PRIVACY STATEMENT & DATA GOVERNANCE POLICY

Last updated: October 1, 2026

Provider: Turritopsis Inc., a Nevada corporation (“Company”, “we”, “us”, or “our”) This Privacy Statement describes how Turritopsis Inc. collects, processes, and protects your personal data when you participate in the private Beta evaluation of Coach. This document is directly integrated with and governed by our Beta Test Terms of Service and our Medical, Health, and Safety Disclaimer. By accessing or using the Service, you confirm that you have read, understood, and agreed to the data practices described herein. Privacy Principles We take your privacy seriously and are committed to ensuring you clearly understand how we collect, use, share, and protect your personal data. We have invested heavily, and will continue to invest, in robust product features, infrastructure, and administrative safeguards to protect the confidentiality, integrity, and security of your personal data. Applicable Service: Coach mobile application and associated backend voice/cloud systems (the “Service” or “Beta Service”) 1. Our Core Data Principles: Zero Sale, Service-Only Use No Selling or Renting of Data: We do not sell, rent, monetize, broker, or trade your personal information, voice recordings, or fitness data to data brokers, advertising networks, or third parties for marketing purposes. Service-Only Purpose: We collect and process your information solely to provide, operate, debug, and improve the Coach experience for you during this testing period. No Marketing Profiling: Your interactions and health-related metrics are never used to serve targeted third-party advertising. Government & Legal Requests: We will only disclose your personal information or data to government agencies or law enforcement authorities if compelled to do so by a valid legal process, such as a legally binding subpoena, warrant, or court order. 2. Information We Collect To deliver an adaptive, voice-first coaching service, the platform collects the following categories of information: Account & Profile Information: Name, email address, age, gender, and basic profile attributes collected during your intake interview. Conversational Audio & Transcripts: Spoken inputs captured when using voice features (including wake-phrase interactions, responses to check-in queries, and audio prompts), together with the resulting machine-generated text transcripts. Health, Fitness & Biometric Inputs: Daily weigh-ins, body metrics, target goals, workout logs, nutritional/meal logs, energy ratings, and habit completion records. Lab & DNA Biomarker Results: Laboratory test results (biomarkers) and genetic/DNA data uploaded via the application's upload feature or provided to Coach through voice or text input, used to further customize and optimize personalized training, nutrition, and recovery programs. Technical & Diagnostic Telemetry: Device identifiers, iOS version, system crash logs, latency benchmarks, session durations, and interaction timestamps necessary to debug the Beta software. 3. How We Use Your Information We use the data collected strictly for the following operational purposes: Real-Time Coaching Generation: Processing your spoken queries and daily check-ins to generate personalized workout programming, dietary guidelines, and progress predictions via our deterministic rule engine and AI model pipelines. Session Continuity: Maintaining conversation state across morning and evening check-ins so your coach remembers recent logs, adjustments, and preferences. Internal Model & Workflow Refinement: Analyzing anonymized or aggregated interaction logs and system errors solely to calibrate coach responses, improve voice transcription accuracy, and optimize prompt engineering for Turritopsis products. Aggregated & Anonymized Research: Analyzing anonymized, non-personally identifiable health and performance logs to discover actionable wellness insights, publish human optimization findings, and continuously refine feature capability across our platform systems. Safety Verification: Ensuring that generated recommendations comply with the internal safety protocols and deterministic guardrails established by our programming guidelines. 4. Third-Party Infrastructure & Technical Processors To deliver low-latency voice and generative AI capabilities, we transmit necessary data payloads to enterprise infrastructure providers under strict contractual confidentiality and data-protection standards: Cloud Hosting: Cloud infrastructure (such as Amazon Web Services) for encrypted database storage and API routing. Language Model & Voice APIs: Enterprise artificial intelligence model endpoints and voice synthesis platforms (such as Anthropic and ElevenLabs) used to parse conversations, generate responses, and synthesize spoken coaching audio. Note: These processors act strictly on our behalf under enterprise terms and are prohibited from using your data to train public foundation models or for their own commercial purposes. 5. On-Demand Data Deletion via App Settings You retain full ownership and control over your personal data. Self-Service Data Deletion at Any Time: You may permanently delete your data, including conversational history, voice recordings, and health logs at any point directly within the application: Open the Coach app. Navigate to App Settings. Select "Delete My Data" and confirm. Effect of Deletion: Once initiated, your personal identifiers, profile data, conversation transcripts, and biometric logs are permanently purged from our active databases. Backups: Residual copies in secure, encrypted system backups will be permanently overwritten in accordance with standard backup rotation cycles (typically within 30 days). 6. Data Security Measures We implement administrative, technical, and physical safeguards engineered to protect your personal and biometric data against unauthorized access, loss, or alteration. All data in transit between the iOS application, our backend servers, and inference APIs is protected using Transport Layer Security (TLS/HTTPS) encryption, and sensitive database volumes are encrypted at rest. Because Coach is experimental Beta software, we encourage you to maintain independent records of any critical personal fitness logs. 7. Relationship to Medical Disclaimers Information processed by Coach, including weigh-ins, body composition estimates, and meal plans, constitutes non-clinical wellness data and is not protected under the Health Insurance Portability and Accountability Act (HIPAA). Your use of the Service remains subject to the Medical, Health, and Safety Disclaimer, confirming that the platform provides wellness guidance rather than regulated medical diagnostic care. 8. Changes to This Policy We may update this Privacy Statement periodically to reflect functional updates to the Service or evolving legal requirements. Any material changes will be communicated via in-app notification or through an updated revision date. 9. Privacy Contact If you have questions regarding this Privacy Statement or our data handling practices, please contact: Turritopsis Inc. Attention: Privacy Officer Email: ops@turritopsis.ai