Privacy Notice

EFFECTIVE DATE: January 1, 2021
LAST UPDATED: August 12, 2025

At Inito Health Inc. (“Inito” or “us,” “we,” or “our”), your privacy is important to us. This Privacy Notice (the “Privacy Notice”) provides you with information about how we may collect, use, share, or otherwise process your Personal Information so that you may make knowledgeable choices about the information that you choose to provide to us or that we otherwise collect. “Personal Information” includes information that alone, or when in combination with other information, may be used to readily identify, contact, or locate you.

Please note that we may update this Privacy Notice from time to time, so please check back with us periodically. This Privacy Notice applies to the Inito services made available via applications on mobile or handheld devices (the “Apps”), and our websites and web applications that link to this Privacy Notice at www.inito.com (the “Website” and “Web App,” respectively, and with the Apps, collectively, the “Service”). We encourage you to read this Privacy Notice closely.

This Privacy Notice provides information regarding Inito’s data practices, including:

• How Inito collects Personal Information and from what sources;
• How Inito uses Personal Information;
• What Personal Information we disclose to third parties and to whom;
• How Inito uses cookies, online advertising and tracking technologies; and
• Other things you should know about privacy and Inito.

This Privacy Notice applies to the information that we collect when you interact with our Service.

To the extent that you participate in a clinical research or other study with us, additional or separate privacy policies may apply.

Residents of certain U.S. states may have additional rights with respect to their data:

• Residents of California
• Residents of Nebraska and Texas

If you are a resident of Washington and Nevada, you may have additional rights with respect to your health information. Please visit our separate Consumer Health Data Privacy Policy, which supplements this policy.

Types of Personal Information Collected

Within the last 12 months, Inito may have collected the following categories of information:

• Identifiers, such as your name, date of birth, address, telephone number, e-mail address, or IP address or other online identifiers. We use this information to provide you with our services, maintain your account, operate our business, and to otherwise communicate with you. We may provide this information to service providers, analytics partners, or to other third parties as required by law.
• Internet or other electronic network activity Information, such as your cookies, device type, Wi-Fi SSID, browser type, geolocation data, search and browsing history within our Service, and information regarding your interactions with pages you visit on the Service. We use this information to better understand your use of our services and for our internal business purposes. We may provide this information to service providers, analytics partners, regulatory authorities, and advertising partners or to other parties as required by law.
• Commercial information, such as the type of product purchased or other product-identifying information. We use this information to better understand your use of our services, for marketing, and for our internal business purposes. We may provide this information to service providers, analytics partners, regulatory authorities, and advertising partners or to other parties as required by law.
• Audio, electronic, visual or similar information. You may have the ability to upload images to us. We use this information to troubleshoot our products and services and for marketing purposes. We may provide this information to service providers, regulatory authorities, or to other parties as required by law.
• Sensitive Personal Information, such as fertility-related data, medications, symptoms, and other family planning and health-related information you provide. We may use your Sensitive Personal Information in the following ways: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; (vii) verifying or maintaining the quality or safety of a service or device or (viii) in order to provide personalized advertising. You can opt out of this advertising by using the Your Privacy Choices link in the footer of this page. We may disclose your Sensitive Personal Information with service providers, analytic partners, and other parties as required by law.

We may aggregate or de-identify the Personal Information we receive and use it for any of the purposes described in the Use of Personal Information section below. Where we de-identify data, we will take reasonable steps to ensure that the information is not re-identified by Inito, and that any third party that receives the de-identify data similarly will not attempt to re-identify the data.

Sources of Personal Information

In the past 12 months, we may have collected Personal Information about you in the following ways:

• Directly from you when you interact with our Service
• Automatically through our use of cookies and other data collection technologies on the Service (see the Cookies, Online Advertising and Tracking Technologies section below).
• From third-party sources, such as social media platforms (if you interact with us through your social media account).

Use of Personal Information

We may use the information we collect about you for the following purposes:

• Providing you with the Service. Inito may use your Personal Information to deliver the Service to you and otherwise provide you with the products and experience that you request from us.
• Customer Service. We may use or disclose your Personal Information where it is necessary for us to complete a transaction, provide product support related to a Service, validate data related to a Service for troubleshooting and dispute resolution purposes, or do something that you have asked us to do. For example if you purchase a paid Service offered by Inito, you may be asked for information needed to complete your request.
• Development of the Inito Service. In our mission to better understand fertility cycles and help women make powerful and informed choices around their fertility, Inito may use anonymized fertility data to better understand human fertility, improve our Service and develop new products. We may also disclose anonymous fertility information with third-party researchers.
• Technical and Administrative Support. Inito may use your Personal Information to notify you periodically about important changes to the Service, fixes or updates to the Service, to troubleshoot the Service, or to notify you of new products and services and related features.
• Promotions and Contests. If you elect to do so, you may be asked to provide Personal Information for entry into a particular promotion or contest, so that we can let you know if you won a prize. The specific rules and regulations governing the particular promotion or contest will vary and your participation constitutes your agreement to abide by those rules and regulations. Any use of your Personal Information in such promotion or contest will not materially exceed the use described in this Privacy Notice.
• Publications. We may aggregate or de-identify user information, and use that information to publicize our Service, including, for example, by describing trends or other information about our user population and how our Service is used by them.
• Marketing. When you provide Inito with your Personal Information, we may communicate with you using the information you have given us to provide you with information we think may be of interest to you, including marketing and promotional messages. The marketing messages we send will contain information as to how to opt-out of receiving further marketing emails. You can also email us at help@inito.com to opt-out of receiving marketing emails.

When and To Whom Inito May Disclose Personal Information

In addition to the circumstances noted above, Inito may also disclose your Personal Information with the following third parties:

• Service Providers. Inito may disclose Personal Information with other companies with whom it contracts (such as vendors and service providers) in order to provide you with the Service.
• Advertising Partners. Inito may disclose your information with third parties for the purposes of serving you with personalized or targeted advertisements on third-party platforms and to measure advertisement engagement.
• Analytics Partners. Inito may disclose your information with third parties for the purpose of improving the functionality of our Service.
• Business Changes. If Inito should ever file for bankruptcy, reorganize into or merge with another company, or if Inito should decide to buy, sell, or reorganize some part or all of its business, Inito may disclose your Personal Information to prospective or actual purchasers in connection with one of these transactions.
• With Your Consent. We may disclose Personal Information about you to certain third parties not described in this Privacy Notice with your consent.
• As Required by Law and Other Extraordinary Disclosures. Inito may be required to disclose your Personal Information if it: (i) believes it is reasonably necessary to comply with legal process (such as a court order, subpoena, search warrant, etc.) or other legal requirements of any governmental authority, (ii) would potentially mitigate our liability in an actual or potential lawsuit, (iii) is otherwise necessary to protect our rights or property, or (iv) is necessary to protect the legal rights or property of others.

Cookies Online Advertisements and Tracking Technologies

Cookies are small lines of text/data that are installed on your computer by a website. The Service may involve use of cookies or other similar technologies to collect and store information. We utilize these technologies to research and understand how the Service is used, to develop and improve the Service, to personalize your online experience, and for advertising and other marketing purposes.

When you exit out of the Service, session cookies used by Inito are removed. In some instances, such as where you register in order to customize your use of the Service, cookies may persist so that we can recognize you without requiring log-in at each visit. These persistent cookies placed in connection with your use of the Service may remain stored on your computer or mobile device until you remove them. Disabling or removing cookies may require you to manually log on each time you wish to use the Service. Most web browsers automatically accept cookies, but it is possible to change your browser setup so that it does not accept cookies. To find out more information about cookies, visit https://www.AllAboutCookies.org.

Google Analytics. We use Google Analytics to helps us understand how users engage with our Services. Google Analytics uses cookies to track your interactions with the Service, then collects that information and reports it to us, without identifying individual users. This information helps us improve the Service so that we can better serve users like you. For more information on Google Analytics, visit https://Support.Google.com/Analytics.

You can generally opt-out of receiving targeted ads from third-party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) by visiting http://optout.networkadvertising.org/. You may also opt-out of receiving targeted advertisements from other companies that perform interest-based advertising services via the Digital Advertising Alliance (DAA) site at http://optout.aboutads.info/. Please note that when using the ad industry opt-out tools described above you may need to execute opt-outs for each browser or device that you use. Opting out of interest-based advertising does not mean you will no longer see advertising online but it does mean that the companies from which you opt-out will no longer show ads that have been tailored to your interests. You also may exercise choices regarding the use of cookies by visiting https://datacloudoptout.oracle.com/#optout.

You can further use the methods described below to manage cookies. You must take these steps on each browser or device that you use. If you replace, change or upgrade your browser or device, or delete your cookies, you may need to use these opt-out tools again.

• Google Chrome
• Apple Safari
• Mozilla Firefox
• Microsoft Internet Explorer

Browser Signals

Some web browsers have “Do Not Track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. At present, the Service does not respond to “Do Not Track” or Global Privacy Control (“GPC”) outside of California, and consequently, the Service will continue to collect information about you even if your browser’s “Do Not Track” feature is activated if you are not located in California. For users in California who navigate to the Service using a web browser, we recognize the GPC signal.

Financial Incentives

From time to time, we may offer financial incentives to consumers in exchange for your sharing of certain Personal Information with us. The specific instructions for how to participate and the rewards offered as incentives may vary and are set out within each program. Our good-faith estimate of the value of your information is the value of the benefit we offer to you. We have calculated that value by using the expense to us of operating the program related to the benefit obtained by our running of the program. To participate in any incentive-based programs you can opt-in by signing up for the incentive when it is offered to you. Participation in our promotional programs is always optional, and you can terminate program participation at any time as explained in the applicable program terms. You can also contact us at help@inito.com to unsubscribe or cancel your participation in any program.

Security

Inito takes reasonable steps to safeguard the Personal Information that we collect about you. However, no data transmissions over the Internet can be guaranteed to be 100% secure. Thus, Inito cannot ensure the security of any information that you transmit to us. You use the Service at your own risk.

Children’s Privacy

Our Service does not knowingly collect Personal Information from users who are under 18 years of age. You should not use the Service if you are not 18 years of age or older. If a person under 18 submits information through our Service and we learn the person is under 18 years of age, we will delete the information once we learn of it.

Please contact us at help@inito.com if you are aware of any Personal Information belonging to a user under 18 years of age.

Retention of Your Personal Information.

As a general matter, we will keep your Personal Information for as long as necessary to fulfill the purpose for which it was collected. If a law requires us to retain your information for a longer period of time, we will comply with that law. We will also retain your Personal Information as necessary to protect our legal rights.

Other Important Information

• Third-party websites. The Service may contain links to third-party websites. Such third-party websites are not governed by this Privacy Notice. If you choose to visit such third-party websites, you should review the third party’s applicable privacy notice carefully.

Changes to this Privacy Notice

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will make reasonable efforts to notify you by sending you an email to your registered email address or through other communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.

Contacting Inito

If you have any questions, comments, or concerns about this Privacy Notice, please email us at help@inito.com or write to us at:

Inito Health Inc.
24 Greenway Plaza, Suite 1800
Houston, TX, USA 77046

Your California Rights

If you are a resident of California, you may be entitled to the privacy rights described below under the California Consumer Privacy Act (“CCPA”).

We collect the categories of information described in the Types of Personal Information Collected section of this Notice.

We use the Personal Information we collect for the purposes described in the Use of Personal Information section of this Notice.

We have not sold Personal Information for any monetary value. However, our use of certain website cookies may be considered a "sale" of information under California law. We may have disclosed your health information, internet activity or non-specific geolocation with third parties whose cookies are on our websites. These cookies are used to analyze usage of our website, provide you with relevant advertising and products, and provide additional, dynamic functionality to our websites. You can opt-out of the use of these cookies by using the Your Privacy Choices link in the footer of the web page. We also recognize opt-out preference signals contained in HTTP header fields. We do not “share” Personal Information as that term is used under California law. We do not knowingly sell or share the personal information of anyone under the age of 18.

We maintain your Personal Information for the periods described in the Retention of Personal Information section of this Notice.

In addition, as a resident of California, you may have certain rights with respect to your personal information:

• Right to Know. You may request information about the categories of Personal Information we have collected about you, the categories of source from which we collect the Personal Information, the purposes for collecting the Personal Information, and to whom we disclosed the Personal Information and why. You may also request the specific pieces of Personal Information we have collected from you.
• Right to Delete. You may request that we delete Personal Information that we have collected from you, subject to certain exceptions under applicable law.
• Right to Correct. You may request that we correct inaccurate Personal Information that we maintain about you.
• Right to Opt Out of Sale/Sharing. You may request to opt out from the sale or sharing of your Personal Information.
• Right to limit Sensitive Personal Information Processing. You may limit the use and disclosure of Sensitive Personal Information collected about you.

Additionally, California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our Website visitors who are California residents to request and obtain from us, once a year and free of charge, information about categories of Personal Information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared Personal Information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

Exercising Your Privacy Rights

To exercise your rights, please contact us at help@inito.com.

Inito cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will not request more information than is necessary to verify your identity in relation to your request. When you submit a request, we will take steps to verify your identity. You are not required to create an account with us to submit a request. If you don't have an account with us, we may ask you to provide us with information about yourself in order to verify your identity.

We will only use Personal Information you provide in connection with identity verification to verify the requestor's identity or authority to make the request and whenever feasible, we will attempt to match the information you provide with information we may already have about you.

If you wish to authorize a third party to make a request on your behalf through an authorized agent, you must contact Inito directly and must provide a valid California power of attorney or comparable documentation of written permission from you and verification of your identity with Inito. You may also make a privacy request on behalf of your minor child.
Non-Discrimination: We will not discriminate against you in any manner prohibited by law for exercising your privacy rights

Additional U.S. State Privacy Disclosures

These Additional U.S. State Privacy Disclosures supplement the information contained in the Privacy Notice. These Disclosures apply only to residents of Nebraska and Texas.

Consumer Privacy Rights

You may have the following rights, subject to any applicable exemptions or limitations:

• Right to Access. You have the right to confirm whether we are processing your Personal Information and to access such Personal Information.
• Right to Correct. You have the right to request that we correct inaccurate Personal Information that we maintain about you.
• Right to Delete. You have the right to request that we delete your Personal Information subject to certain limitations under applicable law.
• Right to Opt-out. You have the right to object or opt-out of certain types of processing, including: (1) processing for the purpose of targeted advertising and (2) processing for the purpose of the sale of Personal Information.
• Right to Data Portability. You have the right to request a copy of your Personal Information in an accessible format.
• Right to Equal Service. If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our websites, services, or properties.
• Right to Appeal. If we do not grant your consumer request, you may have the right to appeal that denial.

You can exercise your privacy rights as described in “Submitting a Privacy Rights Request,” below.

Submitting a Privacy Rights Request

To exercise any of the state rights above, please submit a request to us by emailing us at help@inito.com. Making a consumer request does not require you to create an account with us. Applicable law may limit the number of times that you can submit a particular request within a 12-month period.

You can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable law.

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use Personal Information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.