Sweetmyo Core Privacy Policy

📄 Version: v2.0.0 📅 Effective Date: September 16, 2025

Privacy & Biometric Data Policy

Scope

This Annex explains the collection and processing of Training Data and Biometric Data generated by the Hub1 Terminal, Training Suit, and Sweetmyo App.

Categories of Data

  • • Account & Device Data: account ID, device IDs, firmware/app versions.
  • • Training Data: session duration, program selection, stimulation levels, electrode contact and connectivity status.
  • • Biometric Data: physiological responses and muscle activation signals used to personalize training; categories may include, but are limited to, activation patterns and current acceptance indicators.

Purposes of Processing

Provide and secure core functionality; monitor safety and performance; enable AI‑driven personalization; support product improvement and research using de‑identified or aggregated data.

Legal Bases & Consent

Processing is based on your consent and our legitimate interests in providing secure, high‑quality services. Where required (e.g., GDPR special category data), we will obtain explicit consent.

Sharing & International Transfers

We share data with service providers (e.g., cloud hosting, analytics, customer support) under appropriate contractual safeguards. International transfers use mechanisms such as Standard Contractual Clauses or their successors, as applicable.

Security

Data is encrypted in transit and at rest; access is role‑based and logged; controls are reviewed periodically.

Retention & Deletion

We retain personal data only as long as necessary for the purposes described or as required by law. De‑identified data may be retained for product improvement and research. You may request deletion subject to legal and safety constraints.

Your Rights

You may request access, correction, restriction, portability, or deletion of your personal data, and may withdraw consent at any time by contacting support@sweetmyo.com.

Children

Sweetmyo is intended for adult users. We do not knowingly collect personal data from children.

Regulatory Compliance & Legal Terms

Current Compliance (Consumer Electronics)

Sweetmyo Hub1 is marketed as a consumer electronic wellness training device and is fully compliant today under applicable consumer electronics frameworks. Applicable conformity may include FCC Part 15, CE marking, WEEE for e‑waste, and relevant safety/EMC requirements. No medical claims are made at this time.

Future Regulatory Roadmap

Sweetmyo intends to pursue additional regulatory clearances and approvals that may include FDA Class II (USA), EU MDR/CE (EU), UKCA/MHRA (UK), and NMPA (China). When such approvals are obtained, additional obligations (e.g., labeling, vigilance, UDI where required, quality system elements) will apply and will be reflected in updated documentation. Our current compliance under consumer frameworks remains in force during this pursuit.

Subscriptions & Pricing

Subscriptions renew automatically unless cancelled at least 24 hours before renewal. Pricing may change with at least 30 days' advance notice; continued use after the effective date constitutes acceptance. No refunds are provided for termination due to breach or misuse.

Warranty & Service (IFU‑Aligned)

Hub1 Terminal warranty is one (1) year from original purchase; free repairs are provided within scope. Out‑of‑warranty service is available at cost. The warranty excludes damage from misuse, unauthorized repair, or failure to follow IFU instructions.

Export Controls & Sanctions

You represent that you are not subject to sanctions and will not export or re‑export Sweetmyo products in violation of applicable export control laws.

Governing Law; Arbitration; Class Waiver

Delaware law governs. Disputes are resolved by binding arbitration under AAA Rules. Class or representative actions are waived. You may opt out of arbitration within 30 days of account creation by emailing support@sweetmyo.com.

Survival

Intellectual Property, Subscriptions & Pricing, Warranty & Service, Export Controls, Limitation of Liability, and Dispute Resolution provisions survive termination.