Privacy Policy

Todai Health, Inc. ("Todai Health," "we," "us," or "our") values your privacy. This Privacy Policy explains how we collect, use, disclose, and protect information when you visit our website, apply for or participate in beta programs, create an account, engage with Care Mentors, use platform features, connect optional tools or devices, or otherwise interact with our services.

Todai Health provides peer support, educational tools, and self-management support, and is not a medical provider, telehealth provider, therapy service, emergency service, or substitute for professional medical care.

By using Todai Health's website or services, you acknowledge that you have read this Privacy Policy. If you do not agree with this Privacy Policy, do not use the services.

We collect information you provide directly, information collected automatically when you use the website or platform, and information from third parties you choose to connect or that help operate the services. Our Terms state that Todai Health handles sensitive health-adjacent information and aims to collect only what is needed, protect it carefully, and be transparent about how it is used.

Information you provide

We may collect:

• Contact information, such as your name, email address, phone number, and mailing address.
• Account and profile information, including login credentials, role information, eligibility details, and verification information.
• Beta, onboarding, and application information, including information you submit when applying for a beta program or joining as a Member or Care Mentor.
• Communications and user content, such as messages, journal entries, feedback, support requests, notes, survey responses, audio, video, images, and other information you share through the services.
• Health-related or wellness information you choose to provide, such as information about your diabetes experience, routines, symptoms, goals, self-management activities, mood check-ins, medication reminders, device connections, and similar information used to support the platform's peer-support and self-management features.
• Payment or payout information, if paid services or paid mentor arrangements are offered in the future.

Information collected automatically

We may automatically collect:

• Device, browser, and operating system information.
• IP address and approximate location information.
• Usage logs, interaction data, and diagnostics.
• Cookie, local storage, and similar technology data.
• Information about how you access and use the website and services.

Information from third parties

We may receive information from:

• Service providers that support hosting, communications, video, analytics, scheduling, payments, security, and infrastructure.
• Partner organizations that refer users or support beta recruitment under separate arrangements.
• Optional third-party integrations, such as device platforms, health platforms, calendar tools, or similar services you choose to connect.

We use personal information to provide, operate, maintain, secure, and improve the services. Our Terms also say Todai Health may host, store, process, transmit, display, analyze, summarize, and use user content as needed to provide and operate the services, support Member–Care Mentor interactions, maintain safety and quality, respond to support requests, comply with law, and improve the services subject to applicable privacy and consent restrictions.

We may use information to:

• Create and manage accounts and user profiles.
• Review eligibility, identity, and role verification where needed.
• Facilitate peer-support interactions, educational tools, and self-management features.
• Send service-related messages, updates, reminders, notices, and support communications.
• Support safety, quality review, policy enforcement, and misuse prevention.
• Analyze performance, troubleshoot issues, and improve product design and operations.
• Conduct surveys, product feedback, usability work, and research activities, including cases where separate consent is required.
• Comply with legal obligations and enforce agreements.

Todai Health is not a medical provider, and our Terms describe the services as peer support, educational tools, and self-management support rather than diagnosis, treatment, clinical monitoring, or medical decision-making. In many cases, that means information collected through the website or platform may not be protected health information governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

However, Todai Health may work with partners, service providers, or programs that involve health-related data and legal obligations that overlap with or resemble HIPAA-style safeguards. When Todai Health is acting on behalf of a covered entity or business associate, or when HIPAA otherwise applies to a specific program or relationship, Todai Health will handle applicable protected health information in accordance with those legal obligations and any additional notices or authorizations provided for that program.

Unless Todai Health specifically states otherwise in a separate notice, authorization, or agreement, this Privacy Policy applies to information collected through the public website, beta platform, peer-support services, and related tools. Users should not assume that all information submitted to Todai Health is subject to HIPAA merely because it relates to health, wellness, diabetes, or self-management.

Todai Health may use AI-assisted tools to support session preparation, mentor prompts, safety signals, summaries, content organization, quality review, and operational workflows, but our Terms state these tools do not make medical decisions, provide medical advice, or replace human judgment or a care team.

Todai Health may also support video, audio, chat, notes, transcripts, and session summaries. If audio or video sessions are recorded, transcribed, or used for AI-assisted summaries or safety review, our Terms state that notice and consent will be provided where required by law and policy.

Session summaries are educational and continuity tools, not medical records, clinical documentation, diagnoses, or treatment plans.

Todai Health may offer self-management tools such as mood check-ins, dashboards, medication reminders, journal entries, health status tracking, content recommendations, or optional connected device features. Our Terms state that connected device or wearable integrations are optional, user-controlled, and may depend on third-party permissions and functionality, and that resulting data may be incomplete, delayed, or inaccurate.

Third-party services linked to or integrated with Todai Health are governed by their own terms and privacy practices.

Our Terms state that Todai Health does not sell Member health data. Todai Health may share information in limited circumstances, including:

• With service providers, contractors, and vendors that help operate the services.
• Between Members and Care Mentors as needed to provide the relevant service experience.
• With partner organizations where appropriate, authorized, and consistent with program terms or consent.
• To comply with law, legal process, safety obligations, or to protect rights, users, or the integrity of the services.
• In connection with a merger, acquisition, financing, reorganization, or similar business transaction, subject to appropriate protections.
• With your consent or at your direction.

We do not sell personal information in exchange for money. We also do not sell Member health data.

Todai Health may use cookies, pixels, local storage, analytics tools, and similar technologies to operate the website, remember preferences, understand usage, improve performance, and support analytics. Our Terms expressly contemplate the use of analytics tools and other third-party services in operating the platform.

Depending on your location, you may be able to manage certain cookie settings through your browser or through tools made available on the site.

Todai Health retains personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide services, maintain safety and quality records, comply with legal obligations, resolve disputes, and enforce agreements. Our Terms state that account deletion and data deletion rights are governed by the Privacy Policy and applicable law.

Retention periods may vary based on the type of information, the nature of a beta or research activity, operational needs, safety considerations, and legal requirements.

Todai Health uses reasonable administrative, technical, and organizational safeguards designed to protect personal information. Our Terms also require users to protect account credentials and acknowledge that the services are not guaranteed to be uninterrupted, error-free, secure, or free from data loss.

No method of transmission over the internet or electronic storage is completely secure, so absolute security cannot be guaranteed.

Depending on where you live, you may have rights to request access to, correction of, deletion of, or a copy of certain personal information, or to object to or limit certain processing. You may also have the right to withdraw consent for optional processing where consent is the basis for collection or use.

To make a privacy request, contact privacy@todaihealth.com. Todai Health may need to verify your identity before processing certain requests.

If you are a California resident, California law may provide additional rights regarding personal information, including the right to know the categories of personal information collected, the categories of sources, the business or commercial purposes for collection, the categories of third parties to whom personal information is disclosed, and the right to request deletion or correction, subject to legal exceptions.

California residents may also have the right to request access to specific pieces of personal information, the right to limit the use or disclosure of certain sensitive personal information in some contexts, and the right not to receive discriminatory treatment for exercising applicable privacy rights.

Todai Health's current Terms indicate that the platform may collect identifiers, account information, communications, user content, health-related or wellness information you choose to provide, device and usage data, application and eligibility information, and information from connected third-party services or partners depending on how you use the services. Todai Health uses that information to operate the services, support Member and Care Mentor interactions, maintain safety and quality, improve the product, respond to support requests, conduct feedback or research activities, and comply with law.

Todai Health does not sell Member health data. Todai Health also does not knowingly use or disclose sensitive personal information for purposes that would require a separate California right to limit beyond the uses necessary to provide requested services, maintain the platform, help ensure security and integrity, perform analytics, detect misuse, or comply with legal obligations.

California residents may submit requests by emailing privacy@todaihealth.com. An authorized agent may submit a request on a resident's behalf where permitted by law, subject to identity and authorization verification.

Our Terms state that current beta participation is intended for adults age 18 or older, or the age of legal majority in the relevant jurisdiction, whichever is higher. Todai Health does not intend the services for children and does not knowingly collect personal information from children through the services.

Our Terms state that Todai Health may invite Members, Care Mentors, or partners to participate in surveys, usability sessions, interviews, beta feedback, or research-related activities, and that participation is voluntary unless a specific beta activity clearly requires feedback as part of participation. Research activities beyond normal product feedback may require separate consent.

Additional notices, recording disclosures, beta terms, device notices, or consent forms may supplement this Privacy Policy in specific contexts.

Todai Health may use service providers, contractors, affiliates, or infrastructure that process information in different jurisdictions, consistent with our Terms' description of affiliates, contractors, service providers, agents, and third-party services supporting the platform. If information is transferred across borders, Todai Health will take steps required by applicable law.

Todai Health may update this Privacy Policy from time to time. Our Terms state that material changes may be communicated through the services, by email, or by another reasonable method, and that the last updated date indicates when revisions were made.

For general questions, contact hello@todaihealth.com. For privacy questions or data requests, contact privacy@todaihealth.com. For partnership questions, contact partnerships@todaihealth.com.