BodyWell Method: Privacy Policy

Last updated: FILL: publication date Effective: FILL: effective date

1. Who this policy covers

This Privacy Policy explains how FILL: full registered legal entity name ("BodyWell", "we", "us") collects, uses, shares and protects personal information when you use bodywellmethod.com, our mobile and television applications, and our related services (the "Services").

We are the business responsible for the personal information described here.

2. Information we collect

2.1 Information you give us

• Account information: name, email address, password, and FILL: any other required registration fields.
• Billing information: billing name, billing address, and the last four digits and expiry of your card. We do not store full payment card numbers. Card details are collected and stored by our payment processor, FILL: processor name, e.g. Stripe.
• Fitness and nutrition intake information: the details you choose to give us about your goals, activity level, dietary preferences, and any injuries, limitations or physical conditions you tell us about. See section 3.
• Appointment and booking information: the times you book, the service booked, and anything you write in a booking note.
• Communications: the content of emails, support tickets and in-app messages you send us.
• FILL: **Content you submit**, such as comments, reviews, profile photos. Delete if user submitted content is disabled.
• Event registrations: for live and in-person events, FILL: what is collected, for example emergency contact, dietary requirements.

2.2 Information we collect automatically

• Usage and viewing data: which videos you play, how far through them you get, what you favorite or schedule, when you open the app, and which features you use.
• Device and technical data: device model, operating system version, app version, language, time zone, IP address, and a device or advertising identifier.
• Cookies and similar technologies: on our website. See section 7.

FILL: Confirm the exact set of automatically collected fields with VidApp before publishing, since the app analytics layer is a VidApp service and this list must match what it actually captures. Do not publish a list assembled from a template.

2.3 Information from third parties

• Apple and Google: if you subscribe inside our app, Apple or Google confirms your purchase, renewal and cancellation status to us. They do not give us your payment card details.
• FILL: **Content platform**, if BodyWell's content and member records sit on Kajabi, Uscreen, Squarespace or similar. Name it and describe what flows across.
• FILL: **Marketing and advertising partners**, if any. Delete if none.

3. Health and wellness information: how we treat it

The fitness, injury, and nutrition details you give us are sensitive. We treat them accordingly.

We use this information only to FILL: state the actual uses, for example recommend appropriate programs, adapt content suggestions, and prepare for a booked appointment.

We do not sell this information. We do not use it for targeted advertising. We do not share it with advertising networks or data brokers.

FILL: Verify the three sentences above are true before publishing. If any advertising SDK, pixel, or conversion API is installed on pages or screens where intake information is collected, they are not true, and publishing them creates direct liability. This is the single highest risk item in this document.

FILL: **Consumer health data laws.** Several states, including Washington under the My Health My Data Act and Nevada under SB 370, regulate consumer health data broadly enough to potentially cover fitness and nutrition intake data collected by a wellness app, and they attach consent, separate-notice, and authorization requirements that go beyond a general privacy policy. Several comprehensive state privacy laws also classify health data as sensitive and require opt in consent to process it. Counsel must confirm whether BodyWell falls in scope. If it does, a separate Consumer Health Data Privacy Notice is required in addition to this policy, and this section is not sufficient on its own.

We are not a HIPAA covered entity and this information is not protected health information under HIPAA. FILL: Confirm. If BodyWell ever bills insurance, employs licensed practitioners delivering treatment, or contracts with a health plan or employer wellness program, this sentence may be wrong.

4. How we use your information

We use personal information to:

• create and manage your account;
• deliver the content and features you have paid for;
• process payments, renewals, and refunds;
• recommend content and personalize what you see;
• manage appointments, bookings and event attendance;
• provide customer support;
• send you service messages such as receipts, renewal reminders and security notices;
• send marketing emails, where you have not opted out;
• measure how the Services are used so we can improve them;
• detect and prevent fraud, account sharing, and abuse;
• comply with legal obligations and enforce our Terms.

5. When we share information

We share personal information with:

FILL: This table must list every vendor that actually receives personal information. An incomplete list is a defect. Ask BodyWell for their vendor and integration list rather than inferring it.

We also share information:

• with professional advisers, such as lawyers and accountants, under duties of confidentiality;
• where required by law, subpoena, or a lawful government request;
• to protect our rights, safety, or property, or that of our users;
• in connection with a merger, acquisition, financing or sale of assets, in which case we will notify you if your information becomes subject to a different privacy policy.

6. Do we sell or share your information?

FILL: Answer this honestly. Under California and several other state laws, "sale" and "share" are defined much more broadly than money changing hands, and installing certain advertising or social pixels can count. Do not default to "we do not sell your information" without checking the actual tag stack on the website and in the app. If BodyWell does sell or share as those laws define it, this policy must say so and must provide a working opt out link.

7. Cookies and tracking

On our website we use FILL: describe actual cookie categories in use: strictly necessary, analytics, marketing. You can control cookies through FILL: cookie banner or preference center, if one exists, or browser settings.

In our apps, on iOS we will ask your permission through Apple's App Tracking Transparency prompt before tracking you across other companies' apps or websites. FILL: Delete if BodyWell does no cross-app tracking, which is the likely and preferable position.

We FILL: do / do not respond to Global Privacy Control signals. FILL: Several state laws now require honoring an opt out preference signal. Confirm whether the site does.

8. How long we keep information

We keep your personal information for as long as your account is active, and afterwards for FILL: retention period to meet legal, tax, accounting and dispute resolution requirements. Financial records are typically kept for FILL: period, commonly 7 years.

You can ask us to delete your account and information under section 10.

9. Security

We use FILL: describe the actual measures, for example encryption of data in transit and at rest, access controls, and vendor security review to protect personal information.

No system is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your password confidential.

FILL: Do not list a security measure BodyWell does not actually have in place. Overstated security claims are a recurring enforcement theme.

10. Your privacy rights

Depending on where you live, you may have the right to:

• know what personal information we hold about you and get a copy of it;
• correct inaccurate information;
• delete your information;
• opt out of the sale or sharing of your information, and of targeted advertising;
• limit our use of sensitive personal information;
• opt out of profiling that produces legal or similarly significant effects;
• not be discriminated against for exercising these rights.

To exercise a right, email FILL: privacy email address or use FILL: web form URL, if one exists. We will verify your identity before acting, normally by confirming control of the email address on the account.

We will respond within the period required by applicable law, generally 45 days, and we may extend once where permitted.

Authorized agents. You may use an authorized agent to submit a request. We may ask for proof of authorization.

Appeals. If we decline your request, you may appeal by emailing FILL: appeals email. We will respond to an appeal within the period required by law.

FILL: This section is drafted to the common denominator of US state privacy laws. Counsel should confirm which state laws BodyWell is actually in scope for, since most have revenue or volume thresholds, and should add any state-specific disclosures required, including the California categories-collected and sources tables if CCPA applies.

11. Children

The Services are not directed to children under 13, and we do not knowingly collect personal information from them. FILL: Adjust if the minimum age in the Terms is 18, in which case this should say the Services are not intended for anyone under 18. If you believe a child has given us personal information, contact FILL: privacy email and we will delete it.

12. Users outside the United States

We are based in the United States and process personal information there. FILL: If BodyWell knowingly serves members in the EU, UK, or Canada, this policy is not sufficient. GDPR and UK GDPR require additional content including legal bases, transfer mechanisms, and a data subject rights section written to their standard. Confirm whether BodyWell will market outside the US. VidApp's customer base skews US, Canada and UK, so this is a live question rather than a theoretical one.

13. Changes to this policy

We may update this policy. We will change the "Last updated" date above and, if the change is material, notify you by email or in the app before it takes effect.

14. Contact us

FILL: legal entity name FILL: postal address FILL: privacy email address