Privacy
Policy

Effective date: July 1, 2025

Introduction

At Thrive AI Health, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.
Remember that your use of Thrive AI Health’s Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
You may print a copy of this Privacy Policy by clicking here.
As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. Upon such changes, we will alert you to material changes by placing a notice on the Thrive AI Health 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.
For individuals in Connecticut, Washington or Nevada, please refer to the Thrive AI Health Consumer Health Data Privacy Policy for additional information about the processing of your consumer health data.

Table of Contents

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” or “sensitive 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.
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
Category of Personal Data (and Examples) Business or Commercial Purpose(s) for Collection Categories of Third Parties With Whom We Disclose this Personal Data
Profile or Contact Data (e.g., name, email, phone number, zip code) • Providing, Customizing and Improving the Services
• Marketing the Services
• Corresponding with You 		• Service Providers
Device/IP Data (e.g., IP address, device ID, device/browser type) • Providing, Customizing and Improving the Services • Service Providers
Web and App Analytics (e.g., page or app interactions) • Providing, Customizing and Improving the Services • Service Providers
Consumer Demographic Data (e.g., age, gender, race, ethnicity) • Providing, Customizing and Improving the Services
• Marketing the Services 		• Service Providers
Professional or Employment-Related Data (e.g., company, job title) • Providing, Customizing and Improving the Services • Service Providers
Social Network Data (e.g., email, phone, username, IP, device ID) • Providing, Customizing and Improving the Services • Service Providers
Categories of Data Considered “Sensitive” Under the State Privacy Laws, such as:
  • Race or ethnic origin
  • Sexual orientation and activity
  • Health data (including mental health data)
  • Location information
  • Temporal/activity information
  • Substance use/abuse/addiction
  • Prescription medication
  • Medical treatment information
  • Health symptom information
  • Pre-existing conditions/chronic disease info
  • Healthcare provider information
  • Purchasing behavior
  • Budget/financial information
 • Providing, Customizing and Improving the Services
• Corresponding with You 		• Service Providers
Inferences Drawn From Other Personal Data (e.g., user attributes) • Providing, Customizing and Improving the Services
• Marketing the Services 		• Service Providers
• Analytics Partners
Other Identifying Information that You Voluntarily Choose to Provide (e.g., emails, communications) • Providing, Customizing and Improving the Services
• Corresponding with You 		• Service Providers
• Parties You Authorize, Access or Authenticate
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  • Providing, Customizing and Improving the Services
    • Creating and managing your account or other user profiles.
    • Processing orders or other transactions.
    • 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 and improvement, including, without limitation, Thrive AI Health’s current and future artificial intelligence and/or machine learning algorithms and models.
    • 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, which may include state comprehensive privacy laws like the California Consumer Privacy Act (referred to herein as the “U.S. State Privacy Laws”).
  • Marketing the Services
    • Marketing and selling the Services.
  • Corresponding with You
    • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Thrive AI Health or the Services.
    • Sending emails and other communications according to your preferences.
In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: 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, Thrive AI Health or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and 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 or obtaining your consent.
We collect Personal Data about you from the following categories of sources:
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  • 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
    • Vendors
      • We may use analytics providers to analyze how you interact and engage with the Services, including how you interact with our websites, applications, products, Services, advertisements, communications, or the third parties that help us provide you with customer support.
      • We may use vendors to obtain information to generate leads and create user profiles.
    • Health Records Partners
      • With your permission and consent, Thrive AI Health is configured to incorporate data about you from healthcare providers, medical testing activities, and other health-related information (including information when you use wearable and other devices, such as pulse rate, body movements, and similar information).
    • Third-Party Credentials
      • If you provide your third-party account credentials, such as 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.
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.
    • Analytics providers for web traffic or usage of our Services.
    • Security and fraud prevention consultants.
    • Support and customer service vendors.
    • Vendors that leverage artificial intelligence, machine learning, or other technology to process content submitted to the Thrive AI Health platform, provide you with the Services, and provide you with intelligence features.
  • Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include:
    • Ad networks.
    • Data brokers.
    • Marketing providers.
    • Analytics providers that assist with our Interest-Based Advertisements.
  • Business Partners. These parties partner with us in offering various services. They include:
    • Businesses that you have a relationship with or provide you with products or services, which may be on a joint or “co-branded” basis. In some cases, the relevant partner’s privacy policy may also apply in addition to this Privacy Policy.
    • Companies that we partner with to offer joint promotional offers or opportunities.
  • Parties You Authorize, Access or Authenticate
    • Third parties you access through the services.
    • Social media services.
    • Other users.

Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing 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 disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Services, share with Business Partners and promote our business, provided that we will not disclose such data in a manner that could identify you.
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.
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 or to modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking here. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/.
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 necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. 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.
For example:
  • We retain your profile information and credentials for as long as you have an account with us.
  • We retain your payment data for as long as we need to process your purchase or subscription.
  • We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.
  • We retain conversation data and preferences you provide us to personalize your experience.
  • We store any images you upload including blood labs, images of food, and other visual material for the purpose of enhancing the coaching experience and ensuring accurate guidance.
We do not knowingly collect or solicit Personal Data from children under 18 years of age; if you are a child under the age of 18, 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 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at privacy@thriveaihealth.com.
If you reside in certain U.S. states such as California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia you may have certain rights afforded to you (as described below) depending on your state of residence. Please see the ‘Exercising Your Rights under U.S. State Privacy Laws’ section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Please note that your rights may be subject to certain conditions or exceptions in accordance applicable U.S. State Privacy Laws.
If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@thriveaihealth.com.
  • Access: You may have the right to request confirmation of or access to the Personal Data that we process about you. You can also request access to a portable copy of your Personal Data. If you are an Oregon resident, you also have the right to request a list of specific third parties, other than natural persons, to which we have disclosed your Personal Data.
  • Deletion: You may have the right to request that we delete the Personal Data that we have collected about you.
  • Correction: You may have the right to request that we correct any inaccurate Personal Data we have collected about you.
  • Portability: You may have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible.

“Selling,” “Sharing,” or “Targeted Advertising”

Depending on your state of residence, you may have the right to opt out from the “sale,” “share,” or disclosure of your Personal Data for the purposes of targeted advertising. These or similar terms may be defined differently depending the applicable U.S. State Privacy Law.
You have the right to opt-out of the sale or share of your Personal Data by following the instructions in the “Exercising Your Rights under U.S. State Privacy Laws” section. Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.
We do not sell, share, or process your Personal Data for the purposes of targeted advertising, and have not done so over the last 12 months.
To our knowledge, we do not sell or share the Personal Data of minors under 18 years of age. If you are between 13 and 18 years of age, you must authorize us to sell your Personal Data. If you are under 13 years of age, your parent or guardian must authorize us to sell your Personal Data.

Processing of Sensitive Personal Data

As needed, we may reach out to you to provide us with Personal Data that may be deemed “sensitive” under certain U.S. State Privacy Laws (“Sensitive Personal Data”). The categories of Sensitive Personal Data we collect and our purposes for collecting such Sensitive Personal Data is described in the ‘Categories of Personal Data We Collect’ section above.
Depending on your state of residence, you may either have the right to opt-in, the right to opt-out, or if you are a California resident, the right to limit our use of your Sensitive Personal Data to permitted purposes, by following the instructions in the “Exercising Your Rights under U.S. State Privacy Laws” section. If you are a California resident, please note that our use and disclosure of Sensitive Personal Data are limited to the permitted purposes set forth in section 7027(m) of the CCPA regulations and, therefore, we do not offer a way for you to submit such a request.

Automated Decision Making and Profiling

Depending on the state of your residence, you may have the right to opt-out the use of automated decision-making technology or from the processing of your Personal Data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, if applicable. However, we do not process your Personal Data in this manner.

Anti-Discrimination

We will not discriminate against you for exercising your rights under applicable privacy laws.  We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under applicable privacy laws. However, we may offer different tiers of our Services as allowed by applicable data privacy laws with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

Other State-Specific Privacy Rights

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 privacy@thriveaihealth.com.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.
Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
To exercise the rights described in this Privacy Policy, you or your Authorized Agent (if applicable and as defined below), must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (such as your Contact or Profile Data), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within the time period required by applicable privacy laws. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

Request to Opt-Out of Sale, Share, and/or Targeted Advertising

As applicable, you may opt-out from any “sales,” “shares,” or targeted advertising through Cookies, by using the following methods:
  • By accessing your cookie consent mechanism by accessing your "Cookie Settings" at the bottom left of our website.
  • By implementing the Global Privacy Control or similar universal privacy control that is legally recognized by a government agency or industry standard and that complies with applicable State Privacy Laws. The signal issued by the control must be initiated by your browser and applies to the specific device and browser you use at the time you cast the signal. Please note this does not include Do Not Track signals.
As applicable, you may opt-out from any other “selling,” unrelated to Cookies by using the following methods:
  • You can complete the online form found here: Privacy Request Form
  • Email us at privacy@thriveaihealth.com

Request to Access, Delete, Correct

As applicable, you may submit a Valid Request for your right to access, delete, correct, or obtain a copy of your Personal Data described in this Privacy Policy by using the following methods:
If you are a California, Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey Oregon, or Texas resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

Appealing a Denial

If you are a Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, or Virginia resident and we refuse to take action on your request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the State Privacy Laws (as applicable). We will respond to your appeal within the time period required under the applicable law. You can submit a Verified Request to appeal by the following methods:
  • Email us at: privacy@thriveaihealth.com (title must include “[STATE OF RESIDENCE] Appeal”)
  • Submit a form at this address: Privacy Request Form
If we deny your appeal, you have the right to contact the Attorney General of your State, including by the following links: Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, and Virginia.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Thrive AI Health and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Thrive AI Health in the U.S. and will be hosted on U.S. servers, and you authorize Thrive AI Health to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses.
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:
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