Last Revised: 13 September 2026

This privacy notice for iWel Health and iWel CGM (“we,” “us,” or “our”) describes
how and why we might collect, store, use, and/or share (“process”) your
information when you use our services (“Services”), such as when you:

• Download and use our applications, or any other application of ours that links
  to this privacy notice.
• Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this privacy notice will help you understand your
privacy rights and choices. If you do not agree with our policies and practices,
please do not use our Services. If you still have any questions or concerns,
please contact us at support@iwelcgm.com.

SUMMARY

What personal information do we process?
When you visit, use, or navigate our Services, we may process personal
information depending on how you interact with us and the Services, the choices
you make, and the products and features you use.

Health and fitness data (Android Health Connect): With your explicit permission,
our mobile app reads your daily step count from Android Health Connect.

Bluetooth: Our mobile app uses Bluetooth to connect to your continuous glucose
monitoring (CGM) sensor and related devices. On older Android versions
(Android 11 and below), the system requires a location permission in order to
scan for nearby Bluetooth devices; we use it solely to discover and connect to
your device and we do NOT use it to determine or track your geographic location.
Our app does not collect location in the background.

How do we process your information?
We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law.
We may also process your information for other purposes with your consent.

In what situations and with which parties do we share personal information?
We DO NOT SELL your personal information and we DO NOT share it with third
parties for their own purposes. We share your information only when it is
necessary to provide the Services to you.

How do we keep your information safe?
We have organizational and technical processes and procedures in place to
protect your personal information. However, no electronic transmission over the
internet or information storage technology can be guaranteed to be 100% secure.

1. PERSONAL INFORMATION YOU DISCLOSE TO US

We collect personal information that you voluntarily provide to us when you
express an interest in obtaining information about us or our products and
Services, when you participate in activities on the Services, or otherwise when
you contact us. The personal information we collect may include: names, phone
numbers, email addresses, and mailing addresses.

Sensitive information: With your consent, we process a limited category of
health and fitness data — specifically your daily step count obtained through
Android Health Connect (see Section 2A) — to provide the in-app wellness
experience.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law.
We may also process your information for other purposes with your consent.

2A. HEALTH CONNECT (ANDROID) AND HEALTH DATA

With your explicit permission, the iWel Health app reads your daily step count
from Android Health Connect. We request only the Steps (READ_STEPS) permission,
and only after you choose to connect Health Connect from within the app and
grant access through the standard Android Health Connect permission dialog. We
never access this data silently or in the background.

How we use it:

• Your daily step total is shown to you within the app as part of your activity
  and wellness overview.
• It may be used to estimate your energy expenditure, shown to you in the app.
• With your consent, it is stored to your own authenticated account (transmitted
  securely over HTTPS) so your activity history is available across sessions
  alongside your other health metrics.

What we do NOT do:

• We do NOT sell your Health Connect data.
• We do NOT use it for advertising or marketing.
• We do NOT share it with third parties for their own purposes.
• We do NOT transfer it to any service for the purpose of serving ads, and we do
  NOT use it to determine credit-worthiness or for lending purposes.

Your control:
You can disconnect Health Connect at any time from within the app, which
immediately revokes our access and stops all further reads. You may also revoke
access from the Android Health Connect settings on your device.

Our access, use, and sharing of data obtained through Health Connect complies
with the Health Connect Permissions policy, including the Limited Use
requirements.

3. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for
the purposes set out in this privacy notice, unless a longer retention period is
required or permitted by law. When we have no ongoing legitimate business need to
process your personal information, we will either delete or anonymize it, or, if
this is not possible (for example, because it has been stored in backup
archives), we will securely store it and isolate it from any further processing
until deletion is possible.

4. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational
security measures designed to protect the security of any personal information we
process. However, despite our safeguards, no electronic transmission over the
Internet or information storage technology can be guaranteed to be 100% secure,
so we cannot promise or guarantee that unauthorized third parties will not be
able to defeat our security. Transmission of personal information to and from our
Services is at your own risk. You should only access the Services within a secure
environment.

5. WHAT ARE YOUR PRIVACY RIGHTS?

Withdrawing your consent: If we are relying on your consent to process your
personal information, you have the right to withdraw your consent at any time by
contacting us using the details in Section 8 below. This will not affect the
lawfulness of processing before its withdrawal.

If you have questions or comments about your privacy rights, you may email us at
support@iwelcgm.com.

6. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and applications include a
Do-Not-Track (“DNT”) feature. As no uniform technology standard for recognizing
and implementing DNT signals has been finalized, we do not currently respond to
DNT browser signals. If a standard is adopted in the future, we will inform you
in a revised version of this privacy notice.

7. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this privacy notice from time to time. The updated version will be
indicated by an updated “Last Revised” date at the top of this privacy notice. We
encourage you to review this privacy notice frequently.

8. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from
you, details about how we have processed it, to correct inaccuracies, or to
delete your personal information. You may also have the right to withdraw your
consent. To make a request, please contact us at support@iwelcgm.com.

9. SMS DISCLAIMER

By contacting iWel Health, you agree to iWel Health’s Terms of Use and Privacy
Policy. You consent to receive phone calls and SMS messages from us to provide
updates and information regarding your business with us. Message frequency may
vary. Message & data rates may apply. Reply STOP to opt-out of further messaging.
Reply HELP for more information.