Eiro Engage Privacy Policy

Effective Date: February 20, 2026

1. Who We Are and What the App Does

Eiro Engage is operated by Eiro, Inc. ("we," "us," or "our").

The purpose of this app is to collect health data from you to build artificial intelligence and machine learning models for future healthcare applications. We compensate you for the health data you provide to us. We believe you should understand exactly how this works before you decide to use the app.

This policy provides important information about the information we collect through this app, including the categories of information we collect through this app, how we use it, and how we share it. Please read it before creating an account and using the app.

Here are the basics:

• You provide your health data. You submit mental health information to us directly into the app, and clinical health records from your healthcare providers accessed through Apple Health.
• We pay you. You receive compensation for your data contributions as described in Section 4 of this policy.
• We use your data to build AI. We use the health data contributed by you and other users to train, validate, and improve AI models designed to support personalized healthcare. We develop these models internally. We do not sell your health data to third parties.

We may update this Privacy Policy from time to time. Any updated Privacy Policy will be effective when posted. Please check this Privacy Policy periodically for updates. When we make material changes, particularly changes that affect how we collect, use, or share your health data, or that affect your compensation, we may notify you through reasonable means (e.g., through a notice in the app or by email) and obtain your affirmative consent before those changes apply to your data where required by law.

2. Information We Collect

2.1 Health Information You Provide Directly

We collect health and wellness information that you enter into the app, including:

• Health conditions, diagnoses, and symptoms.
• Mental health information, including mood, stress, and self-assessments.
• Health goals and preferences.
• Responses to health questionnaires and assessments.
• Medications, dosages, and supplement use.
• Health history, including prior treatments, surgeries, and hospitalizations.
• Family health history.
• Lifestyle information, including diet, exercise, sleep, and substance use.
• Reproductive health information, including menstrual cycle and fertility data.
• Biometric measurements you enter manually, such as blood pressure, weight, and blood glucose.

2.2 Clinical Health Records from Apple Health

Our app integrates with Apple Health, which allows you to access clinical health records downloaded from your healthcare providers' patient portals to your Apple device. These records are sourced from your healthcare providers' electronic health record systems and may include information such as lab results, medications, immunizations, diagnosed conditions, allergies, clinical vitals, and procedures.

When you create an account, our app requests access to certain health record information stored on your device through Apple Health Records to verify your identity and to store them on our servers for the purpose of developing AI models. The categories of clinical health records we may collect through this integration include:

• Laboratory and test results, including values, reference ranges, and dates.
• Medications, including prescriptions, dosages, and prescribing providers.
• Diagnosed conditions and clinical assessments.
• Immunization records.
• Allergies and adverse reactions.
• Clinical procedures and surgical history.
• Clinical vitals recorded during healthcare visits (such as blood pressure, heart rate, temperature, and weight as documented by a provider).
• Provider and facility information associated with your records.

2.3 Compensation and Payment Information

We offer two methods of compensation for your data contributions: Amazon gift cards and direct payouts through Stripe Connect.

Amazon Gift Cards. You may elect to receive compensation in the form of Amazon gift cards delivered to the email address associated with your account. We collect your email address for this purpose. We do not collect or store any Amazon account information.

Stripe Connect. You may elect to receive compensation via direct payout through Stripe Connect, a third-party payment processor operated by Stripe, Inc. ("Stripe"). If you choose this option, you will create a Stripe Connect account directly with Stripe. Stripe collects and processes your financial and identity information (such as your name, bank account details, and tax identification information) in accordance with Stripe's privacy policy. We do not collect or store your bank account numbers or financial credentials. We receive only limited information from Stripe necessary to confirm your payment status and process payouts, such as your Stripe account identifier and payout confirmation details.

We use your payment-related information solely to process your compensation. We do not use payment information for advertising, analytics, health-related inferences, or any purpose other than payment processing.

Stripe's collection, use, and sharing of your financial information is governed by the Stripe Privacy Policy. We encourage you to review Stripe's policy before creating a Stripe Connect account.

2.4 Account, Usage and Device Information

We also collect the following information directly from you or automatically through your use of the app:

• Account information, such as your name, email address, and date of birth.
• Demographic information, such as gender, race, and income level.
• Device information, such as device type, operating system, unique device identifiers, and browser type.
• Usage data, including features used, pages visited, time spent, and interaction patterns.
• IP address and approximate location derived from your IP address.

3. How We Use Your Information

3.1 AI Model Training and Development

Our primary purpose for collecting your health data is to develop artificial intelligence and machine learning models for healthcare applications. We use the health data collected through our platform to train, validate, test, and improve AI and machine learning models designed to identify patterns in health data that support personalized treatment planning, generate predictive health insights, and support clinical decision-making in mental health treatment.

We develop these models internally. We do not sell, license, or provide your health data to third parties for their own model development or other purposes.

We intend to use the AI models we develop to build health and wellness products and services, including consumer-facing applications that provide individualized health insights and tools that assist healthcare providers in developing personalized care plans or support clinical decision-making for mental health treatment.

Before your health data is used for model training, we de-identify it by stripping any names, geographic locations, telephone numbers, fax numbers, email addresses, social security numbers, medical record numbers, health plan beneficiary numbers, account numbers, certificate/license numbers, vehicle identifiers, web addresses, internet protocol address numbers, device identifiers, biometric identifiers (including finger and voice prints), full-face photographic images, and any other unique identifying numbers, characteristics, or codes. All dates appearing in user data are shifted by a randomly generated offset, and the internal system logs containing time-of-arrival and internet protocol address and device identifiers of the data originator are inaccessible by all Eiro employees other than a select set of privileged system administrators.

3.2 Database Development

We compile health data collected through the app into structured databases used for internal research, analytics, and as reference datasets for our AI development. These databases contain de-identified data only.

3.3 Payment Processing

We use your payment-related information solely to process your compensation through Amazon gift cards and Stripe Connect, as described in Section 2.3.

3.4 Platform Operations

We use your account and device information to operate the app, including managing your account, communicating with you about your contributions and payments, maintaining platform security, resolving technical issues, and complying with legal obligations.

3.5 With Your Consent

We may use information for purposes not described in this policy with your consent.

3.6 De-Identified Information

We may de-identify your personal information so that it cannot reasonably be used to identify you. Once information has been de-identified, it is no longer personal information, and we may use, share, and retain it for any purpose permitted by applicable law, including research, analytics, and product development. De-identified information is not subject to this policy.

4. How We Compensate You

We pay you for contributing your health data to our platform. This section describes how compensation works, what it reflects, and what happens if you stop participating.

4.1 Compensation Structure

Compensation is based on the scope and completeness of data you contribute, including the categories of data you share and whether you connect clinical health records from Apple Health in addition to self-reported data.

4.2 What Your Compensation Reflects

The amount of compensation you receive is determined based on several factors, including the categories of health data you choose to share, whether you contribute clinical health records from Apple Health in addition to self-reported data, the completeness of your contributions, the frequency at which you contribute data, and prevailing market conditions for health data such as the cost of acquiring comparable health data through other channels. Compensation amounts and the factors used to calculate them may change over time.

4.3 Payment Processing

Compensation is delivered via Amazon gift cards sent to your registered email address or via direct payout through Stripe Connect, depending on the payment method you select, on the schedule and in the manner described in the app. You are responsible for any tax obligations associated with compensation received.

4.4 Stopping Participation

Your participation is voluntary. You may stop contributing data at any time. If you stop:

• You will no longer receive compensation for future contributions.
• Compensation already earned and paid is yours to keep.
• Any earned but unpaid compensation will be paid to you on the next regular payment cycle.
• Stopping participation does not automatically delete data you have already contributed.

5. How We Share Your Information

We share your personal information in the following circumstances:

5.1 Affiliates and Subsidiaries

We may share personal information with our affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.

5.2 Service Providers

We share personal information with third-party service providers that perform services on our behalf, including cloud hosting, data analytics, payment processing, and customer support. These providers are contractually obligated to use your information only as directed by us and to maintain appropriate security measures.

5.3 Legal Obligations

We may disclose personal information when required by law, regulation, legal process, or enforceable governmental request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others, or to investigate potential violations of our terms of service.

5.4 Business Transfers

If we are involved in a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. If such a transfer occurs, where required by law, we will notify you before your information becomes subject to a different privacy policy.

5.5 With Your Consent

We may share information for purposes not described in this policy with your consent.

6. Data Security and Data Retention

6.1 How We Protect Your Information

We implement administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Although we maintain reasonable security safeguards, no security measures or method of transmission over the Internet can be guaranteed to be completely secure, and we cannot guarantee the absolute security of your information.

6.2 How Long We Keep Your Information

Your personal information will be retained as long as necessary to fulfill the purposes outlined in this policy unless we are required to do otherwise by applicable law. This includes retaining your information to provide the services you have requested, process your compensation, support our AI model development activities, maintain our business relationship with you, improve our products and services, and ensure the ongoing legality, safety, and security of our platform. Once you have stopped participating in our program or terminated your relationship with us, we may retain your information in our systems in order to fulfill surviving obligations, comply with applicable legal requirements (including tax record-keeping and breach notification obligations), support our ongoing model development and improvement, resolve disputes, and enforce our agreements. When your information is no longer needed for any of these purposes, we will securely delete or de-identify it.

7. Children's Privacy

The app is not directed to individuals under the age of 18, and we do not knowingly collect personal information from individuals under that age. If we learn that we have collected personal information from a child under 18, we will take steps to delete that information promptly. If you believe a child has provided us with personal information, please contact us at contact@eiro.ai.

8. Contact Information

If you have questions about this Privacy Policy, our data practices, or wish to exercise your privacy rights, please contact us at contact@eiro.ai.

9. U.S. State Consumer Privacy Supplement

If you are a Connecticut resident and the Connecticut Data Privacy Act (CTDPA) applies to our processing of your information, you have the following rights:

• Access. You may request confirmation of whether we are processing your personal data and request access to that data.
• Correction. You may request correction of inaccuracies in your personal data.
• Deletion. You may request deletion of your personal data.
• Data Portability. You may request a copy of your personal data in a portable, readily usable format.
• Opt Out of Targeted Advertising. You may opt out of the processing of your personal data for purposes of targeted advertising. However, we do not use information collected through the app for targeted advertising purposes.
• Opt Out of Sale. You may opt out of the sale of your personal data. However, we do not sell information collected through the app.
• Opt Out of Profiling. You may opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

To exercise these rights, contact us at contact@eiro.ai. We will respond within 45 days. If we need additional time, we will notify you of an extension of up to 45 additional days and the reason for the extension. If we decline your request, we will inform you of the reason and you may appeal by contacting us at contact@eiro.ai. We will inform you in writing of our decision regarding your appeal.