Consumer Health Data Privacy Policy

Effective as of February 28, 2025.

This Consumer Health Data Privacy Policy (“Consumer Health Data Privacy Policy”) applies to the extent required by applicable U.S. state laws with respect of consumer health data (“Consumer Health Data”) as applicable laws may define that term. This Consumer Health Data Privacy Policy supplements our general Privacy Policy. In the event of a conflict between our Privacy Policy and the Consumer Health Data Privacy Policy, the Consumer Health Data Privacy Policy applies to the extent that it is consistent with applicable U.S. state law.

This Consumer Health Data Privacy Policy describes how Perelel Inc. (“Perelel,” “we,” “us” or “our”) processes Consumer Health Data that we collect our websites as well as associated marketing activities and any other activities described in this Policy (collectively, the “Services”).

Consumer Health Data we collect

Consumer Health Data you may provide to us through the Service or otherwise includes:

• Contact data, such as your name, email address, billing and mailing addresses, and phone number.
• Demographic data, such as your sex, date of birth or age, and gender.
• Profile data, such as the username and password that you may set to establish an online account on the Service, order history and status, interests, preferences, and any other information that you add to your account profile.

• Communications data, such as information you exchange with us in email communications sent to us, plus your preferences relating to our emails and other communications (e.g., whether you have opted in to receive marketing communications), as well as your interactions with our communications (e.g., whether you open and/or forward emails. This includes any information you provide in any free-text ‘message’ fields via which you can communicate with us on the Service (e.g., using our ‘contact form’ functionality, customer service agent (such as our chatbot), social media, or similar).
• Health-related data, such as your vitamins, supplements, estimated pregnancy due date, weight, cycle dates, sexual history, and medications.
• Survey responses if you choose to participate in our surveys, such as weight and hormonal stage.
• User-generated data, such as content or information you generate, transmit or otherwise make available through the Service, as well as associated Technical Data.
• Payment data needed to complete transactions, including payment card information or bank account number.
• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
• Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers, transaction history, and product wish lists.

Consumer Health Data we collect automatically

When you use our Service, we collect some information through certain technical tracking technologies that may be considered Consumer Health Data. For example:

• Analytics data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Technical data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
• Chat and artificial intelligence technologies. We use chat and other artificial intelligence (“AI”) technologies such as those provided by Siena AI that employ cookies and software code to operate the chat and/or user input/prompt features that you can use to communicate with us and/or input your prompts and other personal information through the Service. Siena AI and other third parties may access and use personal information you share through online chats or within inputs to facilitate the provision of the Service.

Consumer Health Data we may create, infer or generate

We may create, infer or generate Consumer Health Data from other data we collect, including using automated means to generate information about your likely preferences or other characteristics. Inferential data may include your pregnancy dates, fertility window, product interests and other health-related data.

How we use your Consumer Health Data

We use Consumer Health Data for purposes described in this Consumer Health Data Privacy Policy or as otherwise disclosed to you. For example, we use Consumer Health Data for the following purposes:

Purpose of Use	Categories of Consumer Health Data
Service delivery and operations: including to provide, operate, and secure the Service, and communicate with you regarding the Service.	Contact data, demographic data, profile data, health-related data, survey responses, communications data, marketing data, technical data, analytics data
Service personalization: including to understanding your needs and interests, personalizing your experience with the Service and our Service-related communications, remembering your selections and preferences as you navigate webpages.	Contact data, demographic data, profile data, health-related data, survey responses, communications data, marketing data, technical data, analytics data
Improvement and analytics: including to improve our Service and business, and help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.	Contact data, demographic data, profile data, health-related data, survey responses, communications data, marketing data, technical data, analytics data
Marketing: To provide you with information and services, such as our press releases, social media updates, and our newsletters.	Contact data, demographic data, profile data, health-related data, survey responses, communications data, marketing data, technical data, analytics data
Compliance and protection. To comply with applicable laws, lawful requests, and legal process (such as to respond to disclosure orders, as well as demands, investigations or requests made by regulators, governments, courts and law enforcement authorities; to protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); to audit our internal processes for compliance with legal and contractual requirements or our internal policies; to enforce the terms of agreements that govern access to the Service; and to prevent, identify, investigate and deter fraudulent, harmful, unauthorised, unethical or illegal activity, including cyberattacks and identity theft..	Contact data, demographic data, profile data, health-related data, survey responses, communications data, marketing data, technical data, analytics data
To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.	Contact data, demographic data, profile data, health-related data, survey responses, communications data, marketing data, technical data, analytics data
Corporate events. To facilitate or carry out any corporate events, such as investments in or financings of Perelel, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares (including providing Consumer Health Data to allow third parties to conduct diligence into – and, where relevant, to continue to operate – all or relevant part(s) of our operations).	Contact data, demographic data, profile data, health-related data, survey responses, communications data, marketing data, technical data, analytics data

How we share your Consumer Health Data

We may “share” (as applicable U.S. state laws define that term) Consumer Health Data with your consent or as we determine necessary to provide the Service to you, or as otherwise permitted or required by law. For example, we may share your Consumer Health Data to:

Authorities and others. We will access, share, and preserve Consumer Health Data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies. We will also share Consumer Health Data if we believe it is necessary to protect our customers and/or the rights or property of ourselves or others.

Your Consumer Health Data choices 

You may have certain rights to your Consumer Health Data under applicable laws. Any of the rights discussed below may be subject to certain limitations (for example, a monetary charge).

If you wish to exercise these rights, please email us at [email protected].

Withdraw consent. To the extent we rely upon your consent for either our collection or sharing of your Consumer Health Data, you have the right to withdraw such consent from any future collection or sharing.

Access and confirm. You have the right to ask us to confirm whether we have collected, shared or sold your Consumer Health Data. Further, you have the right to access (in other words, request a copy of) the Consumer Health Data that we have collected, shared or sold. You also have a right to access a list of all “third parties” (as applicable U.S. state laws define that term) and affiliates with whom we have shared or sold your Consumer Health Data and receive certain corresponding information.

Correction. You have the right to ask us to correct inaccuracies in your Consumer Health Data.

Deletion. You have the right to ask us to delete your Consumer Health Data.

Appeal. You have the right to appeal our denying a right you have attempted to exercise. We will provide details on how to appeal our denial in connection with such action.

To exercise your rights above and make a Consumer Health Data rights request, please email us at [email protected]. We may need to verify your identity in order to process your request. To confirm your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you (such as government identification), which we will only use to verify your identity, and for security or fraud-prevention purposes.

Declining to provide information. We need to collect Consumer Health Data to provide certain services. If you do not provide the information we identify as required or mandatory, or if you request that any required Consumer Health Data be deleted or withdraw your consent for future collection or sharing of any required Consumer Health Data, we may not be able to provide those services.

Changes to this Consumer Health Data Privacy Policy

We reserve the right to modify this Consumer Health Data Privacy Policy at any time. If we make material changes to this Consumer Health Data Privacy Policy, we will notify you by updating the date of this Consumer Health Data Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Consumer Health Data Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Consumer Health Data Privacy Policy indicates your acknowledging that the modified Consumer Health Data Privacy Policy applies to your interactions with the Service and our business.

How to contact us

• Email: [email protected]