Privacy Policy - PRIMEGLOW

Section 1

Introduction

This Privacy Policy describes how PRIMEGLOW LTD ("PRIMEGLOW," "we," "us," or "our") collects, uses, shares, and protects information about you when you visit our website, create an account, use the PRIMEGLOW app, or use the optional PRIME BAND wearable (together, the "Services").

By using the Services, you agree to the practices described in this policy. If you do not agree, please do not use the Services.

In plain language: this page tells you what data we collect, why, and what you can do about it. We try to collect only what we need to make PRIMEGLOW work for you.

Section 2

Information We Collect

Account & profile information you provide

Account data - name, email address, password, and (if you choose) profile details such as age range, sex, height, and weight.
Communications - messages, questions, and feedback you send to us through support, email, or in-app chat.
Subscription & purchase records - the plan you choose and the status of your subscription. Payments are processed by our payment provider; we do not store your full card number (see Section 6).

Health & biometric data from the app and PRIME BAND

To deliver the core PRIMEGLOW experience, you may provide or connect health-related data, including:

Self-reported wellness inputs - nutrition, hydration, mood, sleep notes, workouts, habits, and goals you enter in the app.
Lab and biomarker data - values you choose to enter or upload (for example, blood-test results) so PRIMEGLOW can build your personalized insights.
Biometric & sensor data from PRIME BAND - measurements such as heart rate, heart-rate variability, sleep stages, activity and steps, blood-oxygen estimates, skin temperature, and other signals the device records.
Connected-source data - health and fitness data you authorize us to read from other platforms or devices (see Section 7 on Apple HealthKit).

Information collected automatically

Device & technical data - device type, operating system, app version, browser type, language, and crash/diagnostic logs.
Usage data - features used, screens viewed, and interactions, used to operate and improve the Services.
Approximate location - derived from your IP address (we do not collect precise GPS location unless you explicitly enable a feature that requires it).
Cookies & similar technologies - see Section 8.

In plain language: there are three buckets - what you type in (account, profile), your health and PRIME BAND data, and some technical info about your device and how you use the app.

Section 3

How We Use Your Information

We use the information we collect for the following purposes:

Purpose	Data used
Provide the Services - generate your personalized insights, scores, and recommendations	Account, profile, health & biometric, PRIME BAND data
Operate your account - authentication, support, and subscription management	Account, subscription records, communications
Process payments - billing and renewals through our payment provider	Subscription records (handled by payment provider)
Improve and secure the Services - diagnostics, debugging, fraud and abuse prevention	Device, usage, technical data
Communicate with you - service messages, and (with consent) product updates	Account, communications
Comply with the law - meet legal, tax, and regulatory obligations	As required by applicable law

What we do NOT do with your health data

We do not use your health or biometric data to serve you ads, to build advertising profiles, or to target you across other apps or websites - and we do not sell it. Health data is used solely to power the features you ask for.

In plain language: we use your data to make PRIMEGLOW work, keep your account running, take payment, fix bugs, and talk to you. We do not use your health data for advertising, and we do not sell it.

Section 4

Legal Bases & Consent

Where applicable law requires a legal basis to process your information, we rely on the following:

Performance of a contract - to provide the Services you sign up for and manage your account.
Consent - for processing health and biometric data, connecting third-party health sources, and sending optional marketing communications. You may withdraw consent at any time without affecting prior processing.
Legitimate interests - to secure, debug, and improve the Services and prevent fraud, balanced against your rights.
Legal obligation - to comply with laws, such as tax and recordkeeping requirements.

Because health and biometric data is sensitive, we process it only with your consent and only to deliver the features you request. You can withdraw that consent by deleting the relevant data, disconnecting a source, unpairing your device, or contacting us at hello@primeglow.io.

In plain language: we handle your health data only because you ask us to, and you can change your mind at any time.

Section 5

Health Data Is Never Sold or Used for Ads

Our promise

We do not sell your personal information, and we have never sold health or biometric data. We do not share health or biometric data for cross-context behavioral advertising. We do not use health, biometric, or PRIME BAND data to target advertising to you or anyone else.

This applies to data you enter in the app, biometric data from PRIME BAND, and any data we read from connected sources (including Apple HealthKit, described in Section 7). Advertising - to the limited extent we run it - is based on non-health information only, and you can opt out (see Sections 8 and 9).

In plain language: your health data is never for sale and never feeds ads. Full stop.

Section 6

How We Share Your Information

We share information only with the categories of recipients below, and only as needed:

Payment processor (Merchant of Record) - we use a third-party payment provider (such as a Merchant of Record like Lemon Squeezy) to process subscriptions and payments. They receive the information needed to complete your transaction and handle billing, tax, and fraud prevention under their own privacy policy. We do not receive or store your full payment card details.
Service providers / sub-processors - vendors who help us run the Services (for example, cloud hosting, customer support, and email delivery), under contracts that limit their use of your data to providing services to us.
Analytics providers - privacy-respecting analytics used to understand and improve the Services. Analytics is not applied to your health or biometric data for advertising purposes.
Legal, safety & compliance - where required by law, legal process, or to protect the rights, safety, and security of users, the public, or PRIMEGLOW.
Business transfers - in connection with a merger, acquisition, or sale of assets, your data may be transferred, subject to this policy.

In plain language: the main outside party that touches your data is the payment processor for billing. Other vendors only help us run the app, and they are bound by contract. Health data does not go to advertisers.

Section 7

Apple HealthKit

If you choose to connect PRIMEGLOW to Apple Health, we may read health and fitness data from HealthKit (such as activity, heart rate, and sleep) only with your explicit permission, and only to provide app features you request. You control which data categories are shared, and you can revoke access at any time in your device's Health settings.

Consistent with Apple's requirements, data obtained through HealthKit is not used for advertising or any use-based data mining other than improving your health and wellness experience, and it is not sold or disclosed to third parties for such purposes.

In plain language: if you link Apple Health, we only read what you allow, only to power features you want - never for ads, and never sold.

Section 8

Cookies & Tracking

Our website uses cookies and similar technologies to keep you signed in, remember preferences, secure the Services, and measure aggregate usage. Some are essential; others (such as analytics) are optional.

Essential cookies - required for sign-in, security, and core functionality.
Analytics cookies - help us understand usage in aggregate so we can improve the Services.

You can control cookies through your browser settings and, where offered, through our cookie banner or preference controls. Disabling some cookies may affect functionality. We do not use cookies to track your health data for advertising.

In plain language: some cookies are needed to log you in; others just help us see how the site is used. You can turn the optional ones off.

Section 9

Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (as amended by the CPRA) gives you the following rights regarding your personal information:

Right to Know - request the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the categories of third parties with whom we share it.
Right to Delete - request that we delete the personal information we have collected from you, subject to legal exceptions.
Right to Correct - request that we correct inaccurate personal information.
Right to Opt Out of Sale or Sharing - direct us not to "sell" or "share" your personal information.
Right to Limit Use of Sensitive Personal Information - limit our use of sensitive information (which includes health and biometric data) to permitted purposes.
Right to Non-Discrimination - we will not discriminate against you for exercising any of these rights.

Do Not Sell or Share My Personal Information

We do not sell your personal information and do not share it for cross-context behavioral advertising. To confirm this preference or submit any CCPA request, email hello@primeglow.io with the subject line "Do Not Sell or Share My Personal Information."

We will verify your identity before responding and aim to respond within the timeframes required by law (generally 45 days, extendable as permitted). You may use an authorized agent to make a request on your behalf. We do not knowingly sell or share the personal information of consumers under 16.

In plain language: Californians can ask what we have, delete it, correct it, and tell us not to sell or share it. We already don't sell it - and we won't treat you differently for asking.

Section 10

Your Rights & Choices

Wherever you live, you can exercise these choices:

Access & export - request a copy of your data, including a portable export of your PRIMEGLOW and PRIME BAND data.
Correction - update inaccurate account or profile information.
Deletion - delete specific data, disconnect health sources, unpair your PRIME BAND, or delete your account entirely.
Withdraw consent - stop processing of health and biometric data at any time.
Marketing opt-out - unsubscribe from promotional emails via the link in any message or by contacting us.

To make a request, email hello@primeglow.io or use the in-app privacy controls. We will verify your identity before acting on a request.

In plain language: you can see your data, fix it, download it, or delete it - and you can opt out of marketing whenever you want.

Section 11

Data Retention

We keep personal information only as long as needed for the purposes described in this policy:

Data type	Retention period	Reason
Account & profile	While your account is active, then deleted within a reasonable period after closure	Service delivery and account recovery
Health, biometric & PRIME BAND data	Until you delete it, disconnect the source, or close your account	To provide your personalized insights
Payment & transaction records	As required by tax and accounting law (typically several years)	Legal and financial compliance
Usage & diagnostic data	A limited period, then aggregated or anonymized	Security and product improvement

When you delete your account, we delete or anonymize your personal information, except where we must retain it to meet legal obligations or resolve disputes.

In plain language: we keep your data while you use PRIMEGLOW, plus what the law requires us to keep (like payment records). Delete your account and your data goes too.

Section 12

Security

We protect your information using industry-standard safeguards, including:

Encryption of data in transit and at rest.
Access controls that limit who on our team can access personal data.
Secure, reputable cloud infrastructure and regular review of our practices.

No method of transmission or storage is 100% secure. If we become aware of a breach affecting your personal information, we will notify you and the relevant authorities as required by applicable law.

In plain language: we use strong, standard security to protect your data. If something goes wrong, we'll tell you as the law requires.

Section 13

Children's Privacy

PRIMEGLOW is not directed to children. The Services are intended for adults 18 and older, and we do not knowingly collect personal information from anyone under 18 (or under the minimum age required in your jurisdiction). Consistent with the U.S. Children's Online Privacy Protection Act (COPPA), we do not knowingly collect data from children under 13. If you believe a child has provided us personal information, contact us at hello@primeglow.io and we will delete it.

In plain language: PRIMEGLOW is for adults. We don't knowingly collect kids' data, and we'll delete it if we learn we have.

Section 14

Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last updated" date above and, where appropriate, notify you in the app or by email. Your continued use of the Services after an update means you accept the revised policy.

In plain language: if we change this policy in a meaningful way, we'll update the date and let you know.

Section 15

Contact Us

For privacy questions, requests, or to exercise your rights, contact us:

Company: PRIMEGLOW LTD
Email: hello@primeglow.io
Mailing address: Dubai, UAE
Governing jurisdiction: Dubai, UAE

We aim to respond to privacy requests within the timeframes required by applicable law.