Privacy Policy

Effective date: July 15, 2025

1. What this Privacy Policy Covers

   This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don't own or control or people we don't manage.

2. Personal Data

   1. Categories of Personal Data We Collect

      This chart details the categories of Personal Data that we collect and have collected over the past 12 months, along with categories of third parties with whom we share that Personal Data:

      Personal Data	Collect	With Whom We Share this Personal Data:
      Profile or Contact Data	First and last name Email	Service Providers Business Partners Parties You Authorize, Access or Authenticate
      Payment Data	Payment card type Credit card or debit card number (full number) Billing address, phone number, and email	Service Providers (specifically our payment processing partner)
      Online Identifiers	Unique identifiers such as account name and passwords	Service Providers
      Device/IP Data	IP address Device ID Domain server Type of device/operating system/browser used to access the Services	Advertising Partners Analytics Partners
      Web Analytics	Web page interactions Referring webpage/source through which you accessed the Services Non-identifiable request IDs Statistics associated with the interaction between device or browser and the Services	Analytics Partners
      Consumer Demographic Data	Age / date of birth Gender Race Ethnicity	Service Providers Business Partners
      Sensory Data	Photos, videos or recordings of your environment	Service Providers Business Partners
      Health Data	Weight Health or exercise activity monitoring Mental health information Blood pressure Glucose monitor Lab test results Medication Medical conditions	Service Providers Business Partners Parties You Authorize, Access or Authenticate

   2. Categories of Sources of Personal Data

      We collect Personal Data about you from the following categories of sources:

      You

      • When you provide such information directly to us.

      • When you create an account or use our interactive tools and Services.

      • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.

      • When you send us an email or otherwise contact us.

      • When you use the Services and such information is collected automatically

      • Through Cookies (defined in the “Tracking Tools, Advertising and Opt-Out” section below).

      • If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.

      • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

      Third Parties

      Social Networks

      • If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

      Third-party Integrations

      • You may direct other individuals or third parties to share data, including Health Data that they collect from you, directly with us in order to enrich your use of the Services.

   3. Our Commercial or Business Purposes for Collecting Personal Data Include:

      Providing, Customizing and Improving the Services

      • Creating and managing your account or other user profiles.

      • Processing orders or other transactions; billing.

      • Providing you with the products, services or information you request.

      • Meeting or fulfilling the reason you provided the information to us.

      • Providing support and assistance for the Services.

      • Improving the Services, including testing, research, internal analytics and product development.

      • Personalizing the Services, website content and communications based on your preferences.

      • Doing fraud protection, security and debugging.

      • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

      Marketing the Services

      • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about AXO or the Services.

      • Sending emails and other communications according to your preferences or that display content that we think will interest you.

      Corresponding with You

      • Marketing and selling the Services.

      Meeting Legal Requirements and Enforcing Legal Terms

      • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.

      • Protecting the rights, property or safety of you, AXO or another party.

      • Enforcing any agreements with you.

      • Responding to claims that any posting or other content violates third-party rights.

      • Resolving disputes.

      We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

   4. How We Share Your Personal Data

      We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a "sale" of your Personal Data. For more information, please refer to the state-specific sections below.

      Service Providers

      • These parties help us provide the Services or perform business functions on our behalf. They include:

        • Hosting, technology and communication providers.

        • Security and fraud prevention consultants.

        • Support and customer service vendors.

        • Payment processors.

          • Our payment processing partner Stripe, Inc. ("Stripe") collects your voluntarily-provided payment card information necessary to process your payment. Please see Stripe's terms of service and privacy policy for information on its use and storage of your Personal Data.

      Analytics Partners.

      • These parties provide analytics on web traffic or usage of the Services. They include:

        • Companies that track how users found or were referred to the Services.

        • Companies that track how users interact with the Services.

      Business Partners.

      • These parties partner with us in offering various services. They include:

        • Businesses that you have a relationship with.

        • Companies that we partner with to offer joint promotional offers or opportunities.

        • Labs or other providers we partner with to provide testing services.

      Parties You Authorize, Access or Authenticate.

      • Third parties you access through the Services.

      • Other users of the Services you choose to share your Personal Data with

      Legal Obligations

      We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under "Meeting Legal Requirements and Enforcing Legal Terms" in the "Our Commercial or Business Purposes for Collecting Personal Data" section above.

      Business Transfers

      All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part).

      Data that is Not Personal Data

      We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

   5. Personal Data of Children

      As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at support@axo.health.

      Minors under 18 years of age may have the personal information that they provide to us through the Site deleted by sending an email to support@axo.health requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.

3. Tracking Tools, Advertising and Opt-Out

   The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support "Do Not Track" requests sent from a browser at this time.

   We use the following types of Cookies:

   • Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.

   • Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

   • Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services' content for those who engage with our advertising.

   • Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled "Information about Interest Based Advertisements."

   You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

   To explore what Cookie settings are available to you, look in the "preferences" or "options" section of your browser's menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.

   Information about Interest-Based Advertisements:

   We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors ("Interest-Based Ads"). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users' activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a "web beacon") from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

   We comply with the Digital Advertising Alliance ("DAA") Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative ("NAI"), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer's online behavior across different websites and properties. To make choices about Interest Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA's or NAI's consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices.

   Links to Other Websites

   This website may contain links to other sites that are not controlled in any way by us. Please be aware of this when you click on any such links; we are not responsible for the privacy practices and/or policies of any website other than our own. Consequently, we strongly suggest that you review the privacy policy of every website you visit, whether or not they are linked to by our own site.

4. Data Security and Retention

   We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

   We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

   We use industry-standard techniques on the Site to help to protect any personal information you have provided to us from loss, misuse or alteration. However, please be aware that no method of electronic storage can ever be 100% secure. Therefore, as is the case with any organization - we are not in a position to guarantee the absolute security of your information. In this regard, we urge you to take every precaution to protect your personal data while you are on the Internet. At a minimum, we encourage you to make sure that you are using a secure browser as you surf the Internet.

   1. Social Media

      We maintain a social media presence, such as a Facebook page, an Instagram page and a Twitter feed. You can interact with us through social media, such as by entering our contests, posting content, sharing material from our Site, and using our social media plug-ins. When you interact with us using social media, we may receive information such as your user ID, your profile picture, photos you post, and similar information, which is often determined by your privacy settings at social media sites. We may use the information for the same types of purposes we describe throughout this Privacy Policy. Your use of social media sites is primarily governed by the site operators' privacy policies and terms of service, and the information you share with us and with others is largely controlled by the privacy settings you have established at those sites.

   2. Do Not Track

      Do Not Track ("DNT") is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium (W3C) has not yet established universal standards for recognizable DNT signals and therefore, AXO, and the Site do not recognize DNT.

5. State Law Privacy Rights

   1. California Resident Rights

      California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the user information we shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information.

      Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties' direct marketing purposes; in order to submit such a request, please contact us at support@axo.health.

   2. Nevada Resident Rights

      If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at support@axo.health with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account. We do not sell Personal Data.

6. Changes to this Privacy Policy

   We're constantly trying to improve our Services, so we may change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the AXO website, by sending you an email and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

7. Contact Information

   If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

   support@axo.health

   Realize Me, Inc.

   21238 68th Ave South

   Kent, WA 98032

   Privacy Policy