Privacy Policy

HALE PRIVACY POLICY Date of Last Revision: August 26, 2025 Hale Prevention, Inc. (“Hale,” “we,” “us,” or “our”) is proud to offer our generational risk analysis services to you.  At Hale, we know that you care about how your personal information is used and shared, and we take your privacy seriously. In addition to our HIPAA Authorization and any other notices at collection, we have prepared this privacy policy to explain how we interact with your personal information.  Please read the following to learn more about how we handle personal information in connection with the https://www.joinhale.com website, our publicly available mobile applications, and any related services and/or features (collectively, the "Services"). Personal Information We Collect Personal information you provide: Account details, such as your first and last name, email addresses, and your chosen account credentials. Demographic information, such as age, date of birth, gender, state and country of residence, and pronouns. Health information, such as your health history and accompanying information that you directly provide, which can include your family health history and interest regarding specific medical conditions. Hale relies on a combination of user provided information, information derived from our proprietary testing devices, and information we obtain at your direction from a partner lab or trained phlebotomists we partner with.  Subscription information, such as the type of subscription you choose, the user profile the subscription relates to and the date the subscription expires.  Payment information that our payment service providers collect to process your subscriptions, including name, payment card information and billing information. We do not store payment card numbers on our systems. The information you provide in connection with your purchases is handled by our third-party payment processors in accordance with their terms of service and privacy policies. Survey information that you provide when you respond to our survey questions about your progress and preferences, including when you register for our waitlists.  Communications that we exchange with you, including when you contact us with questions, feedback or otherwise. Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them. Other information not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection. Where you provide us with the personal information of third parties, such as your friends or other contacts, it is your responsibility to inform them about the processing of their personal information in accordance with this Privacy Policy, and to confirm that they have given their permission. Automatic data collection. We, our service providers and our business partners may automatically log and combine information about you, your computer or mobile device, and your interaction over time with the services, online resources and our communications, such as: Device data such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings and general location information such as city, state or geographic area. Online activity data such as pages or screens you viewed, the website you visited before browsing to the services, navigation paths between pages or screens, information about your activity on a page or screen, access times, and whether you have opened or otherwise engage with our communications, such as our marketing emails or clicked links or files within them. We use the following tools for automatic data collection: Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns. Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications. Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked. Information we obtain from third parties: Health information. In circumstances where we partner with a laboratory or healthcare services on your behalf, we will obtain your health information with your consent. For example, if you choose to use one of our partner labs for screening services, we will receive your information related to your sample for us to process and form inferences about your health. Social media information. We may maintain pages on social media platforms, such as Facebook, LinkedIn, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.  Third-party login information. When you link, connect, or login to the Services with a third party service (e.g. Google), you direct the service to send us information such as your registration, calendar, and profile information as controlled by that service or as authorized by you via your privacy settings at that service. Other Sources. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.  How We Use Personal Information We use personal information for the following purposes or as otherwise described at the time of collection: Providing and supporting our Services. We use personal information to operate, maintain and provide you with our services, including to allow you to use the Services under our terms of use. Communicating with you about our services. We will use personal information to respond to your requests, provide customer support and communicate with you about our services, including by sending announcements, updates, security alerts and support and administrative messages. Improving, monitoring, personalizing, and protecting our services, which includes:  understanding your needs and interests, and personalize your experience with the services and our communications; troubleshooting, testing and research and to keep the services secure; and investigating and protecting against fraudulent, harmful, unauthorized or illegal activity. Research and development, including to analyze and improve the services and our business. As part of these activities, we may create or use aggregated, de-identified or anonymized data from personal information we collect so you cannot be directly identifiable. We may use this data and share it with third parties for our lawful business purposes, including to analyze and improve the services and promote our business.  Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use personal information for the following marketing and advertising purposes: Direct marketing. We may send you direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of marketing communications section below. Interest-based advertising. We may engage third-party advertising partners, including third party advertising companies and social media companies, to display our ads around the web. These companies may use cookies and similar technologies to collect information (including the automatically-collected data described above) about your interactions over time across our services, our communications, and other online services, and use that information to serve online ads that may interest you. We share information we collect on our website, such as information about the pages you visit and the actions you take on our website with advertising networks and analytics partners to support our interest-based advertising, which may qualify as “sharing” personal information, or targeted advertising, under applicable law.  Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes where it is in our legitimate business interests to do so, including to: protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements and internal policies; enforce the terms and conditions that govern the services; prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities. How We Disclose Personal Information We may disclose personal information to the following parties: Service providers. Companies and individuals that provide services on our behalf or help us operate the services or our business (such as physicians, lab services, hosting, information technology, customer support, email delivery and website analytics services). Advertising partners. Third party advertising companies, including for the interest-based advertising, that may collect information on the website through cookies and other automated technologies. Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us. Authorities and others. Law enforcement, government authorities and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above. Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Hale (including, in connection with a bankruptcy or similar proceedings). With your instruction or permission. We may disclose personal information to a relevant third party, where you give us permission to do so in the course of your relationship with us from time to time.  Privacy Rights and Choices Opt-out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or by contacting us as provided in the How to Contact Us section below. You may continue to receive services-related and other non-marketing emails. Personal information requests. We currently offer you the ability to access your personal information and to delete your personal information (subject to our legal obligations). Please note that deleting your personal information may prevent us from providing the Services to you, as the Services are powered by insights based on your personal information. Please email us or write to us as provided in the How to Contact Us section below. We may ask for specific information from you to help us confirm your identity.  Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the How to Contact Us section below.  Opt out of online tracking. There are a number of ways to opt out of having your online activity and device data collected through our Services, which we have summarized below: Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes. Using privacy plug-ins or browsers. You can block our Services from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block cookies/trackers. Google Analytics. We use Google Analytics to help us better understand how people engage with our Services by collecting information and creating reports about how users use our Services. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout. Platform opt-outs. The following advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising: Google Facebook LinkedIn Microsoft Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies: Digital Advertising Alliance Network Advertising Initiative Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.  Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com. Other Sites and Services Our services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions. This Privacy Policy does not apply to such third-party sites or services. Security We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information. Children’s Privacy  Our Services are not intended for use by children under 18 years of age. If we learn that we have collected personal information through our Services from a child under 18, we will delete it. Retention of Personal Information Where required under applicable laws, we retain personal information only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).  To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.  Changes to This Privacy Policy We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you.  How to Contact Us If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at team@joinhale.com