Please read this Privacy Policy carefully together with our Terms of Use to understand our policies and practices regarding your Personal Data (as defined below) and how we will treat it.

This Privacy Policy applies to the 'Evolv' mobile application ("App") hosted on the Apple App Store and Google Play (together, the "Platform", "Services" or "App") which is operated by Evolv Life, part of Time Health Limited (collectively, "Evolv", "we", "our" or "us").

Important Information and Who We Are

By using the Evolv Platform or Services, you consent to the data practices described in this Privacy Policy. If you do not agree with any part of this Privacy Policy, then we cannot make our Platform or Services available to you and you should stop accessing and using them.

This Privacy Policy explains how we collect and use your Personal Data and is provided in accordance with our obligations under applicable privacy and data protection law, including the UK General Data Protection Regulation (UK GDPR), Regulation (EU) 2016/679 (EU GDPR), and the Data Protection Act 2018 ("Applicable Data Protection Law").

For the purposes of this Privacy Policy, the term "Personal Data" means any information which identifies you or which allows you to be identified when combined with other information. It does not include data where your identity has been removed ("Anonymised Data"). For the purposes of Applicable Data Protection Law, Evolv Life Limited is the data controller.

Children and Age Requirements

Our Platform and Services are intended for users aged 13 and over. We do not knowingly collect Personal Data from children under the age of 13. If you are between 13 and 17, you must ask your parent or guardian for permission before using our Platform or Services.

If we become aware that we have inadvertently collected Personal Data from a child under 13, we will take steps to delete that information as soon as possible. If you believe we may have collected information from a child under 13, please contact us.

Information We Collect and How

Basic Identifiers and Contact Information

We collect some information from you when you provide it to us directly, such as via email or through the support feature embedded in our Services. This information may include your name and email address.

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Account Information

When you create an account, we collect your registration details and account preferences.

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Device Information

When you download and use our Services, we automatically collect information on the type of device you use, operating system, resolution, application version, mobile device identifiers (such as your device ID, advertising ID), language, time zone and IP address.

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Usage Information

We collect information automatically about your activity through our Services, such as the date and time you used a service, features you have used, and data generated when you use our Services.

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Location Information

We may collect, with your consent, approximate location information using your IP address.

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Sleep, Health and Lifestyle Data

The core function of Evolv is to help you track your sleep and understand how it is affected by your supplement intake, diet, and exercise habits. To do this, we collect the data you choose to input, which may include sleep duration and quality logs, supplement and medication records, dietary information, and exercise activity. This information may constitute Special Categories of Personal Data (health data) under Applicable Data Protection Law. We process this data solely on the basis of your explicit consent, which you provide when you choose to input it into the App.

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Information from Third Parties

We may receive information about you from our third-party service providers (such as analytics providers), who collect this information through our Services in accordance with their own privacy policies.

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Aggregated Anonymised Data

The anonymised information we collect from you may be combined with information from other anonymous users to produce aggregated anonymised data sets ("Aggregated Data"). Aggregated Data is not considered Personal Data as it does not reveal your identity, and may be used for operational, statistical, and service improvement purposes. If we combine Aggregated Data with your Personal Data in a way that identifies you, we will treat it as Personal Data in accordance with this Privacy Policy.

App Store Compliance, Tracking & Advertising

To comply with App Store privacy requirements (including Apple App Store and Google Play), we are transparent about the following data practices:

• Cross-app/website tracking: We  do not track users across third-party apps or websites for advertising purposes.
• Advertising identifiers: We may collect your device's advertising identifier (such as Apple's IDFA or Google's GAID) to help us measure the effectiveness of our advertising campaigns and to serve relevant ads.
• Sharing for advertising or analytics: We may share device identifiers and usage data with third-party analytics and advertising partners in accordance with their own privacy policies.

Managing Tracking Preferences

• iOS: Go to Settings > Privacy & Security > Tracking and toggle off permission for Evolv.
• Android: Go to Settings > Google > Ads and select "Delete advertising ID" or "Opt out of Ads Personalisation".
• In-App: You can also manage your data-sharing preferences through the Settings section of the Evolv App.

Opting out of personalised advertising does not mean you will stop seeing ads — it means the ads you see may be less relevant to you.

Use of Cookies and Analytics

The Evolv Platform uses "cookies" and similar technologies to provide and personalise our Services. When you first visit our Website, you will be shown a cookie consent banner that allows you to accept or decline non-essential cookies. We will only set non-essential cookies with your consent.

Changing Your Cookie Preferences: You can update your cookie preferences at any time by clicking the "Cookie Settings" link in the footer of our Website, or by clearing your cookies and refreshing the page to trigger the consent banner again.

Our cookies fall into the following categories:

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• Strictly necessary cookies: Required for the Platform to function. No consent is required for these.
• Analytics cookies: Help us understand how visitors interact with our Platform. Only set with your consent.
• Advertising/targeting cookies: Used to deliver relevant advertisements. Only set with your consent.

Providing Personal Data to Third Parties

When using our Platform, the App is distributed through the Apple App Store and Google Play. We recommend you refer to the privacy policy of the relevant App Store.

Sharing with Service Providers and Partners

We may share your Personal Data with third-party service providers who perform functions on our behalf. These may include IT service providers; data hosts and technical support providers; professional advisers including lawyers, bankers, and auditors; and third-party analytics partners.

For Corporate Transactions

We may transfer your Personal Data if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganisation, dissolution, bankruptcy, or other change of ownership or control.

When Required by Law

We may share Personal Data where we are under a duty to disclose it in order to comply with any legal obligation, or to protect the rights, property, or safety of our business, our customers, or others.

Purposes for Which We Will Use Your Personal Data

We may collect and use your Personal Data to operate our Platform and provide the Services you have requested. The legal bases we rely upon include the contract we have with you, your consent, our legitimate interests, and legal or regulatory obligations.

Examples of how we use your Personal Data:

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• To provide and maintain the Services, including registering you as a new user and generating your sleep analysis and insights. Legal basis: performance of a contract with you.
• To administer and protect our Services (including troubleshooting, data analysis, testing, fraud prevention, and hosting). Legal basis: legitimate interests.
• To personalise your experience and deliver content relevant to your interests. Legal basis: consent and/or legitimate interests.
• To communicate with you about updates, new features, and service-related announcements. Legal basis: legitimate interests and/or consent.

Cross-Border Data Transfers

Sharing of Personal Data sometimes involves cross-border data transfers outside of the UK and/or EEA. We only transfer Personal Data to entities in third countries that have provided appropriate safeguards in accordance with this Privacy Policy and applicable law.

Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Your passwords are stored in encrypted form. Information between your App and our servers is transferred in encrypted form using Secure Socket Layer (SSL) or equivalent technology.

We limit access to your Personal Data to those who have a business need to know. We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator where we are legally required to do so.

Data Retention

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will keep your Personal Data for at least 30 days from the date of the last interaction. Should you opt out of using our Services, you will be able to re-join and access your Personal Data within this period.

The retention of your Personal Data will be reviewed regularly. Any Personal Data deemed no longer relevant will be deleted. Where we have anonymised your Personal Data, we may use it indefinitely for analytical and statistical purposes.

Your Rights

Under Applicable Data Protection Law, you have the following rights regarding your Personal Data:

• Right to Withdraw Consent: Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
• Right of Access (SAR): You may request a copy of your Personal Data. We aim to respond within one month at no charge, unless your request is manifestly unfounded or excessive.
• Right to Rectification: You may ask us to correct inaccurate or incomplete Personal Data.
• Right to Erasure: You may ask us to erase your Personal Data in certain circumstances.
• Right to Restriction: You may ask us to restrict how we process your Personal Data in certain circumstances.
• Right to Object: You may object to processing of your Personal Data in certain circumstances.
• Right to Data Portability: You may ask us to transfer your Personal Data to another organisation or to you in certain circumstances.

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Opt-Out and Unsubscribe

Users may opt-out of receiving communications from us by selecting the "Unsubscribe" option on any email communication.

Changes to This Privacy Policy

We may occasionally update this Privacy Policy to reflect company and customer feedback and changes in data protection regulations. We encourage you to periodically review this Privacy Policy.

Contact Information

Evolv Life, part of Time Health Limited welcomes your questions or comments regarding this Privacy Policy. If you believe that we have not adhered to this Privacy Policy, please contact us.

Evolv Life, part of Time Health Limited

Unit 10a Michael Way

Maresfield, Uckfield

England, TN22 2DU

We ask that you try to resolve any issues with us first, although you have a right to lodge a complaint with the Information Commissioner's Office (ICO) at any time.

Information Commissioner's Office

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113

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