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Introduction

This Privacy Notice for Relvema Inc. (doing business as Relvema) ("we", "us", or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at https://relvema.com or any website of ours that links to this Privacy Notice
• Download and use our mobile application (Relvema), or any other application of ours that links to this Privacy Notice
• Use Relvema. Relvema is a patient-first therapy companion app that helps users capture, reflect on, and act upon insights from their therapy sessions. The app provides summaries of recorded therapy sessions, personalized actions and journaling prompts, and progress tracking tools to support emotional growth between sessions. Relvema is not a medical or diagnostic service, healthcare provider, or mental health practice, and does not replace therapy. Nothing in the Services constitutes medical advice, diagnosis, or treatment. Always consult your therapist or qualified health provider with questions about your mental health.
• Use the Relvema browser extension to copy your signed clinical notes into your electronic health record (EHR)
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@relvema.com.

Relvema browser extension

We offer an optional Relvema browser extension for therapists. Its only purpose is to help you move your own signed clinical notes from your Relvema account into your electronic health record (EHR) system.

When you connect and use the extension:

• Clinical note content (health information). The extension retrieves your own signed clinical notes — including their text and any diagnosis and CPT/billing codes — from Relvema so you can copy them or insert them into your EHR's note and billing fields. This information already resides in your Relvema account; the extension only displays it to you and places it into the EHR page you have open.
• Account-link token (authentication information). Connecting the extension creates a secure, revocable token stored on your device that authenticates the extension to your Relvema account. You can revoke it at any time from your Relvema settings.
• The open client's name. On a supported EHR page, the extension reads the name of the client whose chart you currently have open, only to show you the matching note. It is used momentarily and is not stored or transmitted.

Your note content travels only from Relvema to the EHR page you already have open in your browser. The extension does not send your notes or any page content to any third party, and we do not sell or share this information. It requests only the permissions needed for this single purpose and operates only on your Relvema account and the EHR sites it supports.

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register for the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• email addresses
• passwords
• contact preferences
• contact or authentication data
• audio recordings
• text input
• therapy sessions

Sensitive Information.

We may process sensitive information when necessary with your consent or as otherwise permitted by applicable law. We process the following categories of sensitive information:

• health data
• user-submitted reflection or therapy-related data (which may incidentally contain sensitive information)

Payment Data.

We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. Relvema consumer application subscriptions are processed through Apple In-App Purchase (iOS) and Google Play Billing (Android), managed via RevenueCat. Relvema for Therapists subscriptions are processed through Stripe. In all cases we do not directly collect or store your payment card information. You may review their privacy notices here: Apple Privacy Policy, Google Privacy Policy, RevenueCat Privacy Policy, and Stripe Privacy Policy.

Social Media Login Data.

We may provide you with the option to register with us using your existing third-party account details, like your Google or Apple account. If you choose to register in this way, we will collect certain information about you from your third-party account, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

Application Data.

If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's microphone, calendar, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server).
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files.
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
• Generate therapy session summaries. To process session recordings and notes in order to provide users with AI-generated summaries and insights.

3. What legal bases do we rely on to process your information?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

4. When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers.

We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work.

The third parties we may share personal information with are as follows:

• AI Service Providers — Google Cloud AI
• Allow Users to Connect to Their Third-Party Accounts — Google account and Apple account
• Cloud Computing Services — Google Cloud Platform
• Functionality and Infrastructure Optimization — Cloud Functions for Firebase and Cloud Storage for Firebase
• Subscription Billing — Apple In-App Purchase (iOS) and Google Play Billing (Android) via RevenueCat for the consumer application, and Stripe for Relvema for Therapists subscriptions
• User Account Registration and Authentication — Google OAuth 2.0
• Website Hosting — Firebase App Hosting (Google Cloud)
• Website Testing — TestFlight

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

Website Analytics

We do not use Google Analytics, Mixpanel, Segment, or similar third-party behavioral analytics on relvema.com, therapist.relvema.com, or within our mobile applications, and we do not track individual users across sites. We rely only on aggregate, privacy-preserving server metrics necessary to operate, secure, and troubleshoot the platform.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

6. Do we offer artificial intelligence-based products?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

Our Services include products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide innovative solutions.

Use of AI Technologies

Our AI Products are provided through third-party service providers ("AI Service Providers"), including Google Cloud AI. Your input, output, and personal information will be shared and processed by these AI Service Providers to enable the use of AI Products.

Our AI Products

Our AI Products are designed to perform the following functions:

• Audio transcription of therapy session recordings using Google Cloud Speech-to-Text
• AI-generated session summaries, key insights, and personalized reflection prompts using Google Cloud AI (Gemini)
• Onboarding personalization and therapy goal analysis based on user-provided information

How We Process Your Data Using AI

All personal information processed using AI Products is handled in line with this Privacy Notice and our agreements with third parties, ensuring high security and safeguarding personal information for data safety.

7. How do we handle your social logins?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your existing third-party account details, currently including Google and Apple. Where you choose to do this, we will receive certain profile information about you from your third-party provider. The profile information we receive may vary depending on the provider but will typically include your name, email address, and profile picture.

8. How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law.

Audio Recordings. Raw audio recordings of therapy sessions are retained only as long as necessary to complete transcription and AI processing. Raw audio files are deleted immediately once the associated clinical note is ready; in no case are they retained for longer than 30 days, which serves only as a backstop in the event of a processing failure. Transcripts and AI-generated insights are retained for the duration of your account. You may request earlier deletion of your recordings at any time by contacting us at info@relvema.com.

9. How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

10. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly solicit data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If you become aware of any data we may have collected from children under age 18, please contact us at info@relvema.com.

11. What are your privacy rights?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making.

Withdrawing your consent:

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating your preferences.

Opting out of marketing and promotional communications:

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

Account Information:

If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided or log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at info@relvema.com.

12. Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

California law requires us to let you know how we respond to web browser DNT signals. Because there is not yet an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

13. Do United States residents have specific privacy rights?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months.

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	YES
B. Personal information as defined in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	YES
C. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	NO
D. Commercial information	Transaction information, purchase history, financial details, and payment information	YES
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	NO
G. Geolocation data	Device location	NO
H. Audio, electronic, sensory, or similar information	Images and audio, video or call recordings created in connection with our business activities	YES
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	NO
J. Education Information	Student records and directory information	NO
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics	YES
L. Sensitive personal Information	Health data and account login information	YES

Your Rights

You have rights under US state data protection laws. In general, you have the right to:

• Right to know whether personal data is being processed.
• Right to access personal data.
• Right to correct inaccuracies.
• Right to request deletion of personal data.
• Right to obtain a copy of previously shared personal data.
• Right to non-discrimination for exercising rights.
• Right to opt out of processing for targeted advertising, sale of personal data, or profiling.

How to Exercise Your Rights

To exercise your rights, you can:

• Visit https://relvema.com/contact
• Email us at info@relvema.com

14. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.

15. How can you contact us about this notice?

If you have questions or comments about this notice, please contact us at:

Relvema Inc.
c/o Northwest Registered Agent LLC
7901 4th St N, Suite 300
St. Petersburg, FL 33702
Phone: (305) 845-8520
General inquiries: info@relvema.com
Legal notices: legal@relvema.com

16. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. To request to review, update, or delete your personal information, please visit: https://relvema.com/contact