Privacy Policy

Introduction

Total Life Longevity LLC, and its affiliates and subsidiaries ("Total Life Longevity," "we," or "us") owns and operates websites located at www.totallife.ai, wellness.totallife.com, daily.totallife.com, wellnesstotallife.com, and www.lily-totallife.com (the "Websites") and/or other applications (collectively, the "Platform" or "Wellness Platform"). Your access and use of the Platform, any part thereof, or anything associated therewith, including its content ("Content"), any products, memberships, or additional services provided through the Platform or otherwise by Total Life Longevity, and any affiliated website, software or application owned or operated by Total Life Longevity (collectively, including the Platform and the Content, the "Service" or "Services") are subject to this Privacy Policy unless specifically stated otherwise. This Privacy Policy is part of our Terms of Use, and all capitalized terms not otherwise defined in this Privacy Policy have the same meaning as set forth in the Total Life Longevity Terms of Use.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES. WHEN YOU USE OUR SERVICES AND PLATFORM YOU ACCEPT AND AGREE TO THIS PRIVACY POLICY.

We are committed to respecting the privacy of users of the Service. We created this Privacy Policy to tell you how Total Life Longevity collects, uses, and discloses information in order to provide you with the Service. If you are a resident of Washington, Nevada, or Connecticut, please also review our Consumer Health Data Privacy Policy, which describes our practices regarding certain consumer health data as defined under applicable state law.

By creating, registering, or logging into an account through the Service, or otherwise accessing or using the Service, you are acknowledging the most recent version of this Privacy Policy. We will update this Privacy Policy when necessary to reflect material changes in the Service or how we use personal information, and as required by applicable law.

If you are using the Service on behalf of an individual other than yourself, you represent that you are authorized by such an individual to act on such an individual's behalf and that such individual acknowledges the practices and policies outlined in this Privacy Policy.

Relationship & Personal Information

When you set up an account with Total Life Longevity, you are creating a direct customer relationship with Total Life Longevity that enables you to access and/or utilize the various functions of the Platform and the Service as a user. As part of that relationship, you provide personal information to Total Life Longevity, including but not limited to, your name, email address, home or physical address, phone number and certain payment and transactional information ("personal information"), which we do not consider to be "protected health information" or "medical information" as defined by applicable laws. During your use of the Services, you may also choose to have your healthcare providers disclose certain health information to us, or you may also choose to share health information from third-party applications to Total Life Longevity which we may treat as sensitive personal information.

Please Note: Total Life Longevity is not a "covered entity" under the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its related regulations and amendments from time to time (collectively, "HIPAA") nor does Total Life Longevity act in any capacity as a "business associate" to Total Life Longevity for the purposes of offering its Wellness Offerings and Memberships. Therefore any medical or health information and other sensitive personal information that you provide or make available to Total Life Longevity's Wellness Platform is not subject to HIPAA and its requirements for protected health information, rather subject only to other applicable laws.

User Content Notice. As described in our Terms of Use, you may choose to participate in the Services by creating User Content. You are solely responsible for all of your own User Content. When you create and share User Content about yourself in our online community, including but not limited to, what may be considered sensitive personal information, you understand that your User Content may be public to other Users. When you submit or share User Content, you also understand that it will be categorized as Personal non-sensitive Information, and used by Total Life Longevity according to this Policy.

Personal Information We Collect and How We Collect It

Personal information that we collect depends on how you interact with us, the services that you use, and the choices you make with regards to our Services and your privacy choices. We collect information about you from different sources and in different ways when you use the Services.

Information You Directly Provide

We collect personal information that you directly provide to us when using the Services, filling out forms, requesting Services, or otherwise contacting or sharing information with us. For example:

• Name and contact information, such as your name, email address, phone number, and billing and physical addresses.
• Demographic data, such as your date of birth, ethnicity, and zip code.
• Social plug-ins, such as third-party websites, networks, platforms, servers and/or application information (e.g., Facebook, Twitter, Instagram).
• Payment information, such as your credit card number, financial account information, and other payment details.
• User Content, such as uploads and posts to the Services like photographs, videos, documents, personal information you volunteer and post, your feedback on the Services, and other files.
• Sensitive Personal Information, including: account & log-in information; government IDs; sensitive demographic data; sex assigned at birth and sexuality; general health data; and contents of communications.

Information We Collect Automatically

We collect information when you use our Services or visit our Websites automatically, for example:

• Information and identifiers about your devices. We log your internet protocol (IP) address and information about your device, operating system browser, and other software including type, version, language, settings, and configuration, including Cookies, Mobile IDs.
• Geolocation data. Depending on the Services that you use and your device settings, we collect geolocation data when you use our Services such as the general location of your IP address.
• User behavior and activity. We automatically log your activity on our Websites, including referring and exit pages and URLs, pages that you viewed, and the order in which you viewed or interacted with the site. In some cases, this data may be considered sensitive personal information if it is obtained in relation to browsing activity on specific condition-related pages.

Information from Third-Party Sources

Sometimes, we collect the types of information described above from third parties we work or do business with. These sources can include publicly available sources, third-party apps and partners, service providers, and co-branding/marketing affiliates.

Information We Develop or Infer

We may develop or create inferences using information about you from the data we collect, including using automated means to infer information about your likely preferences or other characteristics. You may decline to provide us certain data, but if you choose not to provide or allow us to collect the information necessary to access or use certain Services or features, then those Services or features may not be fully functional or available for you.

Cookies, Web Beacons, and Online Tracking

Cookies are small text files placed by a website and stored by your browser on your device. Web beacons are tiny electronic images with unique identifiers that allow web servers to log information about your device and set and read cookies.

We, and our analytics and advertising partners, use these technologies in our websites, platform and online services to collect personal information when you use our services, including personal information about your online activities over time and across different websites or online services. This data is used to store your preferences and settings, enable you to sign in, analyze how our websites and apps perform, track your interaction with the site or app, develop or create inferences, serve you interest-based advertising, combat fraud, and fulfill other legitimate purposes.

There are a range of cookie and related controls available through browsers, mobile operating systems, and elsewhere. See the "Privacy Choices & Controls" section below for details.

Use of Personal Information

We use the personal information we collect for purposes described in this Privacy Policy or as otherwise disclosed by you. These purposes include:

• Product and service delivery. To provide, manage, and deliver the Service, including troubleshooting, facilitating your use of the Service, confirming your location, improving, and personalizing those Services.
• Business operations. To operate our business, such as billing, processing your payments, accounting, administering your account, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, verifying your identity, and meeting our legal obligations.
• Product improvement, development, and research. To develop, test, or improve the Services and content, features and/or products or services offered via the Service, to identify or create new products or services, or to analyze traffic and user behavior.
• Personalization. To understand you and your preferences to enhance your experience and enjoyment using our services.
• Customer support. To provide customer support, fulfill your requests, and respond to your questions.
• Communications. To send you information about us or our affiliated entities, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
• Marketing. To communicate with you about new services, offers, promotions, rewards, contests, upcoming events, and other information about our services and those of our selected partners.
• Advertising. To promote and market our and our Affiliated Entities' Service, and the products and/or services offered via the Service.

We may also aggregate and/or de-identify your information in ways that it may no longer be associated or linked to you or your devices. We can then develop, create, and sell the aggregated and/or de-identified data for any business purpose not prohibited by applicable law.

Use of Artificial Intelligence

We use Artificial Intelligence ("AI") technologies to process information that we collect about you, including information that you share with us or in group settings. Our use of the information we collect may include some automated and some human (or manual) methods of processing. We use AI to personalize content or recommendations, improve the quality, efficiency and accuracy of the Services, and enhance customer support.

IMPORTANT NOTICE: THIS PLATFORM AND ITS CONTENT IS FOR INFORMATIONAL USE ONLY AND DOES NOT CONSTITUTE MEDICAL ADVICE. Our use of AI is not intended to make or provide any medical advice or treatment, and any output provided by any Artificial Intelligence should not be considered medical advice or treatment.

All data processed by AI tools is integrated into the Services in accordance with applicable privacy laws. Any health information that you provide to Total Life Longevity is not considered PHI, as defined by HIPAA. For AI processing, we currently use only Google's Gemini service (paid version), under which Google does not use your content to improve its products, and we maintain a HIPAA agreement with Google covering our Google Cloud hosting. We do not use your sensitive health data, recordings, transcripts, or other information you share with us to train or improve our own AI models.

BY USING THE SERVICES, YOU EXPRESSLY ACKNOWLEDGE AND CONSENT TO OUR USE OF AI TECHNOLOGIES AS DESCRIBED HEREIN, INCLUDING THE PROCESSING OF YOUR DATA IN ACCORDANCE WITH APPLICABLE PRIVACY LAWS. IF YOU DO NOT WISH TO HAVE YOUR INFORMATION BE PART OF OUR AI TECHNOLOGIES, YOUR SOLE AND EXCLUSIVE REMEDY IS TO NOT USE THE SERVICE.

Disclosure of Personal Information

We may disclose your personal information in the following circumstances:

• Subsidiaries and Affiliated Entities. We may disclose personal information to our subsidiaries and Affiliated Entities, which include Wellness Affiliates. Any information relating to you that we provide to our subsidiaries or Affiliated Entities will be treated by them in accordance with the terms of this Privacy Policy.
• Service Providers. We may employ independent contractors, vendors, and suppliers to provide specific services and products related to our Website, or products, such as providing payment processing, fraud screening, implementation of AI technologies, and IT hosting and security.
• Financial services & payment processing. When you make a purchase, we share your payment details and other personal information with banks and other financial institutions to process payments, prevent fraud, and manage other financial services.
• Marketing and Advertising Partners. We may provide personal information, including information obtained through cookies, to marketing and advertising partners to deliver personalized advertising to you or for the purpose of delivering advertisements to other people with similar interests.
• Laws, Law Enforcement, and Legal Rights. We may share your personal information if we are legally required to do so, such as complying with a law, court order, or any other valid legal process.
• Sale or Business Transaction. We may disclose personal information to third parties in connection with a corporate restructuring, sale, acquisition, financing, reorganization, bankruptcy, receivership, transfer, or assignment of assets or business merger or divestiture.
• Third Party Analytics and Advertising. We may also use third-party web analytics and advertising service vendors on our Services. The third-party analytics and advertising partners on our websites include Google Analytics, Facebook, and TikTok.

Privacy Choices & Controls

We provide a variety of ways for you to control the personal information we hold about you, including choices about how we use that data.

• Request access, portability, correction, and deletion. If you wish to request further access, download, copy, request correction, or delete your personal information that we hold, please email wellness@totallife.com to make your request.
• Opt out of sale of and disclosure of information for online personalized advertising. You may opt out by clicking on the "Your Privacy Choices" link on our Website. Moreover, our Website recognizes certain browser-based opt-out preferences and signals (e.g., Global Privacy Control) to the extent required by applicable laws. To opt out of sharing your email address with advertising partners, please send an email to wellness@totallife.com.
• Sensitive Data Opt Out/Opt-In Right. You have a right to limit our use of sensitive data for purposes other than to provide the services or goods you request or as otherwise permitted by law. To opt-out from such additional purposes, please visit the "Your Privacy Choices" page or use the Global Privacy Control.
• Marketing preferences. You can opt out of receiving communications about products, services, promotions, and events by email, postal mail, or phone by contacting us using the details below. In commercial emails, you can also opt out by following the instructions at the bottom.

Browser or Platform Controls

• Cookie controls. Most web browsers are set to accept cookies by default. You can go to your browser settings to learn how to delete or reject cookies.
• Global Privacy Control. When we detect a GPC signal, we will make reasonable efforts to respect your choices indicated by that GPC setting or similar control recognized by regulation.
• Do Not Track. Our websites do not respond to browser DNT signals. Instead, you can use the GPC, cookie controls, and advertising controls described above.
• Mobile advertising ID controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.
• Email web beacons. Most email clients have settings that allow you to prevent the automatic downloading of images, including web beacons.

Data Retention

We retain personal information only as long as necessary to provide services, fulfill transactions and requests for Services, comply with legal obligations, resolve disputes, enforce agreements, and for other lawful and legitimate business purposes. Our data retention periods may vary based on factors like data type, user consent, information sensitivity, availability of options for deletion, and our legal or contractual obligations.

Children's Privacy

Our Websites and Services are not intended for children under the age of 18. If you are under the age of 18, please do not attempt to use the Services or provide any personal or sensitive information about yourself to us. We do not knowingly or intentionally collect or share personal information from individuals under the age of 18. If we discover that we have received any personal information from a child under the age of 13, we will take reasonable action to delete the information as quickly as possible.

Privacy Information for California Residents

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (CCPA), you have certain rights with respect to that information:

• Notice at Collection. At or before the time of collection, you have a right to receive notice of our privacy practices, including the categories of personal and sensitive personal information collected, purposes for which your information is collected or used, whether the information is sold or shared, and how long the information is retained.
• Right to Know. You have a right to request that we disclose to you the personal information we have collected about you, and how it has been used, disclosed, or sold. You may make a "request to know" or access by contacting us at wellness@totallife.com.
• Rights to Request a Correction or Deletion. You also have rights to request that we correct inaccurate personal information and that we delete personal information under certain circumstances. To make a request to correct or delete, email us at wellness@totallife.com.
• Right to Opt-Out / Do Not Sell or Share My Personal Information. You have a right to opt-out from future "sales" or "sharing" of personal information as those terms are defined by the CCPA. We do not knowingly collect, sell or share the personal information of minors under 18 years of age.
• Right to Limit Use and Disclosure of Sensitive Personal Information. You have a right to limit our use of sensitive personal information for any purposes other than to provide the products or services or as otherwise permitted by law.
• Authorized Agent. You can appoint an authorized agent, either in writing or through a power of attorney, to submit your requests or exercise your rights under the CCPA.

Additionally, under California Civil Code section 1798.83 (the "Shine the Light" law), California residents may request information about our disclosure of certain categories of personal information to third parties for their direct marketing purposes. We do not disclose your personal information to third parties for their own direct marketing purposes.

Additional Privacy Considerations

Securing Accounts & Password Information. We take actions to implement appropriate physical, technical, and administrative safeguards to protect information from unauthorized access, use, disclosure, alteration, or destruction. However, it is your responsibility to maintain the confidentiality of your account information and password, and for any and all use or access of your account. You must use a strong, unique password for your account and never share it with others.

Linked Sites. The Site may contain links to third party owned or operated websites. This Policy and the practices that we follow under this Policy do not apply to Linked Sites. We are not responsible for the content, accuracy, or opinions expressed on any Linked Site or for the privacy practices or security standards used by third parties on such Linked Sites.

Revisions to Our Privacy Policy

We may update this Privacy Policy to reflect changes in law, our data practices, Services, or technology. The revised policy will be available through the Services, and you should review it periodically. The last revision date is at the top of the document. If significant changes are made, we will notify you as required by applicable law. Your continued use of our Websites or Services after changes signifies your acknowledgment of Privacy Policy updates.

Contact Us

If you have any questions or comments about this Privacy Policy, please contact us: