Your data exists to serve you.

NATUR Health Systems develops technology designed to help people better understand their health.

Your health information belongs to you. NATUR collects personal information to operate the Platform, organize and explain health information you choose to provide, and support informed conversations with qualified healthcare professionals.

This Privacy Policy is built around a simple principle:

Your data exists to serve you.

Consistent with that principle:

• You retain ownership of the User Content you submit to the Platform, subject to any rights held by third parties.
• NATUR will not sell your personal health information.
• NATUR will not use personal health information for third-party targeted advertising or permit third parties to build advertising profiles from identifiable user health information.
• NATUR will not use identifiable personal health information to train generalized artificial intelligence models without explicit user consent.
• Where appropriate, you should be able to review information, correct information, manage preferences, export eligible information, delete eligible information, and control consent.

This Privacy Policy explains how NATUR Health Systems collects, uses, discloses, retains, secures, and deletes personal information in connection with websites, applications, software, artificial intelligence services, health-information tools, educational materials, and related services operated by NATUR Health Systems.

Collectively, these services are referred to as the "Platform."

The Platform may include:

• NATURhealth.us.
• NATUR Kidney Safe.
• Neural Adaptive Trainer (NAT).
• Laboratory-document processing.
• OCR services.
• Health dashboards.
• Educational resources.
• User reports.
• Future NATUR applications and services.

This Privacy Policy is incorporated into the Terms of Use by reference.

Please read it carefully, together with the Terms of Use.

NATUR Health Systems operates the Platform.

Certain core NATUR intellectual property, including Neural Adaptive Trainer (NAT), is owned or managed by NATUR IP LLC and licensed to NATUR Health Systems for use throughout the NATUR ecosystem.

References to "NATUR" in this Privacy Policy generally refer to NATUR Health Systems and, where the context appropriately concerns ownership or affiliated operations, applicable NATUR affiliated entities.

Privacy-related inquiries should be directed to the contacts listed in the Contact Information section of this Privacy Policy.

The Terms of Use govern your access to and use of the Platform.

This Privacy Policy governs NATUR's collection, use, disclosure, retention, security, and deletion of personal information.

If the Terms of Use and this Privacy Policy address the same issue differently, this Privacy Policy will govern with respect to the collection, use, disclosure, retention, or protection of personal information, unless applicable law requires otherwise.

If you access NATUR through a healthcare organization, employer program, research program, enterprise customer, or other institutional relationship, additional agreements may govern that relationship. If an applicable enterprise or healthcare agreement conflicts with this Privacy Policy, the more specific agreement may control for the applicable service or relationship, subject to applicable law.

The information NATUR collects depends on how you use the Platform. NATUR collects only what is reasonably necessary to provide the services you request, operate the Platform, maintain security, and comply with applicable law.

Information You Provide

Certain Platform features require a registered account. When you create or maintain an account, you may provide information such as your name, contact information, login credentials, and other account details. You agree to provide accurate information and keep required information reasonably current.

The Platform may allow you to submit, upload, store, transmit, enter, or otherwise provide information and materials, including:

• Laboratory reports.
• Medical records.
• Images.
• PDFs.
• Dialysis logs.
• Health information.
• Nutrition information.
• Journal entries.
• Notes.
• Questions submitted to NAT.
• Feedback.
• Goals, target ranges, preferences, or information supplied by your healthcare team.
• Other supported content.

Collectively, these materials are referred to as "User Content."

You should not upload another person's confidential medical or personal information unless you are legally authorized to do so.

Information Generated Through Use of the Platform

NATUR may collect information generated when you use the Platform, as reasonably necessary to operate, secure, personalize, and support the services. This may include:

• Account activity and security events.
• Technical or diagnostic information used to operate and protect the Platform.
• Records of communications you send to NATUR, including support requests.
• Preferences, verification actions, and consent records.
• Information associated with your account that NAT uses to personalize how information is presented.

Payment Information

If you purchase a paid service, payment processing may be performed by an authorized third-party payment processor.

NATUR should not store complete payment-card credentials directly unless the Platform architecture and applicable security requirements support that function.

Cookies and Similar Technologies

NATUR may use cookies or similar technologies as reasonably necessary to operate the website, maintain sessions, remember preferences, and protect security.

NATUR will not use cookies or similar technologies to enable third-party targeted advertising based on identifiable health information.

NATUR uses personal information as reasonably necessary to:

• Provide services you request.
• Operate Platform functionality.
• Process documents, including OCR and laboratory-report organization.
• Operate Neural Adaptive Trainer (NAT).
• Personalize your experience.
• Provide customer support.
• Maintain security and investigate suspected unauthorized access, fraud, or unlawful activity.
• Communicate with you about Platform operations, as described in this Privacy Policy.
• Comply with applicable law.
• Perform other processing disclosed in this Privacy Policy.

NATUR may also use information in de-identified or aggregated form that does not identify you, to the extent permitted by applicable law. De-identification or aggregation does not independently authorize generalized AI model training using identifiable personal health information.

You retain ownership of the User Content you submit to the Platform, subject to any rights held by third parties.

Submitting User Content to NATUR does not transfer ownership of that content to NATUR.

By submitting User Content, you grant NATUR Health Systems a limited, non-exclusive, worldwide license to host, store, copy as technically necessary, process, analyze, transmit, display to you, convert, organize, and generate authorized summaries or explanations from your User Content as reasonably necessary to:

• Provide services you request.
• Operate Platform functionality.
• Process documents.
• Operate NAT.
• Personalize your experience.
• Provide customer support.
• Maintain security.
• Comply with applicable law.
• Perform other processing disclosed in this Privacy Policy.

This license does not give NATUR an unrestricted right to commercially exploit your identifiable health information.

The license granted through the Terms of Use does not independently authorize generalized AI model training using identifiable personal health information.

NATUR recognizes that information entered into a digital health platform may be sensitive even when it does not technically qualify as Protected Health Information under HIPAA.

HHS notes that many personal-use health applications are not covered by HIPAA unless the application is provided by or acting on behalf of a covered entity or business associate.

Accordingly, NATUR's privacy framework addresses both:

• HIPAA-regulated PHI where HIPAA applies.
• Consumer health information and other sensitive health information outside HIPAA.

HIPAA Relationships

The existence of medical or health information in a NATUR account does not automatically make NATUR a HIPAA-covered entity or business associate.

NATUR may become subject to HIPAA obligations for particular services or relationships—for example, where NATUR performs functions involving PHI on behalf of a covered healthcare organization. HHS defines a business associate by the function or service performed and the involvement of PHI, rather than simply because an application handles health-related information.

Where required, NATUR will use appropriate agreements and safeguards for those services.

Consumer Health Privacy

Health applications outside HIPAA may remain subject to other privacy and breach requirements.

For example, the FTC Health Breach Notification Rule applies to covered vendors of personal health records and related entities and requires notifications following qualifying breaches of unsecured health information.

Depending on your place of residence, additional consumer health privacy laws may also apply. NATUR will treat consumer health data in accordance with this Privacy Policy and applicable law.

Neural Adaptive Trainer (NAT) is the proprietary health intelligence engine developed and owned or managed by NATUR IP LLC and licensed to NATUR Health Systems for use throughout the NATUR ecosystem.

NAT uses artificial intelligence, computational technologies, and adaptive methods to organize, analyze, summarize, and explain information.

Personalization

A NAT response may be personalized using information associated with your account, such as user preferences, previous interactions, requested level of detail, and relevant health context.

Personalization does not mean NAT has independently established a diagnosis, a prognosis, a treatment plan, a medication order, or a clinical determination.

Personalized processing for an individual user does not automatically authorize generalized model training.

Generalized AI Training

NATUR will not use identifiable personal health information to train generalized artificial intelligence models without explicit user consent.

Where applicable law requires separate or affirmative consent for generalized AI model training, NATUR will request that consent. General acceptance of the Terms of Use does not substitute for that required consent.

Updating the Terms of Use or this Privacy Policy does not automatically authorize NATUR to use identifiable health information for generalized AI training.

Certain Platform services allow users to upload documents for processing by Optical Character Recognition (OCR) and related technologies.

Documents may include:

• Laboratory reports.
• Medical documents.
• Dialysis information.
• Images.
• PDFs.
• Other supported health documents.

Authorization to Process

By intentionally uploading a document for processing, you authorize NATUR to perform the technical processing reasonably necessary to provide the requested functionality.

This may include:

• Reading supported document content.
• Extracting text.
• Identifying laboratory measurements.
• Identifying units.
• Structuring extracted information.
• Associating information with your account.
• Performing validation checks.
• Presenting extracted information for review.
• Using verified information in authorized NATUR features.

Uploading a document does not transfer ownership of the original document to NATUR.

Accuracy and Review

OCR and automated document-processing systems may make errors. Where the Platform provides verification functionality, you should review extracted information before treating it as an accurate representation of the original document.

Storage, retention, deletion, and use of uploaded documents are governed by this Privacy Policy.

NATUR does not sell personal health information.

The Platform may rely on, integrate with, or provide access to technologies or services operated by third parties. These may include:

• Cloud providers.
• Authentication providers.
• OCR services.
• Artificial-intelligence infrastructure.
• Payment processors.
• Analytics providers.
• Email providers.
• Laboratories.
• Healthcare organizations.
• External educational resources.
• Future health-device or data integrations.

NATUR Service Providers

Some third parties act as vendors or service providers to NATUR rather than independent services selected directly by users.

Those vendors may process personal information on NATUR's behalf as reasonably necessary to operate the Platform. Their handling of personal information is addressed in this Privacy Policy and applicable contracts.

Where NATUR acts in a HIPAA-regulated business-associate relationship, vendors or subcontractors handling PHI may themselves require appropriate contractual safeguards. HHS explains that business-associate contracts generally establish and limit permissible uses and disclosures of PHI and require appropriate safeguards.

Sharing That Requires Separate Authorization

NATUR may separately request consent concerning provider sharing, research participation, consumer health-data disclosures, or other activities requiring specific authorization.

Where applicable law requires separate or affirmative consent, general acceptance of the Terms of Use does not substitute for that required consent.

Legal and Safety Disclosures

NATUR may disclose personal information when reasonably necessary to:

• Comply with applicable law, legal process, or governmental requests.
• Protect the security, integrity, or availability of the Platform.
• Investigate suspected unauthorized access, fraud, or unlawful activity.
• Protect the rights, safety, or property of NATUR, users, or others, to the extent permitted by law.

Independent Third-Party Services

Your use of an independently operated third-party service may create a separate legal relationship between you and that provider. A third-party service may be subject to separate terms of service, privacy policies, licenses, or consent requirements.

Links to external resources do not automatically constitute medical endorsement, commercial endorsement, or approval of all content available through that resource.

NATUR will not use personal health information for third-party targeted advertising or permit third parties to build advertising profiles from identifiable user health information.

Identifiable personal health information will not be used for third-party targeted advertising or provided to third parties to build advertising profiles.

Updating this Privacy Policy does not automatically authorize NATUR to introduce third-party targeted advertising based on health information.

Where applicable law requires separate or affirmative consent for a particular activity, general acceptance of the Terms of Use does not substitute for that required consent.

NATUR may separately request consent concerning:

• Certain health-data processing.
• Generalized AI model training.
• Provider sharing.
• Research participation.
• Consumer health-data disclosures.
• Other activities requiring specific authorization.

A general product change, and a general revision to the Terms of Use or this Privacy Policy, does not authorize NATUR to materially change sensitive health-data processing without obtaining additional consent where applicable law requires it.

For example, updating these documents does not automatically authorize NATUR to:

• Use identifiable health information for generalized AI training.
• Introduce third-party targeted advertising based on health information.
• Disclose consumer health data in circumstances requiring separate consent.
• Materially expand sensitive data processing where affirmative authorization is legally required.

Where applicable law requires specific consent to receive a particular record electronically, NATUR will obtain that consent as required.

By creating a NATUR account, you agree that NATUR may communicate with you electronically regarding Platform operations, subject to applicable law and your communication preferences.

Electronic communications may include:

• Account verification.
• Password resets.
• Security alerts.
• Privacy notices.
• Terms updates.
• Service notices.
• Requested reports.
• Support communications.
• Transactional notices.
• Other legally permitted communications.

Sensitive Health Information

NATUR will seek to minimize sensitive health information displayed in ordinary:

• Email.
• SMS.
• Push notifications.
• Device lock-screen notifications.

Where practical, sensitive information should remain within an authenticated Platform environment.

For example, NATUR may provide:

You have a new health update. Sign in to NATUR to review it.

rather than placing detailed laboratory or treatment information directly in a notification.

Detailed laboratory values, diagnoses, medication information, or similarly sensitive information should ordinarily not appear in unsecured email, SMS, or lock-screen notifications.

Marketing Communications

Optional marketing or educational communications may be managed separately from essential account and security communications.

Unsubscribing from promotional communications will not necessarily prevent NATUR from sending security notices, account notices, legal notices, transactional communications, or other communications necessary to operate the service.

NATUR retains personal information as reasonably necessary to provide the Platform, maintain security, honor consent and account records, and comply with applicable law.

Deletion

User Content may be deleted through available Platform functionality or eligible privacy requests.

Deletion is subject to:

• Applicable law.
• Legitimate security obligations.
• Required record retention.
• Backup lifecycle processes.
• Other circumstances described in this Privacy Policy.

Account Closure

You may stop using the Platform at any time.

Eligible users may also close their accounts through available account functionality or the procedures described in this Privacy Policy.

Where reasonably feasible and legally permitted, NATUR should provide an opportunity to export eligible user information before permanent account termination when termination is not required immediately for security or legal reasons.

Account termination does not automatically require immediate destruction of all information.

Certain information may remain subject to:

• Legal retention.
• Security records.
• Consent records.
• Audit logs.
• Backup lifecycle processes.
• Other retention rules established in this Privacy Policy.

If NATUR permanently discontinues a major consumer service, NATUR should, where reasonably feasible and legally permitted, provide advance notice, explain applicable deletion or retention procedures, and allow users an appropriate opportunity to export eligible information.

Where appropriate, and subject to applicable law, you should be able to:

• Review information.
• Correct information.
• Manage preferences.
• Export eligible information.
• Delete eligible information.
• Control consent.

You should review important extracted or generated information and correct known inaccuracies where Platform functionality permits.

Privacy Requests

Depending on your place of residence, applicable law may provide additional rights concerning personal information or consumer health data. Those rights may include, subject to legal exceptions, the right to:

• Confirm whether NATUR processes your personal information.
• Access personal information.
• Correct inaccuracies.
• Request deletion of eligible information.
• Obtain a copy of eligible information.
• Withdraw consent where processing is based on consent.
• Appeal a refusal to act on a request.

NATUR will honor eligible requests as required by applicable law. Where applicable law permits you to designate an authorized agent, NATUR may require information reasonably necessary to verify the request and the agent's authority.

To exercise a privacy right, contact Team@naturhealth.us or use available Platform functionality.

Unless a particular NATUR service expressly states otherwise, the Platform is not directed to children under 13.

Certain services may establish additional age or parental-consent requirements.

If NATUR introduces products specifically intended for minors, those products may be subject to separate eligibility requirements, parental or guardian consent, privacy notices, safety controls, and terms or supplemental agreements.

NATUR uses reasonable safeguards appropriate to the sensitivity of health information to protect personal information against unauthorized access, use, alteration, or destruction.

You agree to maintain control of your login credentials, use reasonable measures to protect your account, and notify NATUR promptly if you suspect unauthorized access.

NATUR may take reasonable protective actions if we detect suspected unauthorized access, credential compromise, fraud, security threats, or unlawful activity. Those actions may include temporary account restrictions, forced credential resets, additional verification, or suspension.

Privacy safeguards should be incorporated into product design and development rather than treated solely as legal disclosures.

No method of transmission or storage is completely secure. NATUR cannot guarantee that unauthorized access will never occur despite reasonable security safeguards.

A force-majeure event, including a cyberattack despite reasonable security measures, does not authorize NATUR to disregard applicable privacy or security responsibilities. Where reasonably practicable, NATUR will seek to protect user information, maintain security, communicate significant service disruptions, and execute appropriate recovery procedures.

If NATUR becomes aware of a security incident affecting personal information, NATUR will take reasonable steps to investigate, contain, and remediate the incident, and will provide notifications as required by applicable law.

Where HIPAA applies to a particular service or relationship, NATUR will follow applicable HIPAA breach-notification requirements for that service or relationship.

Health applications outside HIPAA may remain subject to other privacy and breach requirements. For example, the FTC Health Breach Notification Rule applies to covered vendors of personal health records and related entities and requires notifications following qualifying breaches of unsecured health information.

Additional state consumer-health or personal-information breach laws may also apply depending on the nature of the information and your place of residence.

NATUR may assign or transfer its rights and obligations in connection with a merger, acquisition, corporate restructuring, reorganization, financing, sale of substantially all relevant assets, or transfer of a NATUR product or business operation to an affiliated or successor entity.

Any assignment involving personal information remains subject to:

• Applicable privacy law.
• This Privacy Policy.
• Applicable contractual obligations.
• User rights that survive the transaction.

An acquisition or restructuring does not automatically authorize materially different use of identifiable health information where new consent is required by law.

NATUR may update this Privacy Policy as the Platform, legal requirements, technology, products, or business operations evolve.

When this Privacy Policy is revised, NATUR will update the Last Updated date.

Where changes materially affect users' privacy rights or data use, NATUR may provide additional notice through the Platform, account notifications, email, NATURhealth.us, or another reasonable method.

Where applicable law requires renewed affirmative consent, NATUR will request that consent rather than treating continued use alone as sufficient.

A general revision to this Privacy Policy will not itself authorize processing that requires separate consent under applicable law or NATUR policy.

NATUR should maintain an internal record of prior published Privacy Policy versions and their effective dates. This helps establish which version governed a user relationship at a particular time.

Questions concerning this Privacy Policy, your personal information, or a privacy request may be directed to:

Organization

NATUR Health Systems, Legal Department

Website

NATURhealth.us

Email

Team@naturhealth.us

Mailing Address

To be established before public launch

Questions about how the Platform works, your account, or support for product use may also be directed through NATUR Support.