Amelio Health Privacy Policy

Amelio Health (“AH”) believes that the protection and privacy of your Personal Data and Non-Personal Data (collectively “Data” or “Your Data”) is paramount, and we value your right to privacy. AH strives to protect Data that we collect through your interaction with the Amelio Health (AH) website and Amelio Health e-learning platform (“ameliohealth.com”), AH applications (“AH Apps”), AH social media tools (“AH Social Media”) and other digital and non-digital spaces where AH may collect Data (AH Websites, AH Applications, and AH Social Media, and other digital and non-digital spaces, respectively, and collectively, “AH Digital Assets”).

Data you provide to us through your use of AH Digital Assets helps to inform AH about how best to provide you with a fulfilling user experience as it relates to our mission. Our goal is to ensure that Your Data is secure, and that AH only uses Your Data subject to the terms and conditions set forth below.

AH is committed to working with you to obtain a fair and rapid resolution of any queries, complaints, or disputes about privacy. If you have any questions or comments about our Privacy Statement, Cookie Policy or our information collection and data protection practices, please contact amelio@ameliohealth.com.

Amelio Health Privacy Statement

BY USING AH DIGITAL ASSETS, YOU CONSENT TO THE TERMS AND CONDITIONS OF THIS PRIVACY STATEMENT AND TO AH PROCESSING YOUR DATA FOR THE PURPOSES STATED BELOW. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF THIS PRIVACY STATEMENT, PLEASE UNDERSTAND THAT YOUR USE OF AH DIGITAL ASSETS MAY NOT BE OPTIMISED AND IN SOME INSTANCES YOU MAY NOT BE ALLOWED ACCESS TO AH DIGITAL ASSETS THAT REQUIRE AH TO VERIFY YOU AS AN AUTHORISED USER (FOR EXAMPLE, ACCESSING THE AH E-LEARNING PLATFORM OR LOGGING INTO YOUR ACCOUNT).

Data AH Collects

YOU PROVIDE DATA TO US TO CREATE YOUR ACCOUNT OR TRANSACT BUSINESS WITH US.

We collect Data from all visitors (“Users”) to AH Digital Assets in order to interact with you. The following are examples of the types of Data we collect:

1. Personal Data

“Personal Data” is Data that you provide to us, or that we may otherwise collect, that identifies you directly. This also includes information that is associated with you and could potentially identify you, including when combined with other information from or about you. We will not collect or use Personal Data except as stated in this Privacy Statement. Personal Data may include, among other things, name, postal address, telephone number, email address, payment and billing information, subscriptions or a combination of these and other Data.

2. Non-Personal Data

“Non-Personal Data” can be technical information or it can be demographic information, such as your ZIP code, other geolocation data or interests. Non-Personal Data can be information that is automatically collected through the use of cookies, for instance. Non-Personal Data does NOT identify you personally, but may be tied together with other data to identify you. Here are some examples of the Non-Personal Data that is collected via AH Digital Assets and a description of how this information is used.

• Internet Protocol (IP) address: Your IP address is a number that lets computers attached to the Internet know where to send you data, such as the web pages you view. We use this information to deliver our web pages to you upon request, to tailor AH Digital Assets to the interests of our Users and to measure traffic within our AH Websites.
• Cookies: AH Websites use “cookies” to improve functionality and usability. We use this information for planning, tracking and improving the technical functions of our sites and products. By using AH Digital Assets, you are consenting to our use of cookies in accordance with the terms of this Privacy Statement. For more information about cookies, please see below.

Please note that we also consider aggregated data, which is not personally identifiable, to be Non-Personal Data.

3. Automatically Collected Data

When you visit AH Digital Assets, we may automatically collect Data about you through the use of cookies. This Data includes, for example, the browser or operating system that you use, your IP address, and the date and time you have viewed certain pages on AH Digital Assets. Please see the “Cookies” section below to find out more about how we use cookies and similar technologies.

How AH Uses Your Data

WE USE YOUR DATA TO CONTACT YOU, PROVIDE SUPPORT FOR YOUR MEMBERSHIP, CONDUCT SURVEYS AND PERSONALISE OUR SERVICES TO YOU.

Except to the extent necessary to fulfil our business obligations as described in this Privacy Statement, we do not sell, transfer, or otherwise disclose to third parties any of the Personal Data that we collect directly from or about you.

We use Personal Data that is collected on AH Digital Assets in the following ways:

• To provide member-related services;
• To deliver services, such as educational programs, information or newsletters, you request or purchase;
• To alert you to special offers, updated information and other new services from AH or other third parties, or to forward promotional materials;
• To process your order and, if necessary, to contact you regarding the status of your order;
• To fulfil the terms of a promotion;
• To ensure the Websites are relevant to your needs;
• To help us create and publish content that is most relevant to you;
• To request your feedback about your experience with AH;
• To notify you about a material change to this Privacy Policy, if necessary;
• To allow you access to the limited-entry areas of AH Digital Assets; and
• For other business purposes that help optimise your experience as you interact with AH Digital Assets.

Cookies

COOKIES ARE USED TO RECOGNISE USERS WHEN THEY COME BACK TO OUR SITE, TO LEARN ABOUT WHICH PAGES ARE THE MOST VISITED AND TO ASSIST WITH A SINGLE SIGN-ON ACROSS AH DIGITAL ASSETS.

Cookies are text files sent by web servers to web browsers and are stored on the user’s computer or mobile device. If the browser is loading a page and the server requests the Data stored in the cookie, the Data contained within the cookie is sent back to the server.

Cookies contain data about the user’s activities on a website and can be used by web servers to identify and track Users as they navigate different pages on that website, and can identify Users returning to that website.

Cookies may be either “persistent” or “session” cookies. AH uses persistent cookies to enable our website to recognise you when you visit or return to an AH Website. Persistent cookies will remain stored on your computer until you delete them or until they expire automatically at their expiration date. Session cookies are temporary cookies that typically expire at the end of the web browsing session on a website. AH uses session cookies to keep track of you while you navigate AH Digital Assets. A session cookie expires at the end of the user session, i.e. when the web browser is closed.

How AH Uses Cookies

Cookies contain Data that we have previously stored from prior interactions with AH Digital Assets and may allow us to link to other Data we have about you.

AH Digital Assets use Data we obtain from cookies for the following purposes:

• To recognise the user’s computer when the user visits the website.
• To track some user actions only during the current website session.
• To improve the AH Digital Assets’ usability.
• To analyse the use of the AH Digital Assets.*
• To assist AH with administering the AH Digital Assets.
• To share AH Digital Assets User Data with our third-party vendors.

*We use Google Analytics to analyse the use of AH Digital Assets. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on Users’ computers. The Data generated relating to our website is used to create reports about the use of the website. Google will store this Data. More information is available in Google’s privacy policy at https://policies.google.com/privacy?hl=en&gl=us.

Third-Party Cookies

When Users visit AH Digital Assets, third-party cookies (such as Google advertising cookies) may be sent to their computers by AH’s advertisers or service providers. Third-party advertisers may use data obtained from these cookies:

• To track Users’ browsing across multiple websites.
• To build profiles of Users’ web surfing.
• To target advertisements that may be of particular interest to Users.

Managing Your Cookie Settings

Most browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may limit your overall user experience, since it will no longer be personalised to you. It may also stop you from saving customised settings like login information.

Google Analytics Advertising Features AH Has Implemented

AH uses certain Google Analytics Advertising Features, which contain third-party cookies. Google Analytics is a web analytics tool that helps website owners understand how visitors engage with their website. AH follows the Google Analytics policy requirements found at https://support.google.com, which are incorporated herein by reference. The specific Google Analytics Advertising Features that AH uses include only the following: Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting, and Integrated Services that require Google Analytics to collect data via advertising cookies and identifiers. AH does not use the Google remarketing features. You can opt out of the foregoing Google Analytics Advertising Features by following the instructions at this link: https://tools.google.com/dlpage/gaoptout/.

Release of Data to Third Parties

The AH member and affiliate directories are available only to members and affiliates in a members-only section of the site. All members’ and affiliates’ names are listed in the directory, but members have the option to suppress all other information. Personal Data collected as a function of the AH Digital Assets will not be released to third parties except to further the purpose for which you provided the Data and in the following instances:

• To fulfil a service to you, including answering questions or completing an order.
• To unaffiliated third-party service providers, agents or independent contractors who help us maintain our Sites and provide other administrative services to us (including, but not limited to, order processing and fulfilment, providing customer service, maintaining and analysing data, and sending customer communications on AH’s behalf). AH is committed to ensuring that these unaffiliated third parties will not use the Personal Data for any purpose other than to provide the administrative services for which they are responsible.
• To complete your purchase. If you choose to make a purchase on AH Digital Assets, we may collect from you your credit card number, billing address and other Data related to such purchase, and we may use such collected Data in order to fulfil your purchase. We may also provide such Data to unaffiliated third parties as necessary to complete your purchase (for example, to purchase and send out your wearable device).
• To comply with the law or in the good faith belief that such action is necessary to conform to the requirements of law or comply with legal process served on us, protect and defend our rights or property, including the rights and property of AH Digital Assets, or act in urgent circumstances to protect the personal safety of our end users.
• To third parties as part of any corporate reorganisation process, including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
• To track and analyse non-identifying and aggregate usage and volume statistical data from our Users and provide such Data to third parties.

Third-Party Websites and Advertisers

AH Digital Assets may provide you with links to other websites, although we do not necessarily advise that you link to another website. In the event you choose to access such websites, AH is not responsible for any actions or policies of those sites. Further, please note that the third party’s Privacy Policy, Cookie Policy or security practices may differ from AH’s. AH neither assumes responsibility for, nor does it control, endorse or guarantee, any aspect of your use of the linked site. We recommend that you check the Privacy Policy, Cookie Policy and other pertinent security practices of such a party before providing Personal Data to it.

AH may also permit advertisers, third-party ad networks or other advertising companies to serve advertisements on AH Digital Assets. Please be advised that such companies may gather Data about your visit to AH Digital Assets (through cookies, web beacons and other technologies) to enable such advertising companies to market products or services to you, to monitor which ads have been served to your browser and which web pages you were viewing when such ads were delivered. Follow this link to learn more: http://optout.networkadvertising.org/?c=1#!/

PLEASE NOTE THAT THIS POLICY DOES NOT COVER THE COLLECTION AND USE OF DATA BY SUCH ADVERTISING COMPANIES.

Forums, Chat Rooms and Other Public Posting Areas

Please note that any Data you include in a message you post to any chat room, forum or other public posting area is available to others. If you don’t want people to know your email address, for example, don’t include it in any message you post publicly.

PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY DATA IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE DATA THAT YOU DISCLOSE IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS.

Opt-Out of Communications

We communicate with Users on a regular basis via email. For example, we will use your email address to contact you regarding invoice payments or onboarding, to confirm a request you have made of AH, to send you notice of upcoming payments that are due, to send you information about changes to our products and services, or to send notices and other disclosures as required by law. Generally, members cannot opt out of these communications since it is necessary to keep members informed of specific information regarding membership and actions related thereto.

AH provides you the opportunity to exercise an opt-out choice if you do not want to receive other types of communications from us, such as messages or updates from us regarding new services and products offered on AH Digital Assets, or if you do not want us to share your Personal Data with third parties. For emails, you may opt out by clicking on the “unsubscribe” link within the text of an email. We will process your request to unsubscribe as soon as possible, but please be aware that in some circumstances, you may receive a few more messages until the unsubscribe is processed. If you have elected to receive notices to your mobile device via text message, you may opt out by replying “STOP” to such mobile message. You may receive a confirmatory text message in response to your “STOP” request, and you hereby consent to receipt of such confirmation.

As noted above, to opt out of the Google Analytics advertising features outlined above, follow the instructions at this link: https://tools.google.com/dlpage/gaoptout.

Your Choices & Obligations

Data Retention

We keep your Data for as long as you are a Member or as long as your relationship with AH Digital Assets continues, and as required by law. We retain your Data while your membership is active or as necessary to continue to provide Services, including fulfilling orders, accessing AH, ameliohealth.com and AH e-learning, etc. This includes Data you or others provided to us and Data obtained from your use of AH Digital Assets. There may be some instances where we retain Non-Personal Data in a depersonalised or aggregated form.

Rights to Access and Control Your Personal Data

You can access, change or delete Your Data if you have an ameliohealth.com account by logging into your account. You can also email us at amelio@ameliohealth.com.

We collect Your Data in many ways, most often where you provide it to us, and we provide you with several options for collecting, using and sharing of Your Data, including deleting or correcting Data you have provided to us. We offer you settings to control and manage Your Data through your ameliohealth.com account.

To correct or delete wearable device data, please use your device’s app, as AH has read-only access.

For Personal Data that we have about you:

Delete Data: You can ask us to erase or delete all or some of Your Data (for example, if you resign from being a member) and we will work hard to honour all requests in a timely manner. In some instances, we may not be able to delete your Personal Data in order to comply with applicable laws (for example, it is necessary to keep the financial records of a transaction with you).

Change or Correct Data: You can edit some of Your Data through your ameliohealth.com account. You can also ask us to change, update or fix Your Data in certain cases, particularly if it’s inaccurate.

Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of Your Data.

Right to Access and/or Take Your Data: You have the right to see Your Data and take Your Data, and we will work with you to be sure we can provide the most complete set of Your Data and a secure way to transfer Your Data.

Resignation/Account Closure: We will keep some of Your Data even after you resign your membership with AH or close your ameliohealth.com account in order to fulfil any final service requests. Please note that we will retain Your Data even after you have resigned your membership or closed your ameliohealth.com account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfil your request to “unsubscribe” from further messages from us. We will retain depersonalised Data after your account has been closed.

Your Data may continue to be accessed by others until they refresh their cache.

Website Security

No data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any Data you transmit to us and you understand that any Data that you transfer to AH is done at your own risk. However, AH uses website security measures consistent with current best practices to protect its website, email and mailing lists. These measures include technical, procedural, monitoring and tracking steps intended to safeguard data from misuse, unauthorised access or disclosure, loss, alteration or destruction.

Credit card data is transmitted using Secure Sockets Layer (“SSL”) encryption or Transport Layer Security (“TLS”). Member and purchaser Data is a high priority and we use our own protective measures, as well as the capabilities of our software and hardware vendors.

We realise there can be incidents of misuse or unauthorised program incursions, as almost every website, service and user encounters. In those instances, our goals are to move quickly to isolate the problem, ensure or restore proper functionality and minimise any inconvenience to our Users. As appropriate and necessary, AH will notify the relevant authorities of these incidents of misuse or unauthorised program incursions of the AH website.

Data Retention

AH retains information only as long as necessary to accomplish the business purpose for which it was collected and to comply with its legal and contractual obligations, plus 3 years, and then securely disposes of that information or converts it into non-personal information by aggregating it, de-identifying it, or otherwise anonymising it so that it does not directly or indirectly identify you and cannot, with reasonable efforts, resources, and technologies, be used to re-identify you.

Assignment

In the event that all or part of our assets are sold or acquired by another party, or in the event of a merger, you grant us the right to assign the personal and non-personal Data collected via AH Digital Assets.

Contacting AH

Users may contact AH through email at amelio@ameliohealth.com.

EU User Consent

For Users of this website located in the European Union (“EU”), AH follows the Google EU User Consent Policy found at this link: http://www.google.com/about/company/user-consent-policy.html. By voluntarily using this website, EU Users consent to AH’s data collection, sharing, and usage as described above, as well as consent to AH’s storing and accessing of cookies as described above. Any EU User not consenting to such uses of data and cookies by AH should not use this website.

EU Data Subjects

This section applies if you are an EU data subject (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland).

AH is the data controller for processing Personal Data provided to us through AH Digital Assets.

Subject to applicable law, you have the following rights in relation to your Personal Data:

• Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to have it rectified or completed. If we have shared your Personal Data with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
• Right to erasure: You may ask us to delete or remove your Personal Data and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
• Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
• Right to data portability: Effective 25^th February 2019, you have the right to obtain your Personal Data from us that you consented to give us or that is necessary to perform a contract with you. We will give you your Personal Data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
• Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
  • If we are relying on a legitimate interest to process your Personal Data, unless we demonstrate compelling legitimate grounds for the processing; or
  • If we are processing your Personal Data for direct marketing.
• Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
• Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on your prior consent.
• Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorised to hear those concerns.

How We Protect Your Personal Data

We maintain reasonable risk-based physical, technical, and administrative safeguards to protect against unauthorised and accidental disclosure, use, alteration, or destruction of personal data in our possession, and to maintain the confidentiality, integrity, availability, and resilience of our systems, data, and services. We restrict access to Personal Data to those individuals and third parties who need to know the information to accomplish the business purposes described in this Privacy Statement. We are committed to taking appropriate measures to enforce compliance with this Privacy Statement. In addition, we comply with applicable law for protecting Personal Data.

We provide reasonable security controls to protect electronic Data that we receive from you against foreseeable hazards, but please note that no data transmission over the Internet can be guaranteed to be 100% secure. In addition, use of email to transmit Data is insecure and violates AH policy. Please contact us if you need a more secure method for transmitting Data.

Wearable device data is accessed with read-only permission.

Changes in Our Privacy Policy

AH reserves the right to make changes to our Privacy Policy at any time and for any reason without prior notice. Any changes to our Privacy Policy will be posted on this page and other places we deem appropriate so that you are always aware of our policies. We may also contact you by email with changes. Additionally, we will update the “last updated” date below.

LAST UPDATED November 2026