Privacy Policy

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Policy version 3: 30 March 2026

ORBI APP

PRIVACY POLICY

INTRODUCTION

This Privacy Policy is provided by Avegen Limited (Company Number 09562713) with registered offices located at 64 Vaughan Road, Harrow, England, HA1 4EE ('we', 'our' or 'us') for use of our Orbi application and website www.orbihealth.io (Services).

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

Given the nature of our Services, we do not expect to collect the personal data of anyone under 18 years old. If you are aware that any personal data of anyone under 18 years old has been shared with our Services please let us know so that we can delete that data.

WHAT THIS POLICY APPLIES TO

This privacy policy relates to your use of the Services only.

The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section 'Who we share your personal data with' below.

PERSONAL DATA WE COLLECT ABOUT YOU

We collect and process only personal data that is necessary and proportionate for the purposes described in this Policy. The personal data we collect about you depends on the particular activities carried out through the Services. We may use anonymised or aggregated data that does not identify you for analytics, research and service improvement purposes. Once anonymised, such data is no longer personal data within the meaning of UK GDPR and is used solely for product improvement and research purposes. We will collect and use the following personal data about you:

Category of data: Identify and account data you input into the Services

In more detail:

   Registration is mandatory in order to use the Services

   - Your name and email address

   - Your account details, such as username and password

Category of data: Health data when you use the Services

In more detail:

   With your consent, we will also collect the following health information:

   - Existing condition

   - Symptoms

   - Sleep pattern

   - Daily activities and routines

   - Information relating to your mental health

Category of data: Data collected when you use specific functions in the Services

In more detail:

   Data you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it in accordance with this policy as if it were)

Category of data: Other data the Services collects automatically when you use it

In more detail:

   - Your activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use

   - Your device type, IMEA numbers, MAC address of networks, other unique device identification, device operating system, mobile network information, app version number, storage usage, data usage, time zone settings

If you do not provide personal data we ask for where it is required, it may prevent us from providing services and/or the Services to you.

We collect and use this personal data for the purposes described in the section 'How and why we use your personal data' below.

SPECIAL CATEGORY PERSONAL DATA OR SENSITIVE DATA

Certain personal data we collect is treated as a 'special category' to which additional protections apply under data protection law. This is also known as 'Sensitive Data'. Where we process such Sensitive Data, we will also ensure we are permitted to do so under data protection laws, and any such data will be collected on the basis of your consent. Sensitive Data we collect about you, where you choose to give it to us, may include:

- Medical history and medical information, including:

   - Existing conditions: allergies, chronic pains, chronic illnesses, ongoing treatments such as current medications consumed

- Your gender and sex - if you choose to give this to us

- Lifestyle details including thought journals, mental health questionnaires, sleep patterns and activity.

We process special category health data strictly for the purposes of delivering the Services requested by you. Such processing is based on your explicit consent under Article 9(2)(a) UK GDPR, which is obtained at the point of account creation and acceptance of this Privacy Policy and our Terms and Conditions., if you do not provide some Sensitive Data we ask for where it is asked, it will prevent us from providing all or part of the Services.

We collect and use this Sensitive Data for the purposes described in the section 'How and why we use your Sensitive Data' below.

You may withdraw your consent to the processing of health data at any time by closing your account or contacting us at "support@healthmachine.io".

Withdrawal of consent will prevent continued use of health-related functionalities within the Services.

HOW YOUR PERSONAL DATA IS COLLECTED

We collect Personal Data from you:

- directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, purchase or request services via our Services, post material to our website or App, and

- indirectly, such as your browsing activity while using the Services.

At this point in time, we do not collect any personal information about you using cookies or similar technologies. In the event that this were to change and if we were to decide to collect personal data about you using cookies, you would be notified of this change by means of in-app notification, with detailed information regarding our use of cookies and similar technologies to be made available in the relevant cookies policy.

HOW AND WHY WE USE YOUR PERSONAL DATA

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

- where you have given consent

- to comply with our legal and regulatory obligations

- for the performance of a contract with you or to take steps at your request before entering into a contract, or

- for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see 'How to contact us' below).

Lawful Basis for Processing

We process your personal data under Article 6(1)(b) UK GDPR as necessary for the performance of our contract with you in providing the Orbi services.

Where we process health or other special category data, we rely on your explicit consent under Article 9(2)(a) UK GDPR. By creating an account and accepting this Privacy Policy and our Terms and Conditions, you explicitly consent to the processing of health data you choose to provide for the purposes described herein.

The table below explains what we use your personal data for and why.

What we use your personal data for: Create and manage your account and User account data with us

Our reasons:

   For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you.

   To perform our contract with you or to take steps at your request before entering into a contract

What we use your personal data for: Providing services and/or the functionalities of the Services to you

Our reasons:

   To perform our contract with you or to take steps at your request before entering into a contract.

What we use your personal data for: To enforce legal rights or defend or undertake legal proceedings

Our reasons:

   Depending on the circumstances:

   - to comply with our legal and regulatory obligations

   - in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others

What we use your personal data for: Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important notices

Our reasons:

   Depending on the circumstances:

   - to comply with our legal and regulatory obligations

   - in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you

What we use your personal data for: Protect the security of systems and data

Our reasons:

   To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

What we use your personal data for: Operational reasons, such as improving efficiency, training, and quality control or to provide support to you

Our reasons:

   For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you

What we use your personal data for: Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures

Our reasons:

   For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app

What we use your personal data for: Updating and enhancing User health tracking information

Our reasons:

   Depending on the circumstances:

   - For user-entered data management and system integrity purposes.

   - to perform our contract with you or to take steps at your request before entering into a contract.

   - to comply with our legal and regulatory obligations

   - where neither of the above apply, for our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services

What we use your personal data for: Marketing our services to existing and former application users

Our reasons:

   For our legitimate interests, i.e. to promote our business to existing and former Application users. See 'Marketing' below for further information

What we use your personal data for: Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business

Our reasons:

   To comply with our legal and regulatory obligations

What we use your personal data for: The audit of our accounts and business

Our reasons:

   For our legitimate interests, ie to maintain any accreditations so we can demonstrate we operate at the highest standards

   To comply with our legal and regulatory obligations

   Depending on the circumstances:

   - to perform our contract with you or to take steps at your request before entering into a contract

   - to comply with our legal and regulatory obligations

   - where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services

What we use your personal data for: To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary

Our reasons:

   Depending on the circumstances:

   - to comply with our legal and regulatory obligations

   - in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets

See 'Who we share your personal data with' for further information on the steps we will take to protect your personal data where we need to share it with others.

MARKETING

We may send you marketing communications and updates by email, text message, telephone or about our services, including exclusive offers, promotions or new services.

We will always ask you for your consent before doing sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.

We may contact you by email to request feedback about your experience using the Services or to invite you to participate in research or product improvement activities. These communications are not marketing communications. You may withdraw your consent at any time by contacting us.

You will have the right to opt out of receiving marketing communications at any time by:

- contacting us at support@healthmachine.io

- using the 'unsubscribe' link included in all marketing emails you may receive from us

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see 'Your rights' below.

WHO WE SHARE YOUR PERSONAL DATA WITH

We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including:

- third parties we use to help deliver our services to you, eg.g. third party service providers (such as website developers or payment providers, or providers of security infrastructure)

- other third parties we use to help us run our business, e.g. platform hosts and platform analytics providers

We only allow those organisations/individuals/service providers to handle your personal data if we are satisfied, they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above may occasionally also need to share your personal data with:

- external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations

- professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations

- law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations

- other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see 'How to contact us' below).

We will not share your personal data with any other third party.

HOW LONG YOUR PERSONAL DATA WILL BE KEPT

We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a 'need to know basis' have access to such data.

Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data.

TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK

We use third party processors who are based outside of the UK and may have access to your personal data. We comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data.

Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an 'adequacy regulation') further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:

- The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.

- Any country located outside the UK/EEA: we would rely an appropriate safeguards under the UK GDPR, such as by entering into required international data transfer agreements.

In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.

YOUR RIGHTS

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

Access to a copy of your personal data

   The right to be provided with a copy of your personal data.

Correction (also known as rectification)

   The right to require us to correct any mistakes in your personal data.

Erasure (also known as the right to be forgotten)

   The right to require us to delete your personal data—in certain situations.

Restriction of use

   The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.

Data portability

   The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

To object to use

   The right to object:

   - at any time to your personal data being used for direct marketing (including profiling)

   - in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests.

Not to be subject to decisions without human involvement

   The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

   We do not make any such decisions based on data collected by the Services.

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see 'How to contact us' below). You may also find it helpful to refer to the guidance from the UK's Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please complete a request form—available on our website at https://orbihealth.io/contact-us or email, call or write to us—see below: 'How to contact us'. When contacting us please:

- provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and

- let us know which right(s) you want to exercise and the information to which your request relates

KEEPING YOUR PERSONAL DATA SECURE

We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Security measures include encryption at rest and in transit, role-based access control, audit logging, access monitoring, secure data handling practices, and periodic security assessments.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

You are responsible for maintaining appropriate security on the device used to access the Services, including enabling device-level authentication mechanisms where available and safeguarding your login credentials. While we implement robust technical and organisational measures to protect personal data, users are responsible for maintaining appropriate security on the device used to access the Services. Avegen shall not be liable for unauthorised access resulting solely from a user's failure to secure their device or credentials.

The Services may offer optional multi-factor authentication or biometric authentication features within application settings. Users may enable these additional safeguards at their discretion.

We implement data protection by design and by default principles, ensuring that only personal data necessary for the specified purposes is processed and that appropriate technical and organisational measures are embedded within the architecture of the Services.

If you want detailed information from, Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

HOW TO COMPLAIN

Please contact us if you have any queries or concerns about our use of your information (see below 'How to contact us'). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

CHANGES TO THIS PRIVACY POLICY

We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.

HOW TO CONTACT US

You can contact us by email or our App if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

- support@healthmachine.io

- via the 'Contact Us' feature on our App