Risely Health Privacy Policy

RISELY HEALTH

PRIVACY POLICY

Last Updated: [4.21.26]

1. INTRODUCTION AND SCOPE

This Privacy Policy (“Policy”) describes how Risely Health (“Risely Health,” “we,” “us,” or “our”) collects, uses, discloses, and otherwise processes the personal information of users of the Risely Health Community App (the “App”), our website at www.riselyhealth.com (the “Site”), and any related services we offer (collectively, the “Services”). This Policy also describes the rights and choices you have regarding your personal information.

Risely Health is operated by Lauren Bongiorno Enterprises, Inc., doing business as Risely Health, located at 1415 Kellum Place, Garden City, NY 11530.

By downloading, installing, or using the App or otherwise accessing our Services, you agree to the collection and use of your information as described in this Policy. If you do not agree with this Policy, please do not use our Services.

If you are a resident of the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, please also refer to Section 13 (Additional Information for EEA, UK, and Swiss Residents) for information about your additional rights under applicable data protection law.

2. INFORMATION WE COLLECT

We collect personal information directly from you, automatically through your use of the Services, and in limited cases from third-party sources.

Information You Provide Directly

When you create an account, use the App, or otherwise interact with our Services, we may collect:

Account and Registration Information

• Name and email address

• Password or authentication credentials

• Phone number (if provided)

Diabetes Management Profile Information

• How long you have lived with type 1 diabetes

• The tools and devices you use to manage your diabetes (e.g., insulin pump, CGM device type, pen injections)

Community and User-Generated Content

• Posts, comments, habit check-ins, event participation, and other content you share within the App’s community channels

• Messages and content you submit to the Risely AI coaching assistant

• Feedback, survey responses, and other information you submit to us

Payment Information

• When you purchase a subscription, payment information (such as credit or debit card details) is collected and processed by our payment processor, Stripe. Risely Health does not store your full payment card information. Please refer to Stripe’s Privacy Policy at https://stripe.com/privacy for more information about how Stripe handles your payment data.

Information We Collect Automatically

When you use the App or visit our Site, we may automatically collect:

• Device information, including device type, operating system, and app version

• IP address and general location information derived from your IP address

• Usage data, including features accessed, pages viewed, session duration, and interactions within the App

• App analytics data collected through third-party analytics tools

Information from Third-Party Sources

We may receive limited information about you from third-party service providers who assist us in operating our Services, such as analytics and marketing platforms. We do not purchase or receive personal information from data brokers for the purpose of targeting you with advertising.

3. HOW WE USE YOUR INFORMATION

We use the personal information we collect for the following purposes:

• To create and manage your account and personalize your App experience

• To operate and deliver the Services, including community features, live events, coaching resources, and habit-tracking tools

• To operate and improve Risely AI, including using conversation data in de-identified or aggregated form to train and enhance AI performance

• To process transactions and manage your subscription

• To communicate with you about your account, subscription, and program updates

• To send you marketing communications about our Services, where you have provided consent or where we have a legitimate interest in doing so

• To share community content you post publicly within the App on our social media channels, email newsletter, and other marketing materials, in accordance with Section 5 of this Policy

• To understand how users interact with our Services and to improve our App, content, and features

• To respond to your inquiries and provide customer support

• To detect, prevent, and address fraud, security incidents, and other harmful or illegal activity

• To comply with applicable legal obligations

• To enforce our Terms of Use and other agreements

4. COMMUNITY CONTENT AND MARKETING USE

Risely Health is a community platform. Content you post within the App’s public community channels — including comments, habit check-ins, milestone shares, and other community contributions — may be visible to other App users. Please be thoughtful about the personal health information you choose to share within the community.

From time to time, Risely Health may share or feature content posted publicly within the App’s community channels on our social media accounts, email newsletter, and other marketing or promotional materials. When we do this:

• We will de-identify your content by removing your name and any other information that could directly identify you before sharing it publicly outside the App.

• We will not attribute publicly shared community content to your name or account without your explicit prior consent.

• We will not share content that you post in private or direct messaging features of the App.

If you do not want your community posts to be used in this way, you may contact us at hello@riselyhealth.com to opt out, or you may refrain from posting personally identifiable information in public community channels.

5. HOW WE SHARE YOUR INFORMATION

We do not sell or rent your personal information to third parties. We may share your personal information in the following circumstances:

Service Providers

We share personal information with trusted third-party service providers who assist us in operating the Services, including:

• Stripe — payment processing (https://stripe.com/privacy)

• HubSpot — customer relationship management and email marketing (https://legal.hubspot.com/privacy-policy)

• Analytics providers — to help us understand App usage and improve our Services

• Cloud hosting and infrastructure providers — to store and process data securely

These providers are contractually required to use your information only for the purpose of providing services to us and in accordance with this Policy.

Business Transfers

If Risely Health is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our assets, your personal information may be transferred as part of that transaction. We will provide notice to you of any such change in ownership or control where required by applicable law.

Legal Obligations and Protection of Rights

We may disclose your personal information where we believe in good faith that disclosure is necessary to:

• Comply with applicable law, regulation, legal process, or governmental request

• Enforce our Terms of Use or other agreements

• Detect, prevent, or address fraud, security, or technical issues

• Protect the rights, property, or safety of Risely Health, our users, or the public

Aggregated and De-Identified Information

We may use, share, and disclose aggregated or de-identified information — information that cannot reasonably be used to identify you — for research, analytics, product development, and other business purposes, without restriction.

6. HEALTH AND DIABETES MANAGEMENT DATA

Risely Health collects limited health-related information that you choose to provide, including how long you have lived with type 1 diabetes and the tools you use to manage your condition. This information is used solely to personalize your experience within the App and to improve our Services.

Risely Health does not require you to connect a CGM or share any blood sugar or glucose data. If you choose to share such information voluntarily through the AI coaching assistant or community features, that information is treated as user-provided content under this Policy and is not shared with third parties for any commercial purpose.

Risely Health is not a covered entity or business associate under the Health Insurance Portability and Accountability Act (“HIPAA”). Health-related information you share with us through the App is not protected by HIPAA and is instead governed by this Privacy Policy.

7. RISELY AI COACHING ASSISTANT

The App includes an AI-powered coaching assistant (“Risely AI”). When you interact with Risely AI, the content of your conversations is collected and stored in connection with your account. We may use this data in de-identified or aggregated form to train, improve, and optimize Risely AI and our Services.

Conversation data submitted to Risely AI is treated as user-provided information under this Policy. We do not sell your Risely AI conversation data to third parties. We may share it with service providers who assist us in operating the AI features of the App, subject to confidentiality obligations.

Please do not submit sensitive personal information (such as Social Security numbers, financial account numbers, or highly sensitive medical details beyond what is necessary for coaching support) to Risely AI.

8. COOKIES AND ANALYTICS

Our Site and App may use cookies, pixel tags, and similar tracking technologies to collect information about how you interact with our Services. We use this information to analyze usage, improve performance, and support marketing activities.

We use HubSpot for marketing analytics and customer relationship management. HubSpot may collect information about your interactions with our Site and email communications. You can learn more about HubSpot’s data practices at https://legal.hubspot.com/privacy-policy.

You can control cookie settings through your browser preferences. Note that disabling certain cookies may affect the functionality of our Site or App.

9. YOUR PRIVACY CHOICES

You have the following choices regarding your personal information:

Account Information

You may review and update your account information at any time through your account settings within the App, or by contacting us at hello@riselyhealth.com.

Marketing Communications

You may opt out of receiving marketing emails from us at any time by clicking the “Unsubscribe” link in any marketing email we send. You may opt out of text messages by replying STOP to any text message from us. Even if you opt out of marketing communications, you will continue to receive transactional and account-related messages from us.

Community Content

To opt out of having your public community posts used in Risely Health’s marketing materials, please contact us at hello@riselyhealth.com.

Account Deletion

To permanently delete your account and all associated personal data, please contact us at hello@riselyhealth.com. We will process your request in accordance with applicable law and our data retention obligations.

10. CHILDREN’S PRIVACY

The App is intended for users who are at least 13 years of age. Users between the ages of 13 and 17 must have the consent of a parent or legal guardian to use the App, in accordance with our Terms of Use.

We do not knowingly collect personal information from children under the age of 13. If we discover that we have inadvertently collected personal information from a child under 13, we will promptly delete such information. If you are a parent or guardian and believe we have collected your child’s information without appropriate consent, please contact us at hello@riselyhealth.com.

11. DATA SECURITY

We implement commercially reasonable physical, electronic, and administrative safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include encryption, secure server infrastructure, and access controls limiting personal data to personnel who require it to perform their roles.

No method of electronic transmission or storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account password and for any activity that occurs under your account.

12. DATA RETENTION

We retain your personal information for as long as your account is active or as reasonably necessary to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. When you request deletion of your account, we will delete or anonymize your personal information in accordance with applicable law, except where retention is required by law or legitimate business necessity (such as tax, accounting, or recordkeeping obligations).

13. ADDITIONAL INFORMATION FOR EEA, UK, AND SWISS RESIDENTS

If you are located in the European Economic Area, the United Kingdom, or Switzerland, the following additional information applies to you.

Data Controller

Risely Health (Lauren Bongiorno Enterprises, Inc., doing business as Risely Health) is the data controller responsible for your personal information.

Legal Bases for Processing

We process your personal information on the following legal bases:

• Contract performance — to provide the Services you have subscribed to and manage your account

• Legitimate interests — to improve our Services, prevent fraud, conduct analytics, and for direct marketing to existing members

• Consent — for marketing communications to non-members, and for certain cookie-based tracking

• Legal obligation — to comply with applicable laws and regulations

International Data Transfers

Risely Health is based in the United States. If you access our Services from the EEA, UK, or Switzerland, your personal information will be transferred to and processed in the United States, which may not offer the same level of data protection as your home jurisdiction. Where required, we will implement appropriate safeguards for such transfers, such as Standard Contractual Clauses approved by the European Commission or the UK Information Commissioner’s Office (“ICO”).

Your Rights

Subject to applicable law, you have the following rights regarding your personal information:

• Right to access — to request a copy of the personal information we hold about you

• Right to rectification — to request correction of inaccurate or incomplete personal information

• Right to erasure — to request deletion of your personal information under certain circumstances

• Right to restriction — to request that we limit our processing of your personal information

• Right to data portability — to receive your personal information in a structured, machine-readable format

• Right to object — to object to processing based on legitimate interests or for direct marketing purposes

• Right to withdraw consent — where processing is based on consent, to withdraw that consent at any time without affecting the lawfulness of prior processing

To exercise any of these rights, please contact us at hello@riselyhealth.com. We will respond to your request within the timeframe required by applicable law. You also have the right to lodge a complaint with your local data protection supervisory authority.

For UK residents, the relevant supervisory authority is the Information Commissioner’s Office (ICO), available at https://ico.org.uk. For EEA residents, a list of supervisory authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

14. NOTICE TO NEW YORK RESIDENTS

Risely Health is based in New York. If you are a New York resident and have questions or complaints regarding this Policy or our privacy practices, you may contact us at hello@riselyhealth.com or by mail at the address below. You may also contact the New York State Attorney General’s office for assistance with privacy-related complaints.

15. THIRD-PARTY LINKS AND SERVICES

Our App and Site may contain links to third-party websites or integrate with third-party services. This Policy does not apply to those third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services you access through our App or Site before providing them with your personal information.

16. UPDATES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other business reasons. When we make material changes to this Policy, we will notify you via in-app notification or the email address associated with your account, and we will update the “Last Updated” date at the top of this document. Your continued use of the Services following any update constitutes your acceptance of the revised Policy. If you do not agree with the changes, please discontinue use of the Services and contact us to have your information removed.

17. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact us at:

Risely Health

1415 Kellum Place

Garden City, NY 11530

Email: hello@riselyhealth.com

Website: www.riselyhealth.com