Privacy Notice

Last Modified: July 13, 2026

This Privacy Notice explains how Forela Health, Inc. (“Forela Health, Inc.”) collects, uses, discloses, and otherwise processes personal data in connection with any specific product, service, or application that references or links to this Privacy Notice.

This Privacy Notice does not address our privacy practices relating to Forela Health, Inc. job applicants, employees and other employment-related individuals, nor data that is not subject to applicable data protection laws (such as deidentified or publicly available information in certain jurisdictions). This Privacy Notice is also not a contract and does not create any legal rights or obligations not otherwise provided by law.

Our Role in Processing Personal Data

Data protection laws sometimes differentiate between “controllers” and “processors” of personal data. A “controller” determines the purposes and means (the why and how) of processing personal data. A “processor,” which is sometimes referred to as a “service provider,” processes personal data on behalf of a controller subject to the controller’s instructions.

This Privacy Notice describes our privacy practices where we are acting as the controller of personal data. In certain circumstances, we may process data on behalf of enterprise customers in accordance with their instructions, we may act as a processor of personal data. Where we act as a processor, the applicable customer’s privacy notice governs the processing of your personal data, and we recommend referring to that notice for details on how they engage processors, like us, to process personal data on their behalf. We are generally not permitted to respond to individual requests relating to personal data we process on behalf of our customers, so we recommend directing any requests to the relevant customer.

Our Collection and Use of Personal Data

The categories of personal data we collect depend on how you interact with us and our services. For example, you may provide us your personal data directly when you sign up for our mailing list, register for an account, make a purchase, post a review, participate in an event, contest, promotion or survey, engage with us as a representative of your organization in connection with a business relationship, or otherwise contact us or interact with us.

We also collect personal data automatically when you interact with our websites and other services and may also collect personal data from other sources and third parties.

We collect the following categories of personal data individuals provide us:

Contact Information, including first and last name, phone number, email address, mailing address, and communication preferences. We use this information primarily to fulfill your request or transaction, to communicate with you directly, and to send you marketing communications in accordance with your preferences.

Account Information, including first and last name, email address, phone number, account credentials or one-time passcodes, and the products or services you are interested in, purchased, or have otherwise used. We use this information primarily to administer your account, provide you with our products and services, communicate with you regarding your account and your use of our products and services, and for customer support purposes.

Professional and Business Information, including job title, employer or company name, department, business contact details (such as work email, work phone number, and business address), professional role, and information about your organization’s relationship with us. We use this information primarily to manage and facilitate our business relationships, provide products and services to the organization you represent, communicate with you in your professional capacity, and administer enterprise accounts.

Sensitive Personal Data, including information about health conditions, symptoms (such as immune flares, pain levels, and fatigue markers), menstrual cycles, hormonal shifts, gut health indicators, previous diagnoses, treatment timelines, specialist insights, and other health-related information you provide through our platform, including through our adaptive questionnaires. We process sensitive personal data only with your affirmative consent or where otherwise permitted or required by applicable law. You may withdraw your consent to the processing of sensitive personal data at any time by contacting us as set forth in the Contact Us section below, though doing so may affect our ability to provide certain features of our services. We apply additional technical and organizational safeguards to sensitive personal data, including encryption, access controls, and data minimization practices.

Behavioral and Lifestyle Data, including information about daily habits, environmental triggers, stress levels, nutritional factors, and other lifestyle inputs you provide through our platform. We use this information to provide personalized, adaptive guidance and to help identify patterns and correlations relevant to your health.

Customer Content, including any files, documents, audio, videos, images, data, or communications you choose to input, upload, or transmit to our products and services. We use this content primarily to provide you with our products and services, to facilitate your requests, and to improve our products and services (including by training or fine-tuning our and our third-party providers’ artificial intelligence and machine learning models).

Payment Information, including payment card information, billing address, and other financial information (such as, routing and account number). Please note that we use third-party payment providers, including Stripe, to process payments made to us. We do not retain any personally identifiable financial information, such as payment card number, you provide these third-party payment providers in connection with payments. Rather, all such information is provided directly by you to our third-party payment providers. The payment provider’s use of your personal data is governed by their privacy notice. To view Stripe’s privacy policy, please click here.

Event, Contest, Promotion, and Survey Information, including information provided when you sign up for an event, enter a contest or promotion, complete a survey or submit a testimonial. We use this information primarily to administer and facilitate our products and services, respond to your submission, communicate with you, conduct market research, inform our marketing and advertising activities, improve and grow our business, and facilitate the related event, contest, promotion, or survey.

Feedback and Support Information, including the contents of custom messages sent through the forms, chat platforms, including our online live chat or automated chat functions, email addresses, or other contact information we make available to customers, as well as recordings of calls with us, where permitted by law (including through the use of automated or artificial intelligence tools provided by us or our third-party providers). We use this information primarily to investigate and respond to your inquiries, to communicate with you via online chat, email, phone, text message or social media, and to improve our products and services.

We, and our third-party partners, automatically collect information you provide to us and information about how you access and use our products and services when you engage with us. We typically collect this information through the use of a variety of our own and our third-party partners’ automatic data collection technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. Information we collect automatically about you may be combined with other personal data we collect directly from you or receive from other sources.

We, and our third-party partners, use automatic data collection technologies to automatically collect the following data when you use our services or otherwise engage with us:

Information About Your Device and Network, including the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). We employ third-party technologies designed to allow us to recognize when two or more devices are likely being used by the same individual and may leverage these technologies (where permitted by law) to link information collected from different devices.

Information About the Way Individuals Use Our Services and Interact With Us, including the site from which you came, the site to which you are going when you leave our services, how frequently you access our services, whether you open emails or click the links contained in emails, whether you access our services from multiple devices, and other browsing behavior and actions you take on our services (such as the pages you visit, the content you view, videos you watch, the communications you have through our services, and the content, links and ads you interact with). We employ third-party technologies designed to allow us to collect detailed information about browsing behavior and actions that you take on our services, which may record your mouse movements, scrolling, clicks, and keystroke activity on our services and other browsing, search or purchasing behavior. These third-party technologies may also record information you enter when you interact with our products or services, or engage in chat features or other communication platforms we provide.

Information About Your Location, including general geographic location that we or our third-party proiders may derive from your IP address, as well as more precise geolocation when you grant us access through your device settings.

All of the information collected automatically through these tools allows us to improve your experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our products and services, to offer communications features such as live and automated chat, and to improve the effectiveness of our products, services, offers, advertising, communications and customer service. We may also use this information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our products and services.

For information about the choices you may have in relation to our use of automatic data collection technologies, please refer to the Your Privacy Choices section below. For additional details about the cookies we use on our websites and to adjust your preferences with regard to those cookies, please visit our “Cookie Preferences” manager linked in the footer of our websites.

We may receive the same categories of personal data as described above from the following sources and other parties:

Our Affiliates: We are able to offer you the products and services we make available because of the hard work of our team members across all Forela Health, Inc. entities. To provide our products and facilitate our services, Forela Health, Inc. entities receive personal data from other Forela Health, Inc. entities for purposes and uses that are consistent with this Privacy Notice. For example, we may receive your contact information to process and fulfill your order from a representative at your local Forela Health, Inc. entity.

Single Sign-On: We may provide you the ability to log in to our services through certain third-party accounts you maintain. When you use these single sign-on protocols to access our services, we do not receive your login credentials for the relevant third-party service. Instead, we receive tokens from the single sign-on protocol to help identify you in our system (such as by your username) and confirm you successfully authenticated through the single sign-on protocol. This information allows us to more easily provide you access to our products and services.

Mobile Sign-On: We may provide you the ability to log in to our mobile applications or authenticate yourself using facial, fingerprint, or other biometric recognition technology available through your mobile device. If you choose to utilize these login features, information about your facial geometry, your fingerprint, or other biometric information will be collected by your mobile device for authentication purposes. We do not store or have access to this biometric information. Instead, your mobile device will perform the biometric authentication process and only let us know whether the authentication was successful. If the authentication was successful, you will be able to access the applicable mobile application or feature without separately providing your credentials. For more details, please refer to the biometric authentication guides offered by your device provider.

Social Media: When you interact with our services through other social media networks, such as when you follow us or share our content on other social networks, we may receive some information that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network, and may include profile information, profile picture, username, and any other information you permit the social network to share with third parties. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information primarily to operate, maintain, and provide to you the features and functionality of our products and services, as well as to communicate directly with you, such as to send you messages about features that may be of interest to you.

Advertisers, Influencers, and Publishers: We engage in advertising both on our services and through third-party services. Advertisers, influencers, and publishers may share personal data with us in connection with our advertising efforts. For example, we may obtain information about whether an advertisement on our services led to a successful engagement between you and a third-party advertiser.

Business Partners: We may receive your information from our business partners, such as companies that offer their products and/or services as a part of or in connection with our services. For example, certain of our products and services allow our customers to integrate third-party services. If you choose to leverage these third-party service integrations, we may receive confirmation from our business partner regarding whether you are an existing customer of their services.

Service Providers: Our service providers that perform services on our behalf, such as analytics and certain marketing providers, collect personal data and often share some or all of this information with us. For example, we receive personal data you may submit in response to requests for feedback to our survey providers.

Your Organization or Employer: If you interact with us as a representative of an enterprise customer, partner, or vendor, we may receive your personal data (such as your name, job title, and business contact details) from your organization. For example, an administrator at your company may provide us your information when setting up your account or designating you as a point of contact under a business agreement.

Other Sources: We may also collect personal data about you from other sources, including publicly available sources, or through transactions such as mergers and acquisitions.

Inferences: We may generate inferences or predictions about you and your interests and preferences based on the other personal data we collect and the interactions we have with you.

In addition to the primary purposes for using personal data described above, we may also use personal data we collect to:

  • Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to facilitate payment for our products and services, or to deliver the services requested;
  • Communicate with you, including via email, text message, chat, social media and/or telephone calls;
  • Facilitate the relationship we have with you and, where applicable, the company you represent;
  • Request you provide us feedback about our product and service offerings;
  • Address inquiries or complaints made by or about an individual in connection with our products or services;
  • Create and maintain accounts for our users;
  • Verify your identity and entitlement to our products and services;
  • Register you for and provide you access to events, contests, sweepstakes, and surveys;
  • Market our products and services to you, including through email, phone, text message, push notification, and social media;
  • Administer, improve, and personalize our products and services, including by recognizing you and remembering your information when you return to our products and services;
  • Develop, operate, improve, maintain, protect, and provide the features and functionality of our products and services (Including by training or fine-tuning our and our third-party providers’ artificial intelligence and machine learning models);
  • Identify and analyze how you use our products and services;
  • Infer additional information about you from your use of our products and services, such as your interests;
  • Create aggregated or de-identified information that cannot reasonably be used to identify you, which information we may use for purposes outside the scope of this Privacy Notice;
  • Conduct research and analytics on our user base and our products and services, including to better understand the demographics of our users;
  • Improve and customize our products and services to address the needs and interests of our user base and other individuals we interact with;
  • Test, enhance, update, and monitor the products and services, or diagnose or fix technology problems;
  • Help maintain and enhance the safety, security, and integrity of our property, products, services, technology, assets, and business;
  • Defend, protect, or enforce our rights or applicable contracts and agreements (including our Terms of Use), as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;
  • Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Forela Health, Inc. and others;
  • Facilitate business transactions and reorganizations impacting the structure of our business;
  • Comply with contractual and legal obligations and requirements;
  • Fulfill any other purpose for which you provide your personal data, or for which you have otherwise consented.

As noted above, we may use your personal data to improve our services and train or fine-tune the artificial intelligence and machine learning models that power our platform and services.

Our platform uses artificial intelligence and machine learning technologies to provide our adaptive care services. Specifically, we use AI and automated processing to:

  • Deliver evidence-based, daily adaptive guidance that evolves with your changing symptoms and health data;
  • Generate structured, decision-ready summaries for healthcare providers you authorize to receive such information;
  • Administer adaptive questionnaires designed to gather health metrics while minimizing cognitive burden;
  • Identify patterns, correlations, and inferences across your health data to personalize your experience; and
  • Train and improve our artificial intelligence and machine learning models using aggregated, de-identified, or pseudonymized data where possible, and personal data where you have provided consent or as otherwise permitted by law.

Our AI-driven features do not make autonomous medical decisions. The adaptive guidance and summaries we generate are intended to support — not replace — the judgment of you and your healthcare providers. You may opt out of having your personal data used for AI model training purposes by contacting us as set forth in the Contact Us section below.

Our Disclosure of Personal Data

We disclose or otherwise make available personal data in the following ways:

To Your Healthcare Providers: As part of our Services, we may disclose your personal information, including your health-related information, to healthcare providers that you designate. You have the ability to grant your healthcare providers direct access to view some or all of your Forela records. When you choose to enable this access, your designated healthcare providers will be able to access your information automatically on an ongoing basis until you modify or revoke that access. You control which healthcare providers receive access and the scope of information they can view. You may grant, modify, or revoke a healthcare provider's access to your information at any time through your account settings in the app.

To Our Affiliates: We are able to offer you the products and services we make available because of the hard work of our team members across Forela Health, Inc. entities. To provide our products and facilitate our services, Forela Health, Inc. entities disclose personal data to other Forela Health, Inc. entities for purposes and uses that are consistent with this Privacy Notice. For example, the Forela Health, Inc. entity responsible for our website may disclose your contact information to a/n Forela Health, Inc. entity in your region to facilitate communications between you and a local Forela Health, Inc. representative.

To Your Organization: Where you access or use our services as an authorized user under an enterprise account, we may disclose personal data (including account activity, usage information, and Customer Content) to the organization that manages or sponsors your account. Your organization’s use of such personal data is governed by its own internal policies, and we encourage you to refer to your organization’s privacy practices for more information.

To Marketing Providers: We coordinate and share personal data with our marketing providers in order to advertise and communicate with you about the products and services we make available.

To Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our services, on other websites and services, and across other devices. These parties may collect information automatically from your browser or device when you visit our websites and other services through the use of cookies and related technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

To Business Partners: We may share personal data with our business partners, or we may allow our business partners to collect personal data directly from you in connection with our services. Our business partners may use your personal data for their own business and commercial purposes, including to send you information about their products and services.

To Service Providers: We engage other third parties to perform certain services on our behalf in connection with the uses of personal data described in the sections above. Depending on the applicable services, these service providers may process personal data on our behalf or have access to personal data while performing services on our behalf.

To Other Businesses as Needed to Provide Services: We may share personal data with third parties you engage with through our services or as needed to fulfill a request or transaction including, for example, payment processing services.

In Connection with a Business Transaction or Reorganization: We may take part in or be involved with a business transaction or reorganization, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose, transfer, or assign personal data to a third party during negotiation of, in connection with, or as an asset in such a business transaction or reorganization. Also, in the unlikely event of our bankruptcy, receivership, or insolvency, your personal data may be disclosed, transferred, or assigned to third parties in connection with the proceedings or disposition of our assets.

To Facilitate Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement:

  • in connection with the establishment, exercise, or defense of legal claims;
  • to comply with laws or to respond to lawful requests and legal process;
  • to protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
  • to detect, suppress, or prevent fraud;
  • to reduce credit risk and collect debts owed to us;
  • to protect the health and safety of us, our customers, or any person; or
  • as otherwise required by applicable law.

With Your Consent or Direction: We may disclose your personal data to certain other third parties or publicly with your consent or direction. For example, with your permission, we may post your testimonial on our websites.

Your Privacy Choices

Email Communication Preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in any of our email communications. Please note you cannot opt-out of service-related email communications (such as, account verification, transaction confirmation, or service update emails).

Push Notification Preferences: You can stop receiving push notifications from us by changing your preferences in your device’s notification settings menu or in the applicable service-specific application. Please note we do not have any control over your device’s notifications settings and are not responsible if they do not function as intended.

Direct Mailing Preferences: You can stop receiving promotional direct mail communications from us by contacting us as set forth in the Contact Us section below. Please note this opt-out does not affect any mailings that are controlled by third parties that may feature or mention our services.

Where we have your consent for the processing of your personal data (e.g., when you opt in to receive certain types of marketing communications from us), you may withdraw your consent by following the instructions provided when your consent was requested or by contacting us as set forth in the Contact Us section below.

Certain of our services may provide you the ability to adjust your preferences regarding our use of automatic data collection technologies. For example, there is a “Cookie Preferences” manager linked in the footer of our websites that allows you to adjust your preferences regarding certain automatic data collection technologies on the specific website you are visiting for the specific device and browser you are using at that time (which means you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting).

You may be able to utilize third-party tools and features to restrict our use of automatic data collection technologies. For example, (i) most browsers allow you to change browser settings to limit automatic data collection technologies on websites, (ii) most email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies, and (iii) many devices allow you to change your device settings to limit automatic data collection technologies for device applications. Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using our services, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.

We engage third parties to help us facilitate targeted advertising designed to show you personalized ads based on predictions of your preferences and interests developed using personal data we maintain and personal data our third-party partners obtain from your activity over time and across nonaffiliated websites and other services. The data we and our third-party partners use for purposes of facilitating targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research, are primarily collected through the use of a variety of automatic data collection technologies, including cookies, web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help link the personal data we and our third-party partners collect to the same person, or otherwise target advertising to an individual on a third-party website or platform.

In addition to taking the steps set forth in the Automatic Data Collection Preferences section above, you may be able to further exercise control over the advertisements that you see by leveraging one or more targeted advertising opt-out programs. For example:

Device-Specific Opt-Out Programs: Certain devices provide individuals the option to turn off targeted advertising for the entire device (such as Apple devices through their App Tracking Transparency framework or Android devices through their opt out of ads personalization feature). Please refer to your device manufacturer’s user guides for additional information about implementing any available device-specific targeted advertising opt-outs.

Digital Advertising Alliance: The Digital Advertising Alliance allows individuals to opt out of receiving online interest-based targeted advertisements from companies that participate in their program. Please follow the instructions at https://optout.aboutads.info/?c=2&lang=EN for browser-based advertising and https://www.youradchoices.com/appchoices for app-based advertising to opt out of targeted advertising carried out by our third-party partners and other third parties that participate in the Digital Advertising Alliance’s self-regulatory program.

Network Advertising Initiative: The Network Advertising Initiative also provides individuals instructions for further controlling how information is used for online advertising. Please follow the instructions at https://thenai.org/how-to-opt-out/ to exercise these controls.

Platform-Specific Opt-Out Programs: Certain third-party platforms provide individuals the option to turn off targeted advertising for the entire platform (such as certain social media platforms). Please refer to your platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.

Please note that when you opt out of receiving interest-based advertisements through one of these programs, this does not mean you will no longer see advertisements from us or on our services.  Instead, it means that the online ads you do see from relevant program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, program participants may still use automatic data collection technologies to collect information about your use of our services, including for analytics and fraud prevention as well as any other purpose permitted under the applicable advertising industry program.

If you have any questions about reviewing, modifying, or deleting your personal data, you can contact us as set forth in the Contact Us section below. We may not be able to modify or delete your personal data in all circumstances.

Certain of our third-party providers and partners offer additional ways that you may exercise control over your personal data, or automatically impose limitations on the way we can use personal data in connection with the services they provide:

Device-Specific / Platform-Specific Preferences: The device and/or platform you use to interact with us (such as your mobile device or social media provider), may provide you additional choices with regard to the data you choose to share with us. For example, many mobile devices allow you to change your device permissions to prevent our products and services from accessing certain types of information from your device (such as your contact lists or precise geolocation data), and many social media platforms allow you to change your platform permissions to prevent integrated products and services from accessing certain types of information connected with your profile. Please refer to your device or platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs.

Google Analytics: Google Analytics allows us to better understand how our customers interact with our services.  For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website here: www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Add-On here: https://tools.google.com/dlpage/gaoptout/.We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our services.  You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://myadcenter.google.com/?ref=help-center.

Children’s Personal Data

While parents may choose to upload data about their children to our Services, our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 13. If an individual is under the age of 13, they should not use our services or otherwise provide us with any personal data. If a child under the age of 13 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 13, we will promptly delete that personal data.

Security of Personal Data

We have implemented reasonable physical, technical, and organizational safeguards that are designed to protect your personal data. In addition, we take steps designed to ensure any third party with whom we share personal data provides a similar level of protection. However, despite these controls, we cannot completely ensure or warrant the security of your personal data.

Data Retention

We retain personal data for as long as reasonably necessary to fulfill the purposes for which it was collected, to maintain our relationship with you, to comply with our legal obligations, to resolve disputes, and to enforce our agreements. The retention period for specific categories of personal data depends on the nature of the data, the purposes for which it is processed, applicable legal requirements, and our legitimate business needs. When personal data is no longer necessary for the purposes described in this Privacy Notice, we will securely delete or de-identify such data in accordance with our data retention policies and applicable law. You may request deletion of your personal data by contacting us as set forth in the Contact Us section below.

Third-Party Websites and Services

Our websites and other services may include links to or redirect you to third-party websites, plug-ins, applications, or other services, including social media services where you may connect with us. Third-party websites and other services may also reference or link to our websites and services. This Privacy Notice does not apply to any personal data practices of these third-party websites, plug-ins, applications, or other services. To learn about these third parties’ personal data practices, please visit their respective privacy notices.

Region-Specific Disclosures

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:

United States: If you are a resident of the United States, please click here for additional U.S.-specific privacy disclosures, including a description of the personal data rights made available to residents of certain states under applicable law.

Updates to This Privacy Notice

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on this website or our other platforms, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please contact us at: privacy@forela.health or (213) 313-2497

ADDITIONAL UNITED STATES PRIVACY DISCLOSURES

These disclosures supplement the information contained in our Privacy Notice by providing additional information about the privacy rights available to individual residents of certain states in the United States and our personal data processing practices relating to those individuals. For a detailed description of how we collect, use, disclose, and otherwise process personal data, please read our Privacy Notice.

Nevada Residents

If you are a resident of the state of Nevada in the United States, you have the right to opt out of the sale of your personal data. Although we do not currently sell personal data of Nevada residents (as defined under Nevada law), you may submit a request to opt-out of the sale of your personal data by emailing privacy@forela.health.

California Residents

California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal data to third parties for their direct marketing purposes. It is company policy that we do not disclose personal data to third parties for their direct marketing purposes if a consumer has opted out. To opt out of having your personal data disclosed to third parties for their direct marketing purposes, please email privacy@forela.health.

Connecticut Residents

If you are a resident of the state of Connecticut in the United States, the following supplementary disclosures apply to you.

We disclose all of the categories of personal data we collect to the categories of recipients set forth in the Our Disclosure of Personal Data section of our Privacy Notice. Our disclosure of personal data to the following categories of third parties qualifies as the sale of personal data or the sharing or processing of personal data for the purpose of displaying advertisements that are selected based on personal data obtained or inferred over time from an individual’s activities across businesses or distinctly-branded websites, applications, or other services (otherwise known as “targeted advertising” or “cross-context behavioral advertising”) under certain privacy laws:

Ad Networks and Advertising Partners: The categories of Personal Data sold and/or shared includes: internet service provider, operating system, device type/model/manufacturer, device ID, click stream data, browser type, time and date you visited our Website, Ad ID, IP address, general geolocation (derived from your IP address), URLs visited.

Subject to certain legal limitations and exceptions, you may be able to limit or opt-out of the sale of personal data or the processing of personal data for purposes of targeted advertising (as described in the Your Additional U.S. Privacy Choices section below).

Please note we do not sell the personal data of individuals we know to be less than 16 years of age or share such information for targeted advertising purposes.

The following personal data elements we collect may be classified as “sensitive” under certain privacy laws:

Health Information, such as information about health conditions, symptoms (such as immune flares, pain levels, and fatigue markers), menstrual cycles, hormonal shifts, gut health indicators, previous diagnoses, treatment timelines, specialist insights, and other health-related information you provide through our platform, including through our adaptive questionnaires.

Behavioral and Lifestyle Data, including information about daily habits, environmental triggers, stress levels, nutritional factors, and other lifestyle inputs you provide through our platform. We use this information to provide personalized, adaptive guidance and to help identify patterns and correlations relevant to your health

We use sensitive personal data for the purposes set forth in the Our Collection and Use of Personal Data section of our Privacy Notice. Subject to certain legal limitations and exceptions, you may be able to withdraw your consent for our processing of sensitive personal data (as described in the Your Additional U.S. Privacy Choices section below).

We may at times receive, or process personal data to create, deidentified information that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified information, we will maintain and use the information in deidentified form and not attempt to reidentify the information except as required or permitted by law.

We do not conduct automated processing of personal data for the purposes of evaluating, analyzing, or predicting an individual’s personal aspects in furtherance of decisions that produce legal or similarly significant effects. As a result, we do not provide a right to exercise control over such forms of automated decision-making and profiling.

Subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

  • Right to Know: The right to confirm whether we are processing personal data about you.
  • Right to Access & Portability: The right to obtain access to the personal data we have collected about you and, where required by law, the right to obtain a copy of the personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
  • Right to Correction: The right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of the personal data.
  • Right to Control Over Sensitive Personal Data: The right to exercise control over our collection and processing of certain sensitive personal data.
  • Right to Opt-Out of Targeted Advertising: The right to direct us not to use or share personal data for certain targeted advertising purposes.
  • Right to Opt-Out of Sales: The right to direct us not to sell personal data to third parties.
  • Right to Deletion: The right to have us delete personal data we maintain about you.

You may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

Submitting Privacy Rights Requests

Please submit a request specifying the right you wish to exercise by:

  • Completing our online form found here; or
  • Calling our toll-free U.S. telephone number: (213) 313-2497.

To exercise your right to opt-out as it relates to the use of cookies and related technologies that involve the sale of personal data or the use of personal data for targeted advertising purposes, you can enable the Global Privacy Control which means that any cookies that constitute sales or are used for targeted advertising should already be turned off. Please note this opt-out tool is website, device, and browser specific, so you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting. In addition, you can follow the other steps set forth in the Automatic Data Collection Preferences and Targeted Advertising Preferences sections of the Your Privacy Choices section of our Privacy Notice to further exercise control over automatic data collection technologies.

Before processing your request to exercise certain rights (including the Right to Know, Access & Portability, Correction, and Deletion), we will need to verify your identity and confirm you are a resident of a state that offers the requested right(s). In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. As a result, we require requests submitted through our online form and toll-free number to include first and last name, email address, phone number, state of residency and/or the date of your last transaction with us.

In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or where you are not a resident of an eligible state.

Submitting Authorized Agent Requests

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Appealing Privacy Rights Decisions

You may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted by replying to the communication resolving your original request.

Washington and Nevada Consumer Health Data Privacy Notice

This Consumer Health Data Privacy Notice (the “Consumer Health Notice”) supplements the Forela Privacy Notice and explains how we collect, use, disclose, and otherwise process Consumer Health Data (as defined below) of residents of the states of Washington or Nevada or individuals whose Consumer Health Data is collected in Washington or Nevada through our Services.

This Consumer Health Notice does not address privacy practices relating to Forela job applicants, employees, and other personnel. Please note that this Consumer Health Notice is not a contract and does not create any legal rights or obligations not otherwise provided by law.

The term “Consumer Health Data” as used in this Consumer Health Privacy Notice means personal information that is linked or reasonably linkable to you and that identifies, relates to, or is used to identify your past, present, or future physical or mental health status, condition, or diagnosis, as defined by the Washington My Health My Data Act or the Nevada Consumer Health Data Privacy Law, as applicable (the “Consumer Health Privacy Laws”). The Consumer Health Data we collect depends on the context of your interactions with us and, in most cases, is information that you decide to share with us. This includes information collected through onboarding questions, product recommendation flows, your communications with us, uploads to the Services, or your other interactions with our Services. Consumer Health Data does not include information that is considered deidentified under the Consumer Health Privacy Laws.

Examples of Consumer Health Data that we may collect include:

  • Information about health conditions, symptoms (such as immune flares, pain levels, and fatigue markers), menstrual cycles, hormonal shifts, gut health indicators, previous diagnoses, treatment timelines, specialist insights, and other health-related information you provide through our platform, including through our adaptive questionnaires.

Behavioral and Lifestyle Data, including information about daily habits, environmental triggers, stress levels, nutritional factors, and other lifestyle inputs you provide through our platform. We use this information to provide personalized, adaptive guidance and to help identify patterns and correlations relevant to your health.

We may process and/or use your Consumer Health Data (including with your consent where required by the Consumer Health Privacy Laws) for the following purposes:

  • To manage and provide the Services.
  • To manage, provide, maintain, and improve our business.
  • To respond to your questions, concerns, and other requests for assistance.
  • To customize your browsing and experience on the Services.
  • For market research and providing insights into consumer needs and related health behaviors or conditions, where permitted by law.
  • To build and enhance consumer profiles and use of the Services, where permitted by law.
  • To provide contextual or targeted offers that may be of interest to you, where permitted by law and consistent with any consent or authorization we obtain from you.
  • To create anonymous, aggregated, or de-identified data.

We may also combine your Consumer Health Data with other personal data we collect directly from you or receive from other sources.

The Consumer Health Data we collect depends on the context of your interactions with our Services and, in most cases, is information that you decide to share with us.

We and our service partners may collect this type of information over time and across third-party websites and mobile applications. For more information, please see the Our Collection and Use of Personal Data section of our Privacy Notice.

We may share the categories of Consumer Health Data set forth above as follows:

To Your Healthcare Providers: As part of our Services, we may disclose your personal information, including your health-related information, to healthcare providers that you designate. You have the ability to grant your healthcare providers direct access to view some or all of your Forela records. When you choose to enable this access, your designated healthcare providers will be able to access your information automatically on an ongoing basis until you modify or revoke that access. You control which healthcare providers receive access and the scope of information they can view. You may grant, modify, or revoke a healthcare provider's access to your information at any time through your account settings in the app.

To Our Affiliates: We are able to offer you the products and services we make available because of the hard work of our team members across Forela Health, Inc. entities. To provide our products and facilitate our services, Forela Health, Inc. entities disclose personal data to other Forela Health, Inc. entities for purposes and uses that are consistent with this Privacy Notice. For example, the Forela Health, Inc. entity responsible for our website may disclose your contact information to a/n Forela Health, Inc. entity in your region to facilitate communications between you and a local Forela Health, Inc. representative.

To Service Providers: We work with a variety of service providers who help us process your Consumer Health Data, such as to facilitate the operation of our Services.

In relation to Business Transactions: We may take part in or be involved with a business transaction, such as a merger. We may disclose Consumer Health Data to a third-party during the negotiation of or in connection with such a transaction.

In relation to Legal Obligations and Rights: We may disclose Consumer Health Data to third parties in connection with the establishment, exercise, or defense of legal claims; to comply with laws or to respond to lawful requests and legal processes; to protect our rights and property and the rights and property of others, including to enforce our agreements and policies; to detect, suppress, or prevent fraud; to protect the health and safety of us and others; or as otherwise required by applicable law.

With Your Consent: We may disclose Consumer Health Data about you to other service providers or publicly with your consent or at your direction. For example, with an individual’s consent or at their direction we may post their testimonial on our Services.

The Laws provide the following rights with respect to Consumer Health Data we collect about you:

  • Right to Access / Confirm: You may have the right to confirm whether we are collecting, sharing, or selling Consumer Health Data about you and with whom we may be disclosing such Consumer Health Data, and to access such data.
  • Right to Review / Request Changes: You may have the right to review or request changes to certain Consumer Health Data that we collect about you.
  • Right to Withdraw Consent: If you have provided your consent for our processing or sharing of your Consumer Health Data, you may have the right to withdraw your consent.
  • Right to Delete: You may have the right to request that we delete your Consumer Health Data and that all third parties to whom we have disclosed your Consumer Health Data delete such data.

To exercise any of the privacy rights set forth above or to review or request changes to data, please submit a request to legal@useForela.com, or use the rights request process described in the Additional United States Privacy Disclosures above.

Before processing your request, we will need to authenticate your identity. To authenticate your identity, we will generally require matching a minimum amount of information you provide us with the information we maintain about you in our systems. This process may require us to request additional information from you, including, but not limited to, your email address.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to authenticate your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for our decision.

If your request to exercise a right under the Laws is denied, you may appeal that decision by contacting us at legal@useForela.com. If the appeal is unsuccessful, you may raise a concern or lodge a complaint with the applicable State Attorney General.

We may update this Consumer Health Notice from time to time. When we make changes to this Consumer Health Notice, we will notify you by changing the date at the beginning of this Consumer Health Notice. If we make material changes to this Consumer Health Notice, we will notify individuals by email to their registered email address, by prominent posting on this website or our other platforms, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise specified.