This Consumer Health Data Privacy Notice (“Consumer Health Notice”) supplements the Simple Privacy Policy and applies to Consumer Health Data subject to Washington’s My Health My Data Act (RCW ch. 19.373) (the “MHMDA”), Nevada’s SB 370 (NRS 603A.400–603A.560), and the consumer health data provisions of the Connecticut Data Privacy Act, and similar consumer health data privacy laws that apply to our Services.

This Consumer Health Notice applies to you if you are a Washington resident or your Consumer Health Data is collected in Washington, if you are a Nevada consumer, or if you are a Connecticut resident. It does not apply to information we process about you in an employment context.

This Consumer Health Notice applies only to Consumer Health Data that is not exempt from those laws. It does not apply to deidentified data or to other information that is exempt under applicable law.

For purposes of this Consumer Health Notice, “Consumer Health Data” means personal information that is linked or reasonably linkable to you and that identifies or may be used to identify or may be used to infer your past, present, or future physical or mental health status, including information about bodily functions, vital signs, symptoms, measurements, health conditions, treatments, and health-related surgeries or procedures; and any information we process to associate or identify you with such data that is derived or extrapolated from information that is not itself health information, including through algorithmic, inferential or machine-learning means.

In this Consumer Health Notice, “Services” means the Simple mobile application, the simple.life website and its related pages (including Simple app onboarding, quiz and checkout hosted on simple.life domain), and related features we provide, and “Simple,” “we,” “us,” and “our” means Simple.Life Apps Inc.

1. Consumer Health Data We Collect

Depending on how you use the Services, we may collect the following categories of Consumer Health Data:

• profile, onboarding, and eligibility information, such as age, date of birth, sex, height, weight, goals, preferences, and account settings;
• health, wellness, nutrition, weight, fasting, hydration, activity, habit, and progress information that you choose to provide or generate through the Services;
• health conditions, symptoms, medications you report, and other health-status information you choose to provide during onboarding or when using the Services (including in your interactions with our Avo AI assistant);
• body measurement and body-assessment information, including BodyScan photos you choose to upload and the body assessments generated from them;
• self-reported meal descriptions, nutrition-related entries, food images if you choose to upload them, free-text notes, and related in-app logs;
• reminders, tracking history, trend information, summaries, exports, and other records generated through your use of the Services;
• AI-generated estimates, summaries, coaching responses, nudges, personalized cards, or other wellness-support content (including content generated through our Avo assistant), if saved to your account;
• communications with us, including customer support messages and account-related communications; and
• inferences generated from your logs, goals, preferences, and in-app activity, such as wellness, nutrition, engagement, personalization, progress, and content-personalization inferences.

We do not collect all of these categories from every user.

2. Sources of Consumer Health Data

We may collect Consumer Health Data from:

• you, when you create an account, complete onboarding, enter information, upload content, use features, or contact us;
• your device, browser, or app interactions;
• third-party health, fitness, and wellness platforms you choose to connect (for example, Apple Health, Google Fit, and Health Connect), where you grant permission;
• service providers that help us provide, secure, support, or improve the Services; and
• inferences we generate from your use of the Services.

3. How We Use Consumer Health Data

We use Consumer Health Data only where it is necessary to provide the Services you have requested from us, or where you have given us your consent. Where we ask for your consent, we do so separately from our Terms of Use and this Consumer Health Notice, we tell you what we will use the data for, and we do not treat your continued use of the Services as consent. You can withdraw your consent at any time, and withdrawal will not affect processing carried out before you withdrew.

We may use Consumer Health Data to:

• provide, operate, maintain, personalize, and improve the Services;
• provide non-clinical wellness-support features, including tracking, reminders, trend visualizations, summaries, exports, account functionality, and personalized in-app content;
• provide AI-supported features, such as the Avo assistant, nutrition and protein estimation from meal text or images, personalized cards, nudges, summaries, and suggested responses;
• manage your account, preferences, settings, support requests, and communications;
• provide service messages, reminders, in-app alerts, push notifications, and administrative notices;
• conduct internal analytics, quality assurance, debugging, security, fraud prevention, and product improvement;
• comply with legal obligations and enforce our rights; and
• use the data for other purposes with your consent or as permitted by applicable law.

We use Consumer Health Data to provide the Services you request, with your consent where required, or as otherwise permitted by applicable law.

The Services are wellness-support tools only. AI-supported features provide approximate, non-clinical wellness-support outputs. They are not used to make medical decisions, diagnose, treat, or prescribe, and they do not replace the advice of a healthcare professional.

4. How We Share Consumer Health Data

We may share Consumer Health Data only as needed to provide the Services you request, at your direction, with your consent where required, or as otherwise permitted by applicable law.

The categories of Consumer Health Data we may share include the categories listed in Section 1, but only as needed for the purposes described in this Consumer Health Notice. We do not share all categories of Consumer Health Data with every recipient.

We may share Consumer Health Data with the following categories of recipients:

• cloud hosting and infrastructure providers;
• customer support software and communication platforms;
• analytics and performance monitoring providers;
• identity verification, authentication, access-management, and fraud-prevention providers;
• AI/LLM service providers, where used to provide AI-supported features;
• security, logging, audit, and monitoring providers;
• email, SMS communication, and push notification providers;
• payment processors, where relevant to account or transaction support;
• professional advisors, auditors, legal counsel, and compliance service providers;
• authorities, regulators, courts, or other parties where required or permitted by law;
• parties involved in a merger, acquisition, financing, reorganization, bankruptcy, sale, or transfer of all or part of our business or assets; and
• other parties with your consent or at your direction.

Our specific affiliates with whom we share Consumer Health Data are: AM APPS LTD. AM APPS LTD is located outside the United States. We may share Consumer Health Data outside the United States only as needed to provide, secure, maintain, support, analyze, or improve the Services, and subject to appropriate contractual privacy and security obligations and applicable law.

If this changes, we will update this Consumer Health Notice before sharing Consumer Health Data with any specific affiliate where required by applicable law.

We require processors and service providers that process Consumer Health Data on our behalf to process that data only as instructed by us and subject to appropriate confidentiality, privacy, and security obligations. These instructions are set out in a binding contract with each processor, as required by RCW 19.373.060.

5. Third-Party Collection Across Sites

We do not permit third parties to collect Consumer Health Data over time and across unrelated websites or online services through the Services, except as disclosed in this Consumer Health Notice and with consent where required by applicable law.

6. Sale or Sharing of Consumer Health Data

We do not sell Consumer Health Data.

Under the MHMDA and Nevada law, a “sale” means the exchange of Consumer Health Data for monetary or other valuable consideration. We do not exchange your Consumer Health Data for monetary or other valuable consideration, and we do not disclose it to advertising partners. If this ever changes, we will first obtain your valid written authorization in the form required by RCW 19.373.070 and applicable Nevada law. That authorization would be separate and distinct from any consent you give us to collect or share Consumer Health Data, would describe the data and the purchaser, would expire no later than one year after you sign it, and could be revoked by you at any time.

We do not share Consumer Health Data for targeted advertising or for other purposes requiring consent under applicable consumer health data laws unless we have obtained the consent or authorization required by law.

You may revoke consent where required by applicable law by contacting us at dpo@simple.life or by using any privacy controls we make available.

7. Your Consumer Health Data Rights

Depending on where you reside and the law that applies to you, you may have the right to:

• confirm whether we collect, share, or sell Consumer Health Data about you;
• access Consumer Health Data about you;
• receive a list of third parties and affiliates with whom we have shared or sold Consumer Health Data about you, where required by law;
• withdraw consent for certain collection or sharing of Consumer Health Data;
• request deletion of Consumer Health Data about you;
• request correction of inaccurate Consumer Health Data, where required by law; and
• appeal our decision if we deny your request.

You can exercise these rights by contacting us at dpo@simple.life or by using any privacy request tools we make available in the Services.

We may need to verify your identity before fulfilling your request. We will not require you to create a new account to exercise your rights, but we may require you to use an existing account where permitted by law.

We generally respond to verified requests without undue delay and within 45 days, unless a longer period is permitted by applicable law. If an extension is needed, we will notify you as required by law.

If we deny your request, you may appeal by following the instructions in our response or by contacting dpo@simple.life.

Deletion may be subject to legal limitations. For example, we may retain information where required or permitted by law, including for security, fraud prevention, dispute resolution, compliance, accounting, legal claims, or other legally permitted purposes. Where applicable law requires deletion from archived or backup systems, deletion from those systems may be delayed as permitted by law.

Where required by applicable law, we will notify affiliates, processors, contractors, and other third parties with whom we have shared Consumer Health Data of your deletion request.

8. Security

We maintain administrative, technical, and physical safeguards designed to protect Consumer Health Data against unauthorized access, use, disclosure, alteration, or destruction. We restrict access to Consumer Health Data to those of our employees, processors and contractors for whom access is necessary to further the purposes described in this Consumer Health Notice. No system is completely secure, but we take reasonable steps to protect Consumer Health Data in light of its sensitivity.

9. Geofencing

We do not use geofencing around healthcare facilities to identify, track, collect Consumer Health Data from, or send notifications to consumers regarding their health data. We do not implement a geofence around any entity that provides in-person health care services, and we do not implement a geofence within 1,750 feet of any medical facility, mental health facility, or reproductive or sexual health facility.

10. Changes to This Consumer Health Notice

We may update this Consumer Health Notice from time to time. If we make material changes, we will provide notice as required by applicable law. The effective date above indicates when this Consumer Health Notice was last updated. We will not collect, use, or share categories of Consumer Health Data that are not described in this Consumer Health Notice, or use or share Consumer Health Data for purposes not described here, without first updating this Consumer Health Notice and obtaining your consent where required.

11. Contact Us

If you have questions about this Consumer Health Notice or want to exercise your rights, please contact us at:

Simple.Life Apps Inc

8 The Green, Ste A, Dover, County of Kent, 19901, Delaware, U.S.A.

Email: dpo@simple.life