Draft — under legal review.

SageKin Privacy Policy

Last Updated: August 18, 2026

I. Introduction

We are committed to protecting the privacy of our users and providing them with detailed information on how their information is used and protected. This policy is effective as of date of first published and any update becomes effective as of the Last Updated date as referenced herein.

This Privacy Policy describes how Cuffie Industries LLC and its affiliates (collectively "SageKin," "we," "our," or "us") collect and process your personal information through our website, mobile application, and related services (together, the "Services"). Any capital words not defined but included in this privacy policy shall have the meaning set forth in the Terms of Use. By using SageKin's Services, you are consenting to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, do not access or use the Services.

Our commitments to you: We do not sell your data. We do not use your health information for advertising, and we do not share it with ad platforms. We never share your information with insurers for underwriting or pricing. We never share your information with employers for employment decisions. Anything you share with a care team is started by you, and you can stop it.

II. Health Information

The Platform does not maintain or store Protected Health Information ("PHI"), as defined under the Health Insurance Portability and Accountability Act ("HIPAA"). If you choose to provide personal or health-related information to an independent medical practice or health care provider through the Platform, the Platform facilitates the transmission of that information but does not receive, maintain, or transmit it as a business associate or in connection with a HIPAA-covered transaction.

III. Information Collected by Us

We collect the following types of information:

Information You Disclose.

We receive information about you when you provide it through forms or surveys, and when you sign up for a user account and use our Services. In addition, we receive information about you when you use, edit, or access your account. As a result of those actions, you may supply us with certain information, including, but not limited to, your name, email address, state of residence, payment or financial information, and other information.

Information Automatically Collected.

We may automatically collect certain information resulting from your use of our Services. This information may include your IP address, login details, password, and the location of your device. We may also use device identifiers, cookies (including browser cookies), web beacons, tokens, scripts, and other technologies on devices, applications, emails, and our web pages to collect information about your browsing actions and patterns, information about your devices (such as information related to your computer or device, internet connection, operating system, and internet browser type), or other technical information.

A "cookie" is a small file stored on your computer and may be placed when you visit our website. Our system will issue cookies when you direct your browser to our website.

We and our authorized service providers use cookies and similar tracking technologies to support the secure and effective operation of our website. These technologies help ensure a seamless user experience, analyze performance, and, where permitted, deliver relevant content and communications. Specifically, they allow us to: securely authenticate users and maintain login sessions; detect, prevent, and respond to security incidents; collect analytics (e.g., performance diagnostics, usage patterns); support product development; and improve platform functionality, accessibility, and reliability. We may also use these technologies for research purposes and, with appropriate notice and consent, to personalize the user experience. Cookies may collect or transmit information each time you use our website and may continue to operate until manually cleared or until they expire.

We may use the following tracking technologies on our website, platform, and/or mobile app:

• Cookies: Small text files stored on your browser or device to remember preferences or recognize returning users.
• Session Cookies: Temporary cookies that expire once you close your browser.
• Persistent Cookies: Remain on your device until deleted or expired.
• Web Beacons & Pixels: Small graphic images or code snippets that monitor activity (e.g., whether an email was opened or a page was visited).
• SDKs and Device Identifiers: Mobile technologies used to recognize your device and track usage within mobile applications.

Your Choices: Where required by law, we will present you with a cookie banner or preference manager to allow you to consent to or decline non-essential cookies. You may also disable or delete browser cookies through your browser settings. However, if you select this setting, you may be unable to access certain parts of our website.

Information We Obtain from Third-Party Sources.

We may also obtain the information described above from third parties. These third parties may include: analytics companies; your mobile device manufacturer; your mobile service provider; social media network applications and services with which you choose to connect or interact through our Services; publicly available sources such as government databases; and service providers that collect data for work they complete on our behalf, such as determining your device's location based on an IP address.

IV. Information Collected by Third Parties

When you use the Services, certain third parties -- such as your mobile device manufacturer, operating system provider, browser provider, and mobile service provider -- may use automatic information collection technologies to collect information about you or your device. We do not control these third parties. We do not permit advertising networks to collect information about you through the Services, and we do not share your personal information with third parties for interest-based or targeted advertising.

We do not control these third parties' tracking technologies or how they may be used.

V. How We Use Your Information

We collect your information to provide and improve our Services. In addition, we may use and disclose aggregated or de-identified information that cannot reasonably be used to identify you (for example, overall usage statistics); we do not sell your personal information.

Information you disclose is used to provide, improve, and develop our Services. We, our partners, contractors, or agents, may use personal information about you for various purposes, including, but not limited to:

• Conducting internal research and development and making business decisions about current and future product and Service offerings;
• Responding to your comments, questions and requests and providing customer service;
• Communicating with you about products, services, offers, promotions, rewards and events and providing news and information we think will be of interest to you;
• Managing your online account(s) and sending you technical notices, updates, security alerts and support and administrative messages;
• Personalizing your online experience and providing content or features that match your profile and interests;
• Monitoring and analyzing trends, usage and activities;
• Complying with any court order, law, or legal process, and responding to any government or regulatory request;
• Enforcing or applying our Terms of Use; and/or
• Fulfilling any other purpose for which you provided the information.

Information automatically collected is used generally to improve our Services. In addition to the uses related to the information that you disclose, as outlined above, we may use information automatically collected in a similar manner. We may also combine this information with other information we collect about you and use it for various purposes, such as improving our websites and your online experience, understanding which areas and features of our sites are popular, counting visits, tailoring our communications with you, determining whether an email has been opened and links within the email have been clicked and for other internal business purposes.

VI. How Collected Information Is Shared by Us

We may share your personal information with our affiliates, partners and other third parties, including service providers and subcontractors, to:

• Assist us with the maintenance and operation of the Services;
• Market and promote the Services, including the measurement of the success of such efforts;
• Comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• Enforce or apply our Terms of Use;
• Protect our, our customers', or others rights, property, or safety; or
• Disclose to a buyer or other successor entity in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We do not sell your personal information, and we do not share your personal information with advertising networks or use it for targeted advertising. Financial information collected by us may be shared with third-party payment processors and/or other entities to process payments for the use of our Services.

VII. Privacy and Security

We design our systems with your security and privacy in mind, and we maintain administrative, technical, and physical safeguards to protect your personal information from unauthorized access, use, or disclosure. These safeguards vary based on the sensitivity of the information that is collected.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. Do not share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on our website.

VIII. Notification of Changes

We reserve the right to change this Privacy Policy from time to time in our sole discretion. Your continued use of our Services indicates your consent to the Privacy Policy as posted. The date the Privacy Policy was last revised is identified at the top or bottom of this page. If we make material changes to how we treat our users' personal information, we will notify you by email or through a notice on our website. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this Privacy Policy to check for any changes.

IX. Categories of Third Parties to Whom We May Disclose Data

We may disclose personal information for business purposes to the following categories of service providers:

• Cloud hosting and infrastructure providers (Identifiers, Internet Activity)
• Analytics providers (Internet Activity)
• Payment processors (Identifiers, Purchase History)
• Email delivery providers (Identifiers)

We do not disclose or share personal information with advertising networks, and we do not disclose or share personal information for cross-context behavioral advertising. If you would like to request deletion or correction of your personal information, please contact us at richard@sagekin.net.

X. Accessing/Deleting Your Personal Information

You may be able to update, correct, or delete your personal information by contacting us. We may not be able to delete your information, personal or otherwise, without also deleting your account, and we may not accommodate a request to change or delete information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

XI. Retention of Your Information

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

XII. California Residents

Consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act ("CCPA"), as amended. If you are a California resident, and if the CCPA applies to us, you have certain rights and can make certain requests regarding your personal information. We will fulfill each of these requests to the extent required and permitted by law. We collect and retain your personal information only to the extent reasonably necessary and proportionate for any disclosed purpose. Additionally, we have adopted reasonable security measures to protect such information.

We will not discriminate against any consumer for exercising their rights under the California Consumer Privacy Act. This generally means we will not deny you goods or services, charge different prices or rates, provide a different level of service or quality of goods, or suggest that you might receive a different price or level of quality for goods.

You can make these requests by emailing richard@sagekin.net.

If you are a California resident, the rights referenced in this section may apply to you at such time that we become subject to CCPA. Currently, we are not subject to the CCPA. At such a time that we become subject to the CCPA, updated terms will be posted to this policy.

XIII. Your State Privacy Rights

Certain states afford their residents additional rights with respect to their personal information.

You may have the right to:

• Opt-out of the processing of your personal data for purposes of:
  • Targeted advertising
  • Sale of personal data
  • Profiling that produces legal or significant effects on you
• Opt-out of the processing of sensitive data, including precise geolocation data, or the processing of sensitive data.
• Opt-out of the collection of personal data collected through the operation of voice recognition or facial recognition features.
• Access your data and confirm whether we have collected, held, or processed your data.
• Obtain a list of third parties to which we have disclosed your personal data or any other personal data.
• Request and receive a copy of the personal information you previously provided, delivered in a portable and readily usable format.
• Delete personal data that we have collected and held about you.
• Correct inaccuracies in your personal data held by us.
• Receive your requested data in a usable, portable, and transferable form that allows you to transmit the data to another controller without hinderance.
• Non-discrimination or retaliation for exercising any of these rights. This generally means we will not deny goods and services, change prices or rates for goods or services, or provide a different level of quality or selection of goods or services if you exercise your rights.

Responding to Requests. We are required to respond to your requests without undue delay but within 45 days of receipt of your request. Depending on factors such as the type and complexity of the request, if we notify you within the original 45 days, we may extend the time for response once for an additional 15 days.

• If we decline to take action regarding your request, we must notify you without undue delay, but within 45 days of the receipt of the notice and provide information on our appeal process. We are required to provide justification and provide information on the appeal process within a reasonable time after the communication of the decision to decline.
• You can request information free of charge twice per year. For a third or subsequent request within a 12-month period, depending on your state of residence, we reserve the right to charge a fee for our provision of your information.

How to Exercise Your Rights. If you would like to exercise any of your rights described in this Privacy Policy, you can do so through our website. You may email us at richard@sagekin.net.

• If you wish to exercise your opt-out rights, you can do so through our website by selecting the link that states "Opt-Out Rights." If you wish to designate an agent to exercise your rights on your behalf or are a guardian or conservator exercising consumer rights on behalf of another individual, you may contact us on our website. You may email us at richard@sagekin.net. If your request to exercise your rights is declined, you may appeal the decision by contacting us either by email as designated herein or by following the process on our website.
• If you need to contact us for any reason, you may submit your inquiry through our website contact page, which shall process and provide your communication to one of our representatives. You may email us at richard@sagekin.net.
• If you choose to contact us directly by emailing us as designated herein, you will need to provide us with:
  • Enough information to identify you (e.g., your full name, address and customer or matter reference number);
  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
  • A description of what right you want to exercise and the information to which your request relates.
• We will honor universal opt-out signals, such as those sent by a browser or device setting, in accordance with applicable data privacy laws.
• We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.

Any personal data we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

XIV. The Collection of Minor's Data

The Services are intended for adults. You must be at least eighteen (18) years of age to register for or use the Services, as provided in our Terms of Use. The Services are not directed to children, and we do not knowingly collect personal information from anyone under the age of 18. If we learn that we have collected personal information from a person under the age of 18, we will delete that information and close the associated account. If you believe we may have collected information from a person under 18, please contact us at richard@sagekin.net.

XV. Contact Information

If you have any questions about this Privacy Policy, please contact us at: richard@sagekin.net. You may also request that we help you access, modify or delete your data, by contacting us using the information provided above.