Mobile App Privacy Policy

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PRIVACY POLICY**

Last Updated: 12/10/25

This Privacy Policy explains how Adptive LLC, doing business as Adptive Care™ Products and Solutions (“Adptive,” “we,” “us,” or “our”), collects, uses, shares, and protects information when you use the Adptive Care™ mobile application (“App”).

This Privacy Policy applies only to the mobile application.

For our Website Privacy Policy, visit https://adptive.ai.

Website policies do not govern data practices within the App.

By downloading or using the App, you agree to the practices described here.

If you do not agree, please discontinue use of the App.

1. Information We Collect

We collect information to support app functionality, provider workflows, adherence tracking, and system improvements.

A. Information You Provide Directly

This may include:

• Name, email, or account registration details
• Exercise responses and check-in feedback
• Subjective sensations or difficulty ratings
• Questions you ask the AI
• Messages sent to providers (if enabled)
• Optional profile details you submit

The App does not require posture images or diagnostic uploads.

B. Provider-Entered Information

If your provider uses the Adptive Care™ platform, they may enter:

• Exercise assignments
• Notes
• Progressions or regressions
• Program instructions

This information is controlled by your provider and is part of your clinical relationship with them.

C. Automatically Collected Information

We may automatically collect:

• Device type, operating system, and version
• App usage logs and interaction data
• Crash reports and diagnostics
• IP address
• Session duration and navigation patterns

This helps us operate and improve the App.

D. Cookies and Mobile Analytics

The App may use:

• Mobile analytics tools
• Crash reporting frameworks
• Local storage
• Authentication tokens

These help maintain app performance, stability, and security.

2. How We Use Information

We use collected data to:

• Deliver app functionality
• Support provider-directed exercise programs
• Provide AI-powered educational cues and explanations
• Respond to user inquiries
• Track adherence, progress, and engagement
• Maintain and improve App performance
• Troubleshoot and debug
• Protect system security
• Develop better algorithms, insights, and recommendations
• Generate anonymized usage reports for providers

We may also use anonymized and aggregated data to:

analyze large-scale patterns, improve guidance quality, support research, and enhance system-wide learning models for better care optimization.

This aggregated data cannot identify individual users.

3. How We Share Information

We do not sell your personal information.

We may share information in the following ways:

A. With Your Healthcare Provider

If your provider invites you to use the App:

• they can view your feedback
• they can see your exercise responses
• they can monitor your adherence
• they can adjust your program
• they can review AI session summaries and insights

Your provider determines how they use this information and remains responsible for clinical decisions.

B. With Service Providers

We may share data with trusted vendors that assist with:

• hosting
• analytics
• data processing
• communications
• authentication
• cloud infrastructure
• security

These vendors are contractually obligated to safeguard your information.

C. For Legal or Compliance Reasons

We may disclose information if:

• required by law
• responding to a court order or subpoena
• necessary to enforce our Terms
• needed to protect rights, safety, or security

D. Business Transfers

If Adptive undergoes a merger, acquisition, financing, or restructuring, App data may be transferred as part of business assets.

4. HIPAA and Health Information Notice

The App may be used by healthcare providers who are subject to HIPAA regulations.

However:

Adptive LLC is not acting as a HIPAA-covered entity or business associate unless a separate Business Associate Agreement (BAA) is executed with a provider organization.

Without a BAA:

• the App should not be used to store or transmit PHI in a way that requires HIPAA compliance
• we do not claim HIPAA-covered status

We implement HIPAA-compatible safeguards, but compatibility alone does not mean HIPAA compliance.

Providers are responsible for:

• their own regulatory obligations
• ensuring appropriate use of the App
• managing PHI disclosures

5. AI Interactions and Data Handling

The App includes AI features that:

• answer exercise-related questions
• provide educational guidance
• support understanding of movements

AI-generated responses:

• are not medical advice
• do not replace clinical judgment
• may be stored for quality, performance improvement, and safety monitoring

User interactions with AI may be used to:

• retrain models
• improve accuracy
• enhance support features
• develop aggregated learning insights

All training uses anonymized or de-identified data.

6. Your Choices and Rights

Depending on your jurisdiction, you may request:

• access to your information
• updates or corrections
• deletion of certain data
• restriction of data processing
• export of your data
• opt-out of certain communications

To request action on your data, contact us using Section 11.

7. Data Retention

We retain information only as long as necessary to:

• operate the App
• support provider workflows
• maintain records
• comply with legal obligations

Aggregated, de-identified data may be retained indefinitely.

8. Data Security

We implement administrative, technical, and physical safeguards designed to protect data, including encryption, access controls, and secure hosting practices.

However:

No system is completely secure, and we cannot guarantee absolute protection from unauthorized access or data breaches.

If a security incident occurs, we will take appropriate steps consistent with applicable laws.

9. Children’s Privacy

The App is not intended for children under 13.

We do not knowingly collect data from children under 13.

If we learn a child has used the App, we will delete their data promptly.

10. Third-Party Links and Integrations

The App may link to external websites or services.

We are not responsible for:

• their content
• their privacy practices
• their security measures

You should review third-party privacy policies before interacting with them.

11. Contact Information

If you have questions about this Privacy Policy or wish to submit a data-related request:

Use the contact form at https://adptive.ai

or email us at: [Insert Support Email]

12. Separate Policies for Website and App

This Privacy Policy applies solely to the Adptive Care™ mobile application.

The Website (https://adptive.ai) has its own Privacy Policy and Terms & Conditions.

Website policies do not apply to the App, and this App Privacy Policy does not apply to Website interactions.