "consumer health data" is defined as "any personal data that a controller uses to identify a consumer's physical or mental health condition or diagnosis, and includes, but is not limited to, gender-affirming health data and reproductive or sexual health data."

Because consumer health data is defined very broadly, many of the categories of personal information that we collect under our Privacy Policy may also be considered consumer health data. Examples of consumer health data that you may provide to us, or that we may otherwise collect, may include:

• Information that could identify your attempt to seek health care services or information, including services that allow you to assess, measure, improve, or learn about your or another person's health. For example, we collect your search queries on the Sites, which may include queries or other information concerning nutrition, wellness, fitness, medical conditions, or other health-related topics.
• Information about your health-related conditions, symptoms, status, diagnoses, disease, testing, or treatments.
• Information about social, psychological, behavioral, and medical interventions.
• Information about use or purchase of prescribed medication.
• Information about measurements of bodily functions, vital signs, symptoms, or characteristics.
• Information about diagnoses or diagnostic testing, treatment, or medication.
• Information about surgeries or other health-related procedures.
• Reproductive or sexual health information.
• Information about gender-affirming care.
• Biometric information.
• Genetic data.
• Information about your access to healthcare, including precise location information that could reasonably indicate an attempt to acquire or receive health services or supplies; or
• Information processed to associate or identify an individual with the data listed above that is derived or extrapolated from non-health information.
• Information related to the precise (geo)location information of a consumer used to indicate an attempt by a consumer to receive health care services or products.
• Other information that may be used to infer or derive data related to the above or other consumer health data.

We collect consumer health data that you provide to us, consumer health data we collect automatically when you use the App, and consumer health data from third-party sources, as described in our Privacy Policy and above.

We collect and use consumer health data for the purposes and in the manner described in the "How We Use Personal Information" section of our Privacy Policy.

Primarily, we collect and use consumer health data as reasonably necessary to provide you with the App or Study you have authorized. This may include operating the App and its features, personalization of certain App features, ensuring the secure and reliable operation of the App and the systems that support them, troubleshooting and improving the App, and other essential business operations that support the provision of the App or Study (such as analyzing our performance and meeting our legal obligations).

We may also use consumer health data for other purposes for which we give you choices and/or obtain your consent as required by law.

We may share each of the categories of consumer health data described above for the purposes described above and in the "How We Share Personal Information" section of our Privacy Policy.

We only share or disclose your consumer health data as needed to provide you with the App or conduct the Study, or with your explicit consent. We may share or disclose any or all the above categories of consumer health data to the following entities, who shall use the data only as permitted for the purposes set forth above, and within the bounds of our contracts with them:

• Business Collaborators
• Product co-promotion partners
• Product co-development partners
• Social Media Companies and Platforms
• Service Providers (including those hosting or analyzing data on our behalf, those assisting with fraud prevention, those assisting in program administration, those assisting in incident management and reporting, those administering our call center and websites, and those who assist with our information technology and security programs)
• Authorized/legal representatives, family members, and caregivers
• Third parties (including those with whom SynchNeuro has joint marketing and similar arrangements, those who provide marketing and data analytics services, those who provide program enrollment or product fulfillment, other third parties as necessary to provide App or conduct the Study, or where required by law)
• SynchNeuro lawyers, auditors, and consultants
• Legal and regulatory bodies

In addition, we may share or disclose consumer health data as permitted or required by law, such as (i) to an acquiring organization if we are involved in a sale or a transfer of our business, (ii) as needed to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, (iii) in situations that may involve violations of our terms of use or other rules, (iv) to protect our rights and the rights and safety of others, (v) as needed to support external auditing, compliance and corporate governance functions, (vi) as needed to preserve the integrity or security of our systems, or (vii) to investigate, report, or prosecute those responsible for any action that is illegal under applicable state or federal law.

The CTDPA, MHMDA, and NVCHDPL provide consumers with certain rights with respect to consumer health data.

Under MHMDA, consumers have the right to: (i) confirm whether SynchNeuro is collecting, sharing, or selling consumer health data and to access such data; (ii) withdraw consent from SynchNeuro's collection and sharing of consumer health data; and (iii) request that SynchNeuro delete consumer health data.

Under NVCHDPL, consumers have the right to: (i) confirm whether SynchNeuro is collecting, sharing or selling consumer health data; (ii) have SynchNeuro provide the consumer with a list of all third parties with whom SynchNeuro has shared consumer health data relating to the consumer or to whom SynchNeuro has sold such consumer health data; (iii) request that SynchNeuro cease collecting, sharing, or selling consumer health data relating to the consumer; and (iv) request that SynchNeuro delete consumer health data.

Under CTDPA, SynchNeuro is required to obtain consumer consent prior to selling or offering to sell, consumer health data. Consumers have the right to: (i) confirm whether SynchNeuro is collecting or sharing consumer health data; (ii) have SynchNeuro provide the categories of consumer health data that it shares with third parties and the categories of third parties with which it shares consumer health data; and (iii) withdraw consent from SynchNeuro's selling of consumer health data.

The rights afforded to consumers under CTDPA, MHMDA, and NVCHDPL are subject to certain exceptions.

Subject to certain legal limitations and exceptions, you have the following rights with respect to any consumer health data we may collect about you:

• The right to confirm whether we are collecting, sharing, or selling your consumer health data and to access such data, including to receive a list of affiliates or specific third parties with whom we have shared or sold your information, along with contact information such as an active email address for each third party;
• The right to review and request corrections to your consumer health data;
• The right to withdraw consent from our collection or sharing of your consumer health data; and
• The right to request that we delete your consumer health data.

You may submit a request pursuant to any of these rights by contacting us as described in the "Contact Us" section.

SynchNeuro will not discriminate against you for exercising any of your rights. We will make reasonable efforts to respond promptly to your requests in accordance with applicable laws. Please allow 45 days for a response. We may, after receiving your request, require additional information from you to authenticate your request and verify your identity. Please be aware that we may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so. If we deny your request, you have the right to appeal that denial by contacting us as described in the "Contact Us" section. We will process and respond to your appeal within the time permitted by applicable law.

If you are a Washington resident and your appeal is unsuccessful, you may file a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

We may update this Consumer Health Data Privacy Statement from time to time. When we do update it, for your convenience, we will make the updated statement available on this page. Our intention is to use consumer health data in accordance with the Consumer Health Data Privacy Statement in place at the time the consumer health data was collected.