MyLibreo

Terms and Conditions of Use

PLEASE READ THESE TERMS CAREFULLY BEFORE USING THE APP. BY ACCEPTING AN INVITATION AND ACCESSING THE APP, YOU AGREE TO BE BOUND BY THESE TERMS.

1. Introduction and Acceptance

These Terms and Conditions ("Terms") govern your access to and use of the MyLibreo mobile application ("App"), operated by Well Direct LLC. ("we," "us," or "our"). The App is currently available exclusively to individuals who have received a personal invitation from Well Direct LLC. ("Invited Users").

By tapping 'Accept' during onboarding, by using the App, or by otherwise manifesting your agreement to these Terms, you confirm that you have read, understood, and agree to be bound by these Terms in their entirety, together with our Privacy Policy, which is incorporated herein by reference.

If you do not agree to these Terms, you must not access or use the App and should contact us immediately to have your account deactivated.

2. Invitation-Only Access

2.1 Eligibility

Access to the App is strictly limited to individuals who have received a valid, personalised invitation directly from Well Direct LLC Invitations are non-transferable and may not be shared, sold, or assigned to any other person.

2.2 Account Creation

To activate your account, you must:

• Be at least 18 years of age (or the age of majority in your jurisdiction, if higher);

• Provide accurate and complete registration information;

• Maintain the security and confidentiality of your login credentials; and

• Notify us promptly at info@mylibreo.com if you suspect unauthorised access to your account.

2.3 Revocation of Access

We reserve the right to revoke your invitation and terminate your access at any time, with or without cause, and with or without prior notice. Common grounds for revocation include, but are not limited to, breach of these Terms, provision of false information, or misuse of health data features.

3. Health Data Collection and Use

3.1 Categories of Health Data Collected

In connection with the App's core functionality, we collect the following categories of personal health data (collectively, "Health Data"):

• Heart Rate Data — continuous and on-demand heart rate measurements, resting heart rate, and heart rate variability (HRV), sourced from compatible wearable devices or the device's built-in sensors;

• Physical Activity Data — step counts, active energy expenditure, workout type, duration, intensity, distance, and movement patterns throughout the day; and

• Sleep Data — sleep duration, sleep stages (light, deep, REM), sleep onset and wake times, and sleep quality scores.

3.2 How We Use Your Health Data

Your Health Data is used solely for the following purposes:

• Providing and personalising the App's features and insights to you;

• Generating anonymised, aggregated analytics to improve App performance and user experience;

• Conducting internal research and product development, subject to de-identification;

• Complying with legal obligations; and

• With your explicit, separate consent, sharing de-identified data with approved academic or research partners.

We will never sell your Health Data to third parties. We will never use your Health Data for advertising or marketing profiling purposes.

3.3 Sensitive Health Information

Heart rate, activity, and sleep data constitute sensitive personal information under applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and other applicable laws. We process this data on the legal basis of your explicit consent, which you provide during onboarding and which you may withdraw at any time.

3.4 Data from Apple Health (HealthKit)

The App may integrate with Apple HealthKit to read and write health and fitness data. Data obtained from Apple HealthKit will not be used for advertising, sold to advertising platforms, or disclosed to third parties for purposes unrelated to health and fitness. This is a binding commitment under Apple's App Store Review Guidelines.

3.5 Medical Disclaimer

THE APP IS NOT A MEDICAL DEVICE AND IS NOT INTENDED TO DIAGNOSE, TREAT, CURE, OR PREVENT ANY DISEASE OR MEDICAL CONDITION. The Health Data and insights provided by the App are for informational and wellness purposes only. You should always consult a qualified healthcare professional before making any health, medical, or fitness decisions. Do not disregard or delay seeking professional medical advice based on information provided by the App.

4. Data Retention and Deletion

We retain your Health Data for as long as your account is active or as required to provide you with the App's services. You may request deletion of your account and all associated Health Data at any time by contacting us at legal@mylibreo.com. We will action verified deletion requests within 30 days, subject to any legal retention obligations.

Upon deletion of your account, we will permanently delete or irreversibly anonymise all Health Data associated with your account from our active systems. Residual copies in backup systems will be deleted in accordance with our standard backup rotation schedule, not to exceed 90 days.

5. Data Sharing and Disclosure

We do not sell, rent, or trade your Health Data. We may share your data only in the following limited circumstances:

• Service Providers — trusted third-party vendors who process data on our behalf under binding data processing agreements (e.g., cloud hosting, analytics infrastructure). These providers are prohibited from using your data for their own purposes.

• Research Partners — only with your explicit, separate written consent, and only in de-identified or aggregated form.

• Legal Compliance — where required by law, court order, or a lawful request from a government authority.

• Business Transfers — in the event of a merger, acquisition, or asset sale, your data will remain subject to these Terms or terms no less protective.

6. Data Security

We implement industry-standard technical and organisational measures to protect your Health Data against unauthorised access, accidental loss, destruction, and disclosure. These measures include end-to-end encryption of data in transit (TLS 1.2+), encryption of data at rest (AES-256), strict access controls on a need-to-know basis, and regular security audits.

Notwithstanding the above, no transmission over the internet or method of electronic storage is completely secure. You acknowledge and accept that we cannot guarantee absolute security, and you provide your data at your own risk. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you as required by applicable law.

7. User Obligations and Prohibited Conduct

As a condition of your access to the App, you agree that you will not:

• Share your invitation, login credentials, or account access with any third party;

• Attempt to reverse-engineer, decompile, or extract source code from the App;

• Use the App in any manner that could damage, disable, or impair our servers or networks;

• Attempt to gain unauthorised access to any other user's account or to our systems;

• Use the App for any unlawful purpose or in violation of any applicable laws or regulations;

• Reproduce, distribute, modify, or create derivative works of the App without our prior written consent; or

• Attempt to circumvent any security, access control, or invitation verification feature of the App.

8. Intellectual Property

All intellectual property rights in the App, including but not limited to software, design, graphics, algorithms, and underlying technology, are owned by or licensed to Well Direct LLC. These Terms do not grant you any ownership rights in the App. You are granted a limited, non-exclusive, non-transferable, revocable licence to use the App solely for your personal, non-commercial use in accordance with these Terms.

Any feedback, suggestions, or ideas you provide to us regarding the App may be used by us freely and without obligation to you.

9. Third-Party Devices and Services

The App is designed to integrate with third-party wearable devices and platforms, including but not limited to Apple Watch, Apple HealthKit, and other compatible health hardware. We do not manufacture or control these third-party devices and accept no liability for their accuracy, reliability, or data integrity. Your use of third-party devices and services is governed by the terms and privacy policies of their respective providers.

10. Disclaimers and Limitation of Liability

THE APP IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, WELL DIRECT LLC, ITS DIRECTORS, EMPLOYEES, AND AFFILIATES SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES ARISING OUT OF OR RELATED TO YOUR USE OF OR INABILITY TO USE THE APP, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

Nothing in these Terms shall limit or exclude liability for death or personal injury caused by negligence, fraud, or any other liability that cannot be lawfully excluded.

11. Changes to These Terms

We reserve the right to modify these Terms at any time. If we make material changes, we will notify you by push notification or email at least 14 days before the changes take effect. Your continued use of the App after the effective date of the revised Terms constitutes your acceptance of the changes.

If you do not agree to the revised Terms, you must discontinue use of the App and contact us to deactivate your account.

12. Termination

Either party may terminate these Terms at any time. You may terminate by ceasing use of the App and requesting account deletion. We may terminate or suspend your access immediately if you breach these Terms or for any other reason at our sole discretion.

Upon termination, all licences granted to you under these Terms will cease, and Sections 3 (Health Data), 4 (Retention), 8 (Intellectual Property), 10 (Disclaimers), and 13 (Governing Law) shall survive.

13. Governing Law and Dispute Resolution

These Terms are governed by and construed in accordance with the laws of Utah, without regard to conflict of law provisions. Any dispute arising out of or in connection with these Terms shall be subject to the exclusive jurisdiction of the courts of England and Wales.

If you are a consumer resident in the European Union, you may also have the right to refer a dispute to your local courts or an alternative dispute resolution body under applicable EU consumer protection law.

14. Contact Us

If you have any questions about these Terms, your Health Data, or the App, please contact us at: