Sweetmyo Privacy Policy

Effective Date June 1, 2026 ｜ Last Updated July 7, 2026

This Privacy Policy explains how Sweetmyo Inc. ("we," "us," or "our") collects, uses, stores, shares, discloses, and protects your personal information when you use the Sweetmyo device (Hub1), the mobile application (Sweetmyo App), and our official website and related services (collectively, the "Services").

[Special Notice] Before using the Services, please carefully read and fully understand this Policy, especially the clauses highlighted in bold. Where the collection and use of sensitive personal information is involved (such as height, weight, gender, body type, and other physical attributes), we will obtain your separate consent.

By clicking "Agree" or by beginning to use the Services, you indicate that you have fully understood and agreed to this Policy. If you do not agree with any part of this Policy, please do not use our products or services.

[Health Data Disclaimer] We are not a healthcare provider, and the Services are not intended to provide medical advice, diagnosis, or treatment. The personal information and physical data we collect are for fitness and wellness purposes only and do not constitute Protected Health Information (PHI) under the Health Insurance Portability and Accountability Act (HIPAA) or similar state laws.

1. Definitions

• Personal Information: Various types of information recorded electronically or by other means that can, alone or in combination with other information, identify a specific natural person or reflect the activities of a specific natural person. It does not include anonymized information.
• Sensitive Personal Information: Personal information that, once leaked or unlawfully used, could easily lead to infringement of a natural person's dignity or endanger their personal or property safety. In the Services, this includes your physical and health attributes such as height, weight, gender, and body type.
• Processing of Personal Information: Includes the collection, storage, use, processing, transmission, provision, disclosure, and deletion of personal information.
• De-identification: The process by which personal information is processed so that it cannot identify a specific natural person without the aid of additional information.
• Anonymization: The process by which personal information is processed so that it cannot identify a specific natural person and cannot be restored.
• OAID: Open Anonymous Device Identifier, an anonymous device identifier provided by the mobile smart terminal system that can be reset by the user.

2. How We Collect and Use Your Personal Information

We collect and use your personal information only for the purposes described in this Policy that are necessary to provide our products and services to you. We describe this below by business function scenario:

1. Account Registration, Login, and Authentication

• Mobile phone number (for SMS verification code login or one-tap login auto-fill), email address, and verification code.
• Authorization information when logging in with a third-party account: WeChat and Google account authorization information, and Apple account authorization information (iOS only).
• To provide "one-tap mobile number login" and safeguard account security, the relevant SDK will read your OAID, ANDROID_ID, device network address/IP, network and carrier information, and Wi-Fi access point information (SSID and BSSID) (see the third-party SDK directory in "4. How We Share, Transfer, and Publicly Disclose" for details).

2. Completing Your Profile and Personalized Training (Including Sensitive Personal Information)

• Your nickname, profile picture, and bio.
• To calculate training intensity and calorie expenditure and to provide personalized training recommendations, we collect your gender, year of birth, height, weight, body type, and fitness goals. Among these, height, weight, gender, and body type are sensitive personal information, which we collect only after you voluntarily provide it and give separate consent; declining to provide it will only affect the personalization of your training and will not affect your use of other basic functions. You may view, modify, or delete this information at any time within the App.

3. Connecting to and Using the Device

• Hub1 device serial number, the MAC address / device identifier of the connected Sweetmyo device (used for device recognition and to associate training records), device status, battery level, and firmware version.
• Bluetooth connection information, sensor data, and status (electrode contact quality, training interruption records).
• On Android 11 and earlier systems, the system requires the App to have location permission in order to scan for Bluetooth devices, so connecting a device may require you to grant location permission. We use this solely to complete Bluetooth scanning; we do not collect, record, or upload your geographic location coordinates, nor do we continuously track your location.

4. Training Records and Statistics

• Training time, training intensity settings, mode selection, frequency, calorie expenditure, and training history.

5. Customer Service, After-Sales, and Security

• Contact information and problem descriptions you voluntarily provide when giving feedback or making inquiries.
• To prevent security risks and identify violations, we process necessary information such as device identifiers and operation logs.

6. Device Identifiers and Technical Information

• Unique device identifier: Used for secure authentication of interface requests and device identification. Android uses ANDROID_ID, and iOS uses the IDFV (identifierForVendor); both are resettable identifiers that are not associated with your real identity.
• OAID (Open Anonymous Device Identifier, Android only): Read by the Aurora (JIGUANG) one-tap login SDK after you agree to this Policy, used for one-tap mobile number login and security risk control; the OAID is a resettable anonymous identifier, and we will not use it to associate with your real identity.
• Device model, operating system version, application version number, network status and carrier information, and time zone.
• Network access IP address: Used to determine the country or region you are in (domestic or overseas) so that we can provide region-appropriate services and compliance handling; we will not use it for precise geographic positioning or for advertising.

7. Usage and Statistical Information

• To analyze product usage, optimize features, and improve your experience, we collect statistical information such as app installation/activation events, usage duration, page-view records, and feature-usage information. Such information is used for statistical analysis in an aggregated, de-identified form, does not include sensitive personal information such as your physical-attribute or health data, and will not be used to identify you personally or for advertising.

8. List of App Permissions

The above permissions are requested on demand when you use the corresponding features, and you may turn them off at any time in your system settings; once turned off, the corresponding features may become unavailable, but this will not affect other features.

3. How We Use Cookies and Similar Technologies

When you visit our website or use our App, we and our third-party service providers may use cookies, web beacons, pixel tags, and similar technologies to collect information about your browsing activities, device, and browser. We use these technologies to ensure the Services function properly, remember your preferences, analyze site traffic, and deliver personalized marketing content.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website. We currently do not respond to "Do Not Track" (DNT) signals, but we comply with legally mandated opt-out preference signals where required by applicable state laws.

4. How We Share, Transfer, and Publicly Disclose

1. Sharing

We will not sell or rent your personal information to any third party without your explicit authorization. We will share it within the necessary scope only in the following circumstances:

• With your proactive authorization or consent;
• In accordance with mandatory requirements of applicable laws and regulations or of courts or government authorities;
• The minimum sharing necessary to implement basic functions: sharing data storage and network infrastructure with cloud computing service providers, and sharing information necessary to implement the corresponding functions with the SDK providers listed in the "Third-Party SDK Directory" below.

2. Transfer

We will not transfer your personal information, but in the event of a merger, acquisition, asset reorganization, or similar situation, we will require the new holder to continue to be bound by this Policy; otherwise, we will require it to obtain your authorization and consent anew.

3. Public Disclosure

We will publicly disclose your personal information only with your explicit consent or based on mandatory administrative or judicial requirements under laws and regulations.

4. Third-Party SDK Directory

To implement the corresponding functions, this App integrates the following third-party SDKs, which collect or process relevant personal information within the scope necessary for the functions. Each SDK's processing of personal information is governed by its own privacy policy:

Please note that we do not use or integrate any SDKs that track your precise location coordinates or collect data for cross-app advertising purposes without your explicit consent. The payment processing SDKs (such as Stripe, Apple In-App Purchases, or Google Play Billing) collect your payment details directly; we do not store your full credit card numbers on our servers.

If the integrated SDKs and their information processing change, we will update this directory in a timely manner.

5. How We Store Your Personal Information

1. Storage Location

Your training data and account data will be stored on servers deployed by cloud computing service providers. In principle, your personal information is stored on servers located in the overseas region corresponding to your account.

2. Retention Period

We retain your personal information only for the shortest period necessary to achieve the purposes described in this Policy: account information is retained for as long as your account exists; physical-attribute and training data are retained for the duration of your account in order to provide you with historical records and trend analysis; where laws and regulations specify a minimum retention period for certain information (such as transaction records), we will retain it in accordance with the law. After you cancel your account or the above retention periods expire, we will delete or anonymize your personal information, except as otherwise required by laws and regulations.

6. How We Protect Your Personal Information

We have adopted the following security technical and management measures to protect your information:

• TLS encryption is used during data transmission.
• Access control and tiered permission management are applied during storage.
• A device-unbinding mechanism is built into the App to prevent unauthorized use by others.
• Log monitoring and malicious-operation detection mechanisms.
• Minimization of employee permissions and regular security training.

In the unfortunate event of a personal information security incident, we will promptly notify you and report to the regulatory authorities in accordance with the law, informing you of the basic circumstances of the incident, its possible impact, the remedial measures already taken, and the preventive recommendations you may follow.

7. How You Can Manage Your Personal Information

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

• Access and Copy: You may view your personal profile and training records in the App under "Me"; if you need a copy, you may request one through the contact methods in this Policy.
• Correction and Supplementation: You may correct information such as your nickname, gender, height, and weight in the App under "Me" → "Edit Profile."
• Deletion: You may delete training records, or delete your personal information together when canceling your account; in legally prescribed circumstances, you may also request that we delete it.
• Withdrawal of Consent: You may turn off the corresponding permissions in your system settings, or turn off the corresponding features within the App, to withdraw the authorization and consent you previously gave. Withdrawal does not affect processing already carried out based on consent prior to the withdrawal.
• Account Cancellation: You may cancel your account yourself via the App under "Me" → "Settings" → "Cancel Account," or apply by sending an email to [email protected]. After cancellation, the personal information under that account will be deleted or anonymized, and this action is irreversible.
• Complaints and Reports: You have the right to lodge complaints with us regarding the processing of personal information, and you may also file complaints or reports with the competent data protection authority in your jurisdiction.

We will respond to your request within 15 business days of receiving it.

8. U.S. State Privacy Rights (Including California CCPA/CPRA)

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or other states with applicable privacy laws, you may have specific rights regarding your personal information:

• Right to Know and Access: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you.
• Right to Delete: You have the right to request the deletion of your personal information, subject to certain exceptions.
• Right to Correct: You have the right to request correction of inaccurate personal information.
• Right to Opt-Out of Sale or Sharing: We do not "sell" your personal information for monetary value. However, sharing data with third-party analytics or advertising partners via cookies on our website may be considered a "sale" or "sharing" under California law. You can opt out by clicking the "Do Not Sell or Share My Personal Information" link on our website footer.
• Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.

To exercise these rights, please contact us at [email protected]. We may require you to verify your identity before processing your request.

9. Children's Privacy (COPPA Compliance)

Our Services are strictly intended for general audiences and are not directed to children under the age of 18. We do not knowingly collect personal information from children under 18. If you are under 18, please do not use the Services or provide any information to us. If we become aware that we have collected personal information from a child under 18 without verifiable parental consent, we will take immediate steps to delete that information from our servers. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

10. How This Policy Is Updated

We may update this Privacy Policy from time to time. For material changes (such as substantial changes to the purposes and methods of data processing, changes to the parties with whom information is shared, changes to user rights and how they are exercised, etc.), we will notify you by means such as in-App pop-ups, prominent notices, or website announcements. If you do not agree to the changes, you have the right to stop using the Services and cancel your account.

11. Dispute Resolution and Governing Law

Any disputes arising out of or relating to this Privacy Policy or our data practices will be governed by the laws of the State of Delaware, without regard to its conflict of law principles. All disputes shall be resolved in accordance with the binding arbitration clause and class action waiver set forth in our Terms of Service.

12. How to Contact Us

If you have any questions, comments, or complaints about this Privacy Policy or about how your personal information is processed, please contact us through the following, and we will respond within 15 business days:

• Email: [email protected]
• Address: 16192 Coastal Highway, Lewes, DE 19958, USA
• Company: Sweetmyo Inc.

Appendix: Personal Information Collection List

The table below summarizes the types of personal information collected by the Services, along with their purposes and attributes, for your convenient overview:

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