Evobeing Privacy Policy

About This Privacy Policy

Evobeing places a high priority on your privacy and the security of your personal data.

Through smart wearable devices, mobile applications, and related services, our products help you understand information related to sleep, recovery, stress, activity, and your daily physical status.

We understand that data related to physical status and health is highly private. Accordingly, this Privacy Policy is intended to explain:

• What personal data we collect;
• Why we process this data;
• How we use, share, and protect this data;
• How you can manage your data and privacy rights.

This Privacy Policy applies to personal data processing activities conducted by evobeing LLC (“Evobeing,” “we,” or “our”) when you use the following services:

• Evobeing Ring;
• Evobeing App;
• The official Evobeing website;
• Software, services, and related products provided by Evobeing.

The above products and services are collectively referred to below as the “Evobeing Services” or “Services.”

This Privacy Policy does not apply to websites, applications, platforms, or services operated by independent third parties.

A third party's processing of your personal data is governed by its own privacy policy and related terms.

We process your personal data only to the extent reasonably necessary to provide, maintain, secure, and improve the Evobeing Services. When providing artificial intelligence-assisted features, we may use data you authorize, historical usage information, and relevant health and physical and mental status data to generate personalized insights and recommendations. We do not use your personal health data to train general-purpose artificial intelligence models made available to the public.

We solemnly commit that we:

• Do not sell your personal data;
• Do not sell your personal health data or Consumer Health Data;
• Do not use your health and physical and mental status data for third-party targeted advertising or data brokerage activities.

Why We Process Your Personal Data

When you use the Evobeing Services, we may process your personal data for the following purposes.

We process necessary data to:

• Create, verify, and manage your account;
• Pair, connect, and manage an Evobeing Ring;
• Synchronize data between the Evobeing Ring and Evobeing App;
• Calculate and display sleep, recovery, stress, activity, and other health and physical and mental status information;
• Establish your personal baseline;
• Help you understand your current physical status and long-term trends;
• Provide personalized insights, recommendations, and other intelligent features;
• Save information that you actively record;
• Provide account, device, and customer support services.

Providing a Personalized Experience

We may combine your physical data, historical information, personal preferences, and content you actively provide to offer more relevant interpretations of your health and physical and mental status, trend analysis, and personalized recommendations.

For example, we may combine your recent sleep, recovery, stress, activity, and personal historical baseline to help you understand your current physical status.

Protecting Account and Service Security

We may process account, device, and technical information for identity verification, preventing unauthorized access and abuse, troubleshooting device connection or data synchronization issues, and maintaining the security and stability of accounts and systems.

Improving Products and Services

We may analyze usage, performance, diagnostic information, and error information from the Evobeing App and Evobeing Ring to improve the application, smart ring, data algorithms and calculation results, personalized features, device connectivity and data synchronization, and the overall product experience.

Where reasonably practicable, we will prioritize the use of aggregated, pseudonymized, de-identified, or anonymized data for analysis.

Communicating with You

We may send you necessary information related to account verification, security, Evobeing Ring status, privacy requests, Service changes, and policy updates.

If you choose to receive marketing information, we will provide an appropriate way to unsubscribe in accordance with applicable law.

Complying with Legal Obligations

Where necessary, we may process your personal data to comply with applicable legal requirements, address valid judicial or regulatory requests, resolve disputes, and protect lawful rights and interests.

Legal Bases for Processing Personal Data

If applicable law requires us to explain the legal basis for processing personal data, depending on the circumstances, we may rely on:

• Performance of a contract. Where processing the relevant data is necessary to provide you with the Evobeing Services, such as account management, Evobeing Ring data synchronization, or membership service management.
• Your consent. For processing that legally requires consent, such as certain health data, system permissions, third-party health platform connections, or other optional features.
• Legitimate interests. Where permitted by law, we may process necessary data based on legitimate interests such as maintaining Service security, providing customer support, preventing fraud, and reasonably improving products.
• Legal obligations. For example, fulfilling tax, accounting, consumer protection, or other applicable legal responsibilities.

Some physical and health-related data may constitute Sensitive Personal Data or Special Categories of Personal Data. Where required by applicable law, we will obtain your explicit consent or process the data based on other applicable legal conditions.

Personal Data We Process and Its Sources

The data we process depends on the Evobeing products and features you use and the permissions you grant.

Account and Profile

When you create and use an Evobeing account, we may process:

• Email address;
• User ID or account ID;
• Login and authentication information;
• Country or region;
• Language and time zone;
• Age or date of birth;
• Height and weight;
• Nickname;
• Goals and preferences;
• Other profile information that you actively provide.

You primarily provide this information when registering an account, setting up a profile, or using relevant features.

Evobeing Ring, Wellness Data, and Physical Status Information

When you wear and use an Evobeing Ring, we may process information collected by Ring sensors or calculated from sensor data, such as:

• Heart Rate;
• Resting Heart Rate;
• Heart Rate Variability (HRV);
• Sleep timing, sleep duration, and sleep stages;
• Steps, activity levels, and exercise-related data;
• Skin temperature trends;
• Other Wellness Signals supported by the Evobeing Ring.

To provide relevant features and generate analysis results, we may also process necessary raw sensor data, wearing status, signal quality, measurement timing information, and device information related to measurements.

Based on the above data, we may calculate or generate information related to Wellness management, such as sleep analysis, recovery status, stress trends, personal baselines, physical status scores, trend analysis, Insights, and personalized recommendations.

Some of this data may directly or indirectly reflect your physical status or health-related information. Accordingly, under applicable laws in your country or region, this data may be considered Health Data, Sensitive Personal Data, Special Categories of Personal Data, or Consumer Health Data.

Information You Actively Provide

When you use recording, feedback, personalization, or other interactive features, you may actively provide Evobeing with:

• Daily records;
• Notes and tags;
• Physical sensations;
• Goals and preferences;
• Feedback;
• Text you enter in interactive features;
• Communications with customer support.

Content you actively enter may contain health or other sensitive information. Please provide only information necessary to use the relevant feature.

Device and Technical Information

When you use an Evobeing Ring, the Evobeing App, or the website, we may automatically collect technical information related to your device and use of the Services, such as:

• Device and Evobeing Ring identification information;
• Application, firmware, and operating system information;
• Device connection and synchronization information;
• IP address and network information;
• Diagnostic, error, and performance information.

This data is primarily used to connect and manage devices, provide and maintain the Services, troubleshoot technical issues, and protect account and system security.

Data from Third-Party Sources

If you choose to connect Evobeing with Apple Health, we may obtain and process relevant data within the scope of your authorization and use it only to provide you with corresponding health and physical and mental status features.

You may view, change, or withdraw relevant permissions at any time through Evobeing or your device's system settings. After withdrawal, we will no longer obtain new data through the third-party service.

Health and fitness data obtained through Apple Health / HealthKit will not be used for third-party advertising, marketing, or data brokerage activities. We do not sell, rent, or share data obtained through Apple Health / HealthKit for advertising purposes. We will share data obtained through Apple Health / HealthKit only where we have obtained your corresponding authorization and applicable requirements are satisfied.

How We Share Your Personal Data

To provide, maintain, and improve the Evobeing Services, we may share personal data necessary to complete the relevant services with authorized third-party service providers, including, but not limited to:

• Cloud storage and infrastructure service providers;
• Account verification and identity management service providers;
• Data processing, analysis, and artificial intelligence and machine learning technology service providers used to support Evobeing features;
• Customer support service providers.

We share relevant personal data only to the extent necessary to achieve a specific service purpose and require the relevant service providers to:

• Process personal data only according to our instructions and for the agreed purposes;
• Implement appropriate security and privacy safeguards;
• Comply with applicable data protection legal requirements.

Evobeing does not sell your personal data and does not share your health or Wellness data with third parties for third-party targeted advertising or data brokerage activities.

With Your Authorization or at Your Direction

If you actively:

• Connect a third-party service;
• Use a data export feature;
• Ask us to provide data to a third party;

we may share relevant information based on your authorization or direction.

For example, when you connect Apple Health, we access or share relevant data only within the scope you authorize.

Legal and Security Requirements

Where required by law or reasonably necessary, we may disclose relevant personal data to:

• Comply with applicable laws, regulations, or legal processes;
• Respond to valid requests from courts, regulatory authorities, or law enforcement agencies;
• Investigate or prevent fraud, security risks, or unlawful activities;
• Protect the lawful rights, safety, and property of Evobeing, users, or other individuals.

Corporate Transactions

If Evobeing undergoes a merger, acquisition, financing, restructuring, asset sale, or other similar business transaction, personal data related to the relevant business may be lawfully transferred to relevant parties as a transaction asset.

Where required by applicable law, we will take reasonable measures to notify you of the relevant changes.

International Data Transfers

Because Evobeing may use service providers located in different countries or regions, your personal data may be stored or processed outside your country or region.

Regardless of where data is processed, we will implement corresponding safeguards in accordance with applicable data protection laws.

For users in the European Economic Area and the United Kingdom, when a cross-border data transfer occurs, we will use an adequacy decision, Standard Contractual Clauses, or another lawful data transfer mechanism in accordance with applicable law.

For users in Japan, we will process cross-border data transfers in accordance with applicable requirements of Japan's Act on the Protection of Personal Information (APPI).

Data Security and Retention

Data Security

Based on the nature and sensitivity of personal data, we implement reasonable technical and organizational measures to protect your data, including encryption during transmission and storage, access controls, security monitoring, and other necessary security measures.

Only employees, contractors, and service providers for whom access to the relevant personal data is genuinely necessary to provide the Services or perform relevant duties may access such data.

We also continuously maintain the security of the Evobeing App, Evobeing Ring firmware, and related Services and recommend that you promptly update to the latest versions.

Although we take reasonable measures to protect your data, no information system can guarantee absolute security. If a data security incident occurs for which applicable law requires notification, we will take corresponding measures in accordance with law.

Data Retention

We retain your personal data only for the period reasonably necessary to provide the Evobeing Services, achieve the purposes described in this Privacy Policy, protect account and Service security, or comply with legal obligations.

Generally, account information, Evobeing Ring data, health and physical and mental status data, and content you actively provide will be retained for the duration of your account or the period necessary for the relevant feature. Transaction, security, and diagnostic records may be retained for a longer period based on legal, security, fraud prevention, or financial requirements.

When relevant data is no longer needed, we will delete or de-identify it in accordance with law, except where continued retention is required or permitted by law.

Due to the operating mechanisms of backup systems, deleted data may continue to exist in backups for a limited period and will be deleted or overwritten according to the normal backup cycle.

Your Data and Privacy Rights

Depending on the laws of your country or region, you may have all or some of the following rights:

• To know whether we process your personal data;
• To access your personal data;
• To obtain a copy of your personal data;
• To correct inaccurate or incomplete data;
• To request deletion of personal data;
• To request data portability;
• To withdraw consent;
• To request restriction of certain processing;
• To object to certain data processing;
• To appeal the outcome of certain privacy requests.

You may use the data and privacy management features currently provided in the product through Evobeing App → Profile → Privacy & Data.

You may also submit a relevant request to us at dataprotection@evobeing.com.

To protect your account and personal data, we may need to verify your identity before processing an access, export, correction, or deletion request.

Withdrawal of consent will not affect data processing lawfully conducted before the withdrawal.

If a Service needs to use data you have deleted or for which you have withdrawn authorization, the relevant feature may no longer function properly.

Deleting Data and Accounts

You may manage and delete certain personal data using features provided by Evobeing.

Deleting individual data, withdrawing device permissions, unpairing a Ring, and deleting an entire Evobeing account are separate operations.

Deleting Data

Where supported by the relevant feature, you may delete records, historical content, or other manageable data that you actively created within the Evobeing App.

Withdrawing Permissions

You may withdraw Bluetooth, Notifications, Apple Health, or other permissions through your device's system settings.

Withdrawing a permission will generally stop future data collection but will not automatically delete data lawfully obtained before the withdrawal.

Unpairing an Evobeing Ring

Unpairing an Evobeing Ring from your account is not the same as deleting your Evobeing account and will not automatically delete historical health and physical and mental status data already stored in the account.

Deleting an Evobeing Account

You may initiate account deletion through Evobeing App → Profile → Account Management → Delete Account.

After account deletion, we will delete or de-identify personal data associated with the account in accordance with applicable law, except for limited data that the law requires or permits us to continue retaining, such as records related to tax, accounting, security, fraud prevention, or legal claims.

If account deletion requires processing time, we will explain the relevant process to you.

Supplemental Terms for Specific Countries and Regions

Depending on your country or region, applicable law may grant you additional privacy rights. The following supplements this Privacy Policy. In the event of a conflict with applicable local law, the requirements of applicable law will prevail.

European Economic Area, United Kingdom, and Switzerland

If the GDPR, UK GDPR, or other applicable data protection laws apply to your personal data, we will process relevant data based on an appropriate legal basis, such as performance of a contract, your consent, legitimate interests, or legal obligations.

Some physical and health-related data may constitute Special Categories of Personal Data. Where required by applicable law, we will obtain your explicit consent or use another lawful basis for processing and implement corresponding safeguards.

Under applicable law, you may have the right to access, correct, delete, or obtain your personal data, restrict or object to certain data processing, withdraw consent, and request data portability.

You also have the right to lodge a complaint with a data protection supervisory authority that has jurisdiction.

United States

If applicable U.S. state privacy laws apply to your personal data, including, but not limited to:

• The California Consumer Privacy Act (CCPA, as amended by the California Privacy Rights Act, CPRA);
• The Washington My Health My Data Act;
• Other applicable consumer privacy or health data protection laws;

you may have the following rights under applicable law:

• To request access to your personal data;
• To request a copy of your personal data;
• To request deletion of your personal data;
• To request correction of inaccurate personal data;
• To request restriction of or refusal to permit certain processing of Sensitive Personal Data;
• To know about the collection, use, sharing, and disclosure of personal data;
• To appeal a decision denying certain privacy requests.

Evobeing does not sell your personal data.

Evobeing does not sell Consumer Health Data and does not use Consumer Health Data for third-party targeted advertising, cross-context advertising tracking, or data brokerage activities.

For regions where applicable law requires a Consumer Health Data Privacy Notice, please refer to:

Evobeing Consumer Health Data Privacy Notice

Japan

If Japan's Act on the Protection of Personal Information (APPI) applies to your personal information, we will process relevant data in accordance with this Privacy Policy and applicable APPI requirements.

For information that legally requires special protection, we will implement corresponding safeguards in accordance with applicable requirements and obtain your consent where necessary.

If your personal data is processed across borders or provided to a third party outside Japan, we will take necessary measures in accordance with applicable APPI requirements.

Under applicable law, you may have the right to request disclosure, correction, deletion, cessation of use, or cessation of provision of your personal data to third parties.

Children's Privacy

The Evobeing Services are not directed to children who have not reached the minimum age for use specified by applicable law in their country or region.

If we discover that a child has provided personal data to us without appropriate authorization, we will take reasonable measures to delete or otherwise process the relevant information in accordance with applicable law.

If you believe that a child may have provided personal data to Evobeing, please contact us at dataprotection@evobeing.com.

Cookies and Similar Technologies

When you visit the official Evobeing website, we may use Cookies and similar technologies to provide website functionality, protect security, save your settings, and understand website usage.

For non-essential Cookies that legally require consent, we will obtain your consent before use and provide an appropriate way to manage them.

Updates to This Privacy Policy

We may update this Privacy Policy due to changes in products and Services, data processing methods, third-party service providers, security measures, or legal requirements.

If this Policy is updated, we will revise the “Last Updated” date at the top of the page.

If an update will have a material impact on your privacy rights or the processing of Sensitive Personal Data, we will notify you by in-app notification, email, website notice, or other appropriate means in accordance with applicable law.

If a new data processing activity legally requires new consent, we will obtain your consent before the relevant processing begins.

Contact Us

If you have questions about this Privacy Policy or how Evobeing processes your personal data, or if you wish to exercise your privacy rights, please contact us as follows:

Data Controller
Evobeing LLC

Registered Address
45 E LOUCKS ST, 2ND FLOOR SHERIDAN, WY 82801, United States

Privacy Contact Email
dataprotection@evobeing.com

We will process your request in accordance with applicable data protection laws.

Where applicable law grants you the relevant right, you may also lodge a complaint with a data protection authority or privacy regulator that has jurisdiction.