Privacy Policy

PRIVACY POLICY

Last Updated: March 27, 2026

BeSwell24, Corp. ("BeSwell 24", “Company”, "we", "our", or "us") respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (this “Policy”). This Policy describes how we collect, process, retain, and disclose personal information when you access or use our websites, purchase products, enroll in subscription plans, complete assessments, interact with digital tools, or use any related features (collectively, the “Services”) and our practices for using, maintaining, protecting, and disclosing that information.

This Policy applies only to Personal Data we collect:

1. Through the Services.
2. In communications, including email, text, chat, and other electronic messages, between you and the Services.
3. In related offline interactions with us that are directly connected to the Services including phone communications, mailed correspondence, events, or other communications related to our offerings.

This Privacy Policy does not apply to:

1. Information collected through websites, applications, or services that do not link to this Policy; or
2. Information collected by third parties that operate independently of us, including device manufacturers or third-party applications, even if linked to or accessible from the Services.

We may provide additional or different policies that are specific to certain features, or services, which will supplement this Privacy Policy.

Please read this Policy carefully to understand our practices regarding your information and how we treat it. Where required by applicable law, we will obtain your consent before collecting or processing certain categories of personal data. This policy may change from time to time (see Changes to Our Privacy Policy).

Children's and Minors' Data. Our Services are not intended for, and we do not knowingly collect any personal data from, children under the age of 13. If we learn we have collected or received personal data from a child under 13 years old without verification of parental consent, we will delete that information.

The ability to purchase products, enroll in Subscription Plans or otherwise enter into binding agreements through the Services is limited to individuals who meet the age and eligibility requirements set forth in our Terms and Conditions, including applicable minimum age requirements. (See Terms and Conditions for the Online Sale of Products and Services).

The Personal Data That We Collect or Process

"Personal Data" is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, or billing and transaction information, or any other identifier we may use to contact you online or offline.

The types and categories of Personal Data we may collect or process include:

1. Account and contact information, including name, address (such as home address, work address, or other address), email address, phone number, username, and other contact information you provide us.
2. Billing and transaction information, including limited payment-related details necessary to process transactions (such as billing name, billing address, transaction identifiers, and payment status). Payment card information is processed securely by third-party payment processors, and we do not store full credit or debit card numbers.
3. Account history, including information about your subscription, account, transactions, purchases, order history, or discounts.
4. Limited demographic or eligibility information, such as age or confirmation of eligibility to use the Services or enter into transactions, if and when required for account creation, legal compliance, fraud prevention, or to enable specific features or transactions.
5. Functional, wellness, and accessibility information (non-medical) that you voluntarily provide, such as information about home environment needs, mobility or dexterity considerations, vision or hearing preferences, daily routines, caregiver relationships, or use of assistive technologies. This information is used solely to craft product recommendations and is not medical or clinical data. Assessment responses and related inputs are used to generate product recommendations. These recommendations are informational only and are not medical advice, diagnoses, treatment recommendations, or eligibility determinations.
6. Location information, including general geographic location such as country, state or province, or city.
7. Device information, including your IP address, device identifiers, operating system and version, preferred language, hardware identifiers, browser type and settings, and other device information.
8. Content and information you elect to provide through your account, in reviews, or through emails, chats, or other communications sent to us.

Certain information described above may be considered “sensitive” under applicable privacy laws. Where required by law, we will collect and use such information only as permitted and for limited purposes, such as providing requested Services or complying with legal obligations. If you choose not to provide certain information, some features or Services may not be available.

We also collect:

1. Statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person. We may generate aggregated or de-identified data based on information collected through the Services for operational, analytical, and service-improvement purposes. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature.
2. Technical information. Technical information includes information about your internet connection and usage details about your interactions with the Services, collected for purposes such as operating the Services, maintaining security, troubleshooting, analytics, and improving performance and functionality. This may include clickstream information to, through, and from the Services (including date and time), products that you view or search for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from a page.

If we combine or connect aggregated, de-identified, or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information in accordance with this Policy.

How We Collect Your Personal and Other Data

You Provide Information to Us

We collect personal data about you when you interact with our Services, such as when you create or update an account, place an order, complete an assessment, subscribe, make a purchase or submit a request, or create, upload, or post content to the Services. Where required by applicable law, we will obtain your consent before collecting or processing certain categories of personal data.

Automatically Through Our Services

As you navigate through and interact with our Services, we may automatically collect certain information using standard data collection technologies. This information may include usage details, IP address, device and browser information, operating system, general location information, and information collected through cookies or similar technologies, to help operate, secure, and improve the Services.

The technologies we use for this automatic data collection may include standard website technologies such as:

1. Cookies. Cookies are small files placed on your device to enable functionality, preferences, and analytics. You may disable cookies through your browser settings, though some features of the Services may not function properly. For more information, see our Cookie Policy.
2. Web Beacons. Some parts of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, or single-pixel gifs). These technologies are used to understand usage patterns, measure engagement, and help maintain system integrity. For example, web beacons may be used to count users who have visited certain parts of the Services or opened an email, and to compile related usage statistics, such as the popularity of certain content.
3. Third-Party Service Providers. When you interact with the Services, certain third-party service providers may collect information in connection with providing services to us, such as analytics, hosting and infrastructure support, payment processing, and security or fraud-prevention services. These service providers process information solely for purposes related to operating, supporting, securing, or improving the Services, and in accordance with their own privacy policies and applicable law.

From Business Partners and Service Providers

We also may receive limited personal data from business partners or vendors involved in providing or supporting specific products, services, or features offered through the Services, including information used to support functionality, improve service performance, fulfill transactions, or provide customer support, to the extent permitted by applicable law.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal data, to:

1. Provide you with the Services and any contents, features, information or products that we make available through the Services.
2. Fulfill and manage subscriptions, purchases, orders, deliveries, payments, and returns, and exchanges.
3. Fulfill any other purpose for which you provide it.
4. Provide you with notices about your account or subscription, including expiration and renewal notices.
5. Improve our Services, including by analyzing information and creating aggregated data to develop, maintain, analyze, improve, optimize, measure, and report on our Services and how users interact with them.
6. Carry out our legal and compliance obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
7. Notify you about changes to any products or services we offer.
8. Fraud prevention and security.
9. Customer service and communication.
10. For any other purpose with your consent.
11. In any other way we may describe when you provide the information.

The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to:

1. Estimate our audience sizes and usage patterns.
2. Store information about your preferences to help tailor aspects of the Services.
3. Speed up your searches.
4. Recognize you when you return to our Services.

We do not use wellness information for advertising or marketing purposes. We may also use your contact or account information to send you marketing or promotional communications about products, services, or offerings that may be of interest to you. You may opt out of receiving these communications at any time by following the unsubscribe instructions included in the applicable communication or by contacting us at privacy@beswell24.com.

We may use your contact or account information to send you transactional or service-related communications, such as order confirmations, shipping notices, subscription updates, billing notices, or account-related messages that are necessary to provide the Services.

If and when we offer SMS or text message communications, such communications will be subject to your separate, express consent and applicable legal requirements, and additional disclosures will be provided at the time of enrollment. For more information, see the section of this Policy labeled Your Rights and Choices About Your Information.

Who We Disclose Your Information To

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also disclose personal data that we collect, or you provide as described in this Policy:

1. To our subsidiaries and affiliates, if any.
2. To contractors, service providers, and other third parties we use to support our organization and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.
3. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us is among the assets transferred.
4. To fulfill the purpose for which you provide the information.
5. For any other purpose disclosed by us when you provide the information.
6. With your consent.

We may also disclose your personal data:

1. To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
2. To enforce or apply our Website Terms of Use, Terms and Conditions for the Online Sale of Products and Services, Subscription Policy, and other agreements, including for billing and collection purposes.
3. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

The categories of personal data we may disclose include:

1. Account and contact information.
2. Payment information.
3. Account history, including information about your subscription, account, transactions, purchases, order history, or discounts.
4. Demographic information.
5. Location information, including general geographic location.
6. Device information.
7. Content and information you elect to provide to us.
8. Images, voice recordings, and video content, which we may collect, store, or process only if and when you voluntarily use features of the Services that allow you to upload, record, transmit, or otherwise provide such content (for example, submitting reviews with photos, participating in optional support interactions, or enabling future features that support audio or video input). We do not collect images, voice recordings, or video content by default, and such information is collected only with your knowledge and affirmative action.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Advertising, marketing, cookies, and other tracking technologies choices:

1. Advertising. We may send you promotional communications about our products or services, subject to applicable law. You may opt out of receiving promotional communications at any time by following the unsubscribe instructions included in the communication or by contacting privacy@beswell24.com. Opting out of marketing communications does not affect transactional or service-related communications necessary to provide the Services.
2. Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. You may be able to control the use of certain tracking technologies through available opt-out mechanisms, where provided. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the online services you visit indicating you do not wish to be tracked.
3. Promotions by the Company. We may use your information to promote our own products, services, or offerings. You may opt out of receiving promotional communications at any time by following the unsubscribe instructions included in the communication or by contacting privacy@beswell24.com.

Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data, including:

1. Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
2. Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information's nature and processing purpose.
3. Deletion. You may request that we delete personal data about you that we maintain, subject to certain exceptions under applicable law.
4. Opt-Out of Certain Data Uses. To the extent required by applicable state law, you may have the right to opt out of certain uses of personal data, such as targeted advertising, profiling, or “sales” as those terms are defined under applicable law. Please note that BeSwell 24 does not currently engage in targeted advertising or sell personal data.

State Specific Privacy Rights

1. California Privacy Rights (CCPA / CPRA). If you are a California resident, you may have additional rights regarding your personal data under the California Consumer Privacy Act and the California Privacy Rights Act, including the right to:
2. Request access to the personal data we collect about you
3. Request correction of inaccurate personal data
4. Request deletion of personal data, subject to applicable legal exceptions
5. Request data portability
6. Opt out of certain data uses, such as the sale or sharing of personal data or targeted advertising, if applicable, as those terms are defined under applicable law.
7. Privacy Rights in Other U.S. States. Residents of certain U.S. states, including Colorado, Connecticut, Utah, and Virginia, may have rights under applicable state privacy laws, which may include the right to:
8. Access personal data we process about you
9. Request correction of inaccurate personal data
10. Request deletion of personal data, subject to legal exceptions
11. Obtain a copy of your personal data in a portable format
12. Opt out of targeted advertising or profiling, if applicable, as defined under applicable law.
13. Florida Privacy Notice. BeSwell 24 is a Florida corporation and complies with the Florida Information Protection Act (“FIPA”) and other applicable Florida data protection laws.

Important: The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request. To exercise any of these rights, please contact us at privacy@beswell24.com.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data "sales" as defined under certain laws. When required by applicable law and when we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depend on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access. Older adults may be more vulnerable to scams or phishing attempts, and we encourage users to remain vigilant and contact us if they suspect suspicious activity.

Security Incidents and Breach Notification

In the event of a security incident involving personal data, and where required by applicable law, we will: notify affected individuals in accordance with applicable legal requirements; notify relevant regulatory authorities as required by applicable law; and take reasonable steps to investigate, address, mitigate, and remediate the incident.

How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

Changes to Our Privacy Policy

We may update this Policy from time to time, and we will provide notice of any such changes to the Policy as required by law. We will notify you of changes to this Policy by updating the "last updated" date and posting the updated Policy. In certain circumstances, including where required by applicable law, we may also provide you with additional notice of material changes, such as by email or through the Services. You should check our Website periodically to see the current Policy and any changes we have made to it. Your continued use of the Website and Services after we make changes is deemed to be acceptance of those changes.

Contact Information

To exercise your rights or ask questions or comment about this Policy or our privacy practices, contact us at:

Email: privacy@beswell24.com

Phone: 1(888) 306-2073