Nebbi Consumer Health Data Privacy Policy

Effective Date: September 28, 2026

This Consumer Health Data Privacy Policy (“Health Data Policy”) describes how Nebbi, Inc. (“Nebbi,” “we,” “us,” or “our”) collects, uses, shares, and protects consumer health data. It supplements the Nebbi Privacy Policy.

Nebbi is a wellness application. Nebbi is not a healthcare provider and does not provide medical, psychiatric, psychological, or therapeutic services.

1. Consumer Health Data We Collect

Depending on how you use Nebbi, information you voluntarily provide through the App may be considered consumer health data under applicable law. This may include:

• Mood and emotion selections.
• Emotional check-ins.
• Journal and reflection entries.
• Information about experiences, situations, or triggers associated with your emotions or well-being.
• Wellness patterns and information derived from your use of these features.
• Household, family, or personal circumstances that you voluntarily provide in connection with your wellness experience.

Nebbi may generate patterns, insights, or recommendations based on information you record. Nebbi does not diagnose medical or mental health conditions based on this information.

2. Sources of Consumer Health Data

We collect consumer health data primarily directly from you when you voluntarily enter information into Nebbi, including when you complete an emotional check-in, track a mood, complete a journal or reflection entry, or otherwise interact with wellness features in the App.

We may receive limited account or eligibility information from an organization sponsoring your access to Nebbi. Sponsoring organizations do not provide Nebbi with your personal mood logs, emotional check-ins, journal entries, or similar wellness information.

3. How We Use Consumer Health Data

We use consumer health data as reasonably necessary to provide the features you request and operate Nebbi, including:

• Recording and displaying your emotional and wellness information.

• Helping you identify patterns in information you have recorded.

• Providing personalized content, insights, or recommendations.

• Maintaining and improving Nebbi’s wellness features.

• Supporting the security and integrity of the App.

• Generating anonymous or aggregated group-level insights and reporting.

• Complying with applicable legal requirements.

Nebbi does not use consumer health data to make medical diagnoses or treatment decisions.

4. Organization-Sponsored Programs

If your access to Nebbi is provided or sponsored by an employer, educational institution, athletic organization, nonprofit, or other organization, your individual wellness information remains private from that sponsoring organization.

A sponsoring organization may receive anonymous or aggregated group reports about participation, engagement, patterns, or program outcomes. These reports may include group-level participation or engagement information, aggregated patterns, general insights, and recommendations.

Nebbi does not provide sponsoring organizations with an individual participant’s mood logs, emotional check-ins, journal or reflection entries, wellness history, or individual emotional profile unless that individual specifically directs or authorizes Nebbi to do so or disclosure is required by law.

5. Sharing and Processing of Consumer Health Data

Nebbi does not sell consumer health data.

Nebbi uses service providers to help operate, maintain, secure, and improve the App. Depending on the services they provide, these providers may process information associated with your use of Nebbi, including consumer health data where necessary to provide their services to Nebbi.

These service providers include providers of cloud hosting and infrastructure, product analytics, crash and error monitoring, communications, push notifications, subscription management, and other technology services.

Nebbi requires service providers to appropriately protect information they process on our behalf and to process it only as necessary to provide their services.

We may also disclose consumer health data when you specifically direct or authorize us to do so, when required by applicable law or valid legal process, or when reasonably necessary to protect the rights, safety, or security of Nebbi, our users, or others.

Nebbi does not provide individual consumer health data to an organization sponsoring a user’s access to Nebbi except as described in Section 4.

6. Data Storage and Security

Consumer health data is stored using Nebbi’s cloud infrastructure, primarily through Google Cloud Platform systems located in the United States.

Nebbi uses commercially reasonable administrative, technical, and organizational safeguards designed to protect consumer health data, including encryption of information at rest and in transit. No electronic storage or transmission method can be guaranteed to be completely secure.

7. Retention and Deletion

You may delete your Nebbi account through the App. Account deletion removes your login and identifying details from Nebbi’s primary database. Certain wellness information, including mood logs, journal entries, or similar content, may remain in de-identified form after account deletion.

Deleted identifying information may remain temporarily in encrypted system backups. Nebbi’s current primary database backup retention period is seven days. Backups are maintained for disaster recovery purposes and are not routinely accessed or restored.

Certain information may also remain temporarily with Nebbi’s service providers according to their applicable retention practices. Some provider records may remain associated with anonymous or system-generated identifiers until deletion is specifically requested.

You may request complete erasure by contacting support@nebbi.io. Nebbi will process a valid deletion request in accordance with applicable law. Where required, Nebbi will also notify applicable service providers, processors, contractors, or other parties that received the consumer health data of the deletion request. Information stored in archived or backup systems may remain until it is deleted through Nebbi’s normal backup retention process or within the period permitted by applicable law.

8. Your Consumer Health Data Rights

Depending on where you live and applicable law, you may have rights concerning your consumer health data, including the right to:

• Confirm whether Nebbi collects, shares, or otherwise processes your consumer health data.
• Access consumer health data associated with you.
• Request deletion of your consumer health data.
• Withdraw consent for certain collection or sharing where applicable.
• Obtain information about the categories of consumer health data we collect, the sources from which it is collected, the purposes for which it is collected or shared, and categories of third parties or service providers with whom it is shared.
• Exercise other rights available under applicable consumer health privacy laws.

To exercise these rights, contact support@nebbi.io. We may need to verify your identity before completing certain requests.

If applicable law provides a right to appeal our decision regarding a privacy request, you may submit an appeal by contacting support@nebbi.io and identifying the request you would like us to reconsider.

Nebbi will not discriminate against you for exercising applicable consumer health privacy rights.

9. Your Choices and Consent

You choose whether to provide emotional and wellness information through Nebbi’s check-in, mood tracking, journaling, reflection, and related features. Nebbi collects and uses this information to provide the features you request.

Where applicable law requires additional consent for a particular collection, use, or disclosure of consumer health data, Nebbi will obtain that consent before engaging in that activity.

You may withdraw consent where permitted by applicable law by contacting support@nebbi.io. Withdrawal of consent does not affect processing that occurred before the withdrawal and may affect Nebbi’s ability to provide certain features.

10. Changes to This Health Data Policy

We may update this Consumer Health Data Privacy Policy periodically to reflect changes to our practices, technology, or legal obligations. When we make material changes, we will update the effective date and provide notice through the App or by other reasonable means. We will obtain additional consent where required by applicable law.

11. Contact Us

For questions about this Consumer Health Data Privacy Policy or to exercise your consumer health data rights, contact:

Nebbi, Inc.
10960 Wilshire Blvd, 5TH Floor
Los Angeles, CA 90024
Email: support@nebbi.io