Privacy Policy

This Privacy Policy describes how SmartBran, LLC. and its affiliates (referred to as “SmartBran ”, “our”, “we” or “us” in this Policy) collect, use, share, and protect your personal information, what choices you have relating to your personal information, and how you can contact us.

CONTENTS

Scope of this Privacy Policy
Personal Information We Collect
How and Why We Use Your Information
How We Disclose and Share Personal Information
Your Sharing
Children’s Privacy
Protection of Personal Information
Retention of Personal Information
Managing Your Privacy Rights and Choices
About Cookies and Similar Technologies
Using the SmartBran Platform with Third-Party Products and Services
Changes to Our Privacy Policy
Questions, Feedback and Metrics

1. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy (“Policy”) applies to the personal information that SmartBran, LLC. collect and process when you interact with us as a customer, including when you interact with our websites, platform, digital experiences, mobile apps, online or offline events, promotions, or one of our other products or services, all of which are part of SmartBran’s “Platform” and direct to this Privacy Policy. This Policy also applies to the personal information that SmartBran processes when you subscribe to receive marketing communications from us, communicate with us or engage with us via our Platform, or participate in contests, sweepstakes, and surveys.

SmartBran may provide you with additional privacy notices that will apply to certain personal information collected and processed by us. For example, we may provide additional notice to provide more specific information if you choose to take advantage of a particular partner opportunities. This Policy does not apply to your personal information if you work for us as an employee or independent contractor, apply for a job at SmartBran, or interact with third party partners or websites that are linked to or accessible from SmartBran’s Platform.

This policy does apply to:

APIs and integrations
Data collected through user accounts
Data collected through clients access
Communications, support, and related services

This policy does not apply to:

Third-party services integrated by Users
We b-sites not controlled by SmartBran
Information collected offline unless explicitly stated

Healthcare organizations remain responsible for their own compliance with HIPAA and internal privacy practices.

2. PERSONAL INFORMATION WE COLLECT

SmartBran collects personal information directly from our subscribers, automatically when you use our Platform or interact with us, and from third parties who are associated with our Platform. The definition of “personal information” depends on the applicable law of where you reside. For purposes of this policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual or household. This does not include aggregated or de-identified information that is maintained in a form that cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual or household.

Personal Information Collected Directly from Subscriber. We ask all subscribers for certain personal information to provide you with the products or services you request. The personal information we collect from you depends on how you interact with us or use our Platform. This personal information includes your:

Identifiers. We collect certain personal information from you, such as your name, telephone number, email address, date of birth, password, and other identifiers, as well as any personal and demographic information that you share with us, such as gender, hometown, photos, and images you provide to us or post to your profile, or product preferences. When you make a purchase, we collect your payment or credit card information or account information and billing address.
Commercial Information. We collect information about your purchase, and features that you view or add to your application experience.
Communications. When you communicate with us, we collect your contact details and keep a record of the communications, as well as our responses. We also maintain records of information you provide to us related to any customer support requests.
Physical Characteristics. We collect information on your physical characteristics, including weight, height, and body measurements (pertaining to clients).
Marketing Campaigns and Promotions. If you participate in marketing campaigns and promotions that we offer, we may collect your personal information and other registration information related to marketing campaigns and promotions.
Events Information. We also collect personal information related to your participation in our events or booths we have at other events. For example, if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event.

Personal Information We Derive or Collect Automatically. We and our third-party service providers automatically collect personal information related to your use of our Platform and interactions with us and others, including when you enable certain features within our Platform. This information includes:

Location information. We may collect or derive approximate or precise location information about you. How we collect this information depends on how you use and interact with our Platform and your device settings. For example, we may derive your general location through your IP address. We may collect your precise geolocation (GPS) information from your device or browser, including with your permission available via your device or browser. You may turn off precise location information sharing through your device settings.
Device information. When you interact with our Platform, we collect technical information about your device including your IP address; unique identifiers; unique device identifier and device type; domain, browser type, version, and language; operating system and system settings; general location information and time zone; and similar device and usage information.
Online Activity and Browsing Information. We use cookies, log files, pixel tags, software development kits (“SDKs”) and other tracking technologies to automatically collect information about your interaction with our websites and apps and communications you receive from us. This information includes links clicked, page views, purchases, searches, features used, items viewed, time spent within the Platform, information uploaded, items you add to your cart and your interactions with others within the Platform. For more information, see “About Cookies and Similar Technologies” below.
Audio, visual and other electronic data. We may collect audio, visual, and other electronic data, such as through mobile, laptop and desktop device microphones, and other devices that utilize our application.
Sensor and Movement Data. When you grant us access, we may collect information about you and clients you serve from your device’s sensors, including heart rate, and information about your movement and travel patterns from your device’s accelerometer.
Photos, Contacts, and Calendar information. When you grant us access, we may collect your photos and clients you serve, contacts and calendar information stored on your device.
Inferences. To personalize your experience on the Platform, we may draw inferences using your personal information, to create a profile reflecting your interests, preferences, and characteristics.

Personal Information from Third Parties. We may collect personal information about you from third party sources, including when you use our Platform with third party products and sources. This includes:

Information from Third Party Products and Services. If you connect your SmartBran account or access our Platform through third party products or services (such as website or social media platforms), we may collect information about you from that third party product or service.
Information from Partners. With your consent where required, we may obtain information about how you participate or engage with marketing campaigns and/or events that SmartBran sponsors jointly with third party partners.

Third-party products and services may control the information they collect and share about you. For information about how these third parties may use and disclose your information, please consult their respective privacy policies.

3. HOW AND WHY WE USE YOUR INFORMATION

SmartBran collects, uses, discloses, and otherwise processes the personal information we collect for the following business and commercial purposes:

3.1 Platform Functionality

To operate its core features effectively, SmartBran collects and processes specific types of data that support the essential functions of the platform. Electronic records rely on accurate and complete information to maintain a centralized, accessible, and compliant system of documentation for clients, staff, and organizational operations. Scheduling features require access to service details, staff roles, availability, and client needs so the platform can automate assignments, reduce scheduling conflicts, and support timely service delivery. Notifications depend on contact information and system activity data to send real-time alerts, reminders, and updates that keep staff informed and reduce the risk of missed appointments or incomplete documentation. Secure tracking and audit logs are fundamental for HIPAA compliance and system integrity, capturing actions such as logins, edits, or record access to ensure accountability and traceability across the organization. Data analytics uses aggregated operational and service-related information to help organizations identify trends, improve efficiency, monitor performance, and make more informed decisions. Transportation management requires location, schedule, and service-related data to coordinate non-medical trips, verify completed rides, optimize routes, and maintain compliance with payor or program requirements.

Each of these features plays a significant role in why SmartBran collects certain data elements. Without electronic records, organizations would lack a structured and compliant way to store service documentation. Without scheduling and transportation data, staff assignments and client services could not be managed efficiently. Notifications help ensure real-time communication, which is critical in fast-paced healthcare and support environments. Secure tracking and audit logs protect against unauthorized access and ensure transparency in all system interactions. Data analytics transforms raw information into actionable insights, helping organizations improve care quality, staff productivity, and service outcomes. Together, these components demonstrate how data collection within SmartBran is essential not only for core functionality but also for maintaining compliance, operational efficiency, and high-quality service delivery.
We may also use information for event planning and management, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events and services.

For Research, analytics, and improvement. We use information to better understand how consumers engage with the Platform and our products and offerings, including consumer behavior and preferences. We administer surveys and questionnaires, such as for market research or member satisfaction purposes. We also use information for other research and analytical purposes, such as to evaluate and improve our Platform and business operations, to develop services and features, and for internal quality control and training purposes. For example, we may use information about how consumers engage with SmartBran.io to search for and find products, to better understand the best ways to organize and present product offerings in our storefront.
To Personalize Your Experience and Our Platform. We use personal information, including inferences drawn from your personal information, to tailor and personalize your experience on our Platform.
To Operate, Improve and Maintain our Business, Products and Services. We use the personal information you provide to us to operate, improve, and maintain our business, products, and services. We may use personal information about how you use our products and services to enhance your user experience and to help us diagnose technical and service problems and administer our Platform. We also use information to consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and as related to the administration of our general business, accounting, auditing, compliance, record-keeping, legal and other internal functions.
To Protect Our or Others’ Rights, Property or Safety. We use information to protect the Platform and our business operations; to protect our rights or those of our stakeholders; to prevent, detect and investigate actual or suspected fraud, abuse, illegal use, unauthorized or illegal activities and access and other misuse; and where we believe necessary to investigate, prevent or take action regarding situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use.
To Comply with Legal Obligations. We may also use your personal information as part of legal proceedings, to respond to legal process, and to comply with court orders, governmental requests, or applicable law.

• • Other purposes. We may also use your personal information in other ways and will provide specific notice at the time of collection and obtain your consent where necessary

4. HOW WE DISCLOSE AND SHARE PERSONAL INFORMATION

SmartBran may disclose and share personal information we collect with the following types of entities and recipients:

To our affiliates, subsidiaries, vendors, and service providers. We may disclose personal information to our affiliates and subsidiaries, as well as service providers, vendors and others for business purposes and to perform functions on our behalf (such as those who process credit cards and payments, perform shipping and deliveries; host, manage and service our data; provide technical support or logistics services; secure our Platform; distribute emails; perform research and analysis; manage brand and product promotions; and administer certain services and features on our Platform).
To other Platform users. Your username and any information that you post to our Platform, including, without limitation, reviews, comments, and other text, will be available to, and searchable by, other users of the Platform. You can review and make changes to who can view your profile in your account settings.
Third Party Partners Connected to Your Subscription. If you are a SmartBran subscriber, we may disclose your personal information to third parties that we work with to bring you special offers or who may contact you about products, services and offers you may be interested in. SmartBran’s enables you to connect our Platform or link your Subscription with third party memberships or subscriptions, products, and services. If you choose to connect your SmartBran account or subscriptions or membership, we will share certain personal information with third party partners who may process your personal information in accordance with the privacy policies of those third parties. The information may include information generated through your use of the Platform (such as profile, fitness and activity, and purchase information).
To Third-Party Advertising and Social Platforms and Networks. We may disclose or make available personal information to third-party platforms and providers to obtain personalized and tailored advertising services, to provide or make available certain features or portions of the Platform, or as necessary to respond to your requests. For example, we make information collected via cookies and similar technologies on our Platform available to third-party advertising companies to serve you with relevant ads and content and to manage, improve and measure our advertising campaigns (see “About Cookies and Similar Technologies” below for more information). We also use third party services to match information that we hold with personal information in their database to create custom audiences and tailor advertising to your interests on the Internet, including social media, as permitted by applicable law.

Providing tailored advertising services may be considered a “sale,” “sharing” for cross-context behavioral advertising, or “targeted advertising,” as defined by applicable law. We do not disclose, sell, or share personal information to third parties for money or compensation. You may opt-out of cross-context behavioral advertising or targeted advertising by using the relevant settings available in our Platform.

Business partners and potential buyers (and their agents and advisors). We may disclose your personal information with actual or potential buyers (and their agents and advisors) in connection with any actual or proposed purchase, merger, acquisition, financing, reorganization, bankruptcy, receivership, sale of company assets or transition of service to another provider, provided that we inform the buyer or transferee that it must use your personal information only for the purposes disclosed in this Privacy Policy.
Other Parties. We may disclose personal information to other parties, including government entities and regulators, to the extent necessary to: (i) comply with a government request or applicable law and to respond to legal process; (ii) prevent illegal uses of our Platform or violations of our Platform's Terms of Use and our policies; (iii) defend ourselves against third party claims; and (iv) assist in fraud prevention or investigation (e.g., counterfeiting).

• • With your consent. We may disclose your personal information to any other third party where you have provided your consent.

5. YOUR SHARING

When you use certain social features on our Platform, you CANNOT make your profile public, that includes information such as your screen name, profile picture and hometown. You CANNOT share content with your friends or the public, including product reviews and information about your SmartBran activity. This would be a direct violation of our HIPAA Compliance Policy. Subscribers have access to client data (meaning individuals they service directly, indirectly or have frequent contact with). This content, including any information that you post to our Platform. It will be ONLY available to other users with administrative access in relation to your registered business of the Platform. We encourage you to use the tools we provide for managing SmartBran’s social sharing to control what information you make available through SmartBran’s social features.

6. CHILDREN’S PRIVACY

We do not knowingly collect personal information online from children under the age of 13 as registered subscribers or memberships SmartBran.

If you’re a parent or guardian and you believe we have collected your child’s information as a subscriber or through membership (not including client or customer support or services), please contact us at support@smartbran.io

7. PROTECTION OF PERSONAL INFORMATION

We use a variety of technical, administrative, and organizational security measures, including encryption and authentication tools in certain circumstances, that are intended to protect your personal information. Please be aware that despite our efforts, no data security measures can guarantee security. You can help keep your data safe by taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.

8. RETENTION OF PERSONAL INFORMATION

We retain your personal information for as long as reasonably necessary to fulfill the purposes described in this Policy or disclosed to you at the time of collection, unless otherwise required or permitted by law. For example, we keep your account profile information for as long as you keep your SmartBran account, but we may keep your purchase history longer to comply with our legal, tax, accounting and record-keeping obligations, administer applicable returns and warranty programs, and for research, development and safety purposes, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims or comply with legal obligations.

We’re committed to protecting the privacy of our SmartBran Subscribers by only storing your data when you maintain an active profile. Your profile will be considered active if you have an active subscription to our app within the last two years.
- After two years personal information will be available in your profile settings if you sign back in.

• • After five years all profile information and personal data will be permanently deleted across all platforms and will be unrecoverable. Purchase history will remain available to SmartBran in line with statutory requirements on data retention for sales, tax, and warranties. Please contact us at support@smartbran.io if you have any questions.

9. MANAGING YOUR PRIVACY RIGHTS AND CHOICES

Privacy Rights. You may have certain rights identified below under applicable laws of where you reside with respect to your personal information. We have full discretion in choosing to voluntarily provide you with some or all of those rights regardless of the state in which you reside. Please refer to (Section Additional State-Specific Information) to determine the rights you have in the state you reside.

Depending upon the applicable law, access to your rights may be denied, such as: (a) when denial is required or permitted by law; (b) when granting access would have a negative impact on another's privacy; or (c) to protect our rights and properties.

The privacy rights you may have include the following:

Right to know and access your personal information. You may have the right to know what personal information we collect about you, including the categories of personal information, the sources from and purposes for which we collect it, and the types of recipients we disclose it to, and to request a copy of the specific pieces of personal information that we maintain about you.
Right to correct your personal information. Right to correct inaccurate personal information that we maintain about you.
Right to delete your personal information. You may request the deletion of their personal information that we have collected about you, subject to certain exceptions.
Right to opt out of “sales” or “sharing” for cross-context behavioral advertising or targeted advertising. You may request to opt-out of our sale of your personal information and sharing of their personal information for cross context behavioral advertising or targeted advertising. We share your personal information with third parties (such as marketing and advertising networks and social platforms) for behavioral advertising or disclose your personal information to other third-party partners in accordance with your privacy settings and/or consent. These types of disclosures of your personal information may be deemed a “sale” or “sharing” of your personal information under applicable privacy laws.
Right to non-discrimination. You have the right not to be subject to discriminatory treatment for exercising your rights under certain laws.

Exercising your Rights and Choices. You may submit privacy rights requests and manage your privacy choices in several ways.

Submitting Privacy Rights Requests: You may request to access your personal information (both the categories of data we collect, which is laid out in this policy, and specific pieces of information), obtain an electronic copy of your personal information, correct your personal information if it is incomplete or inaccurate, or delete or restrict sharing of your personal information in certain circumstances, as provided by applicable law.
- Non-Discrimination. We will not discriminate against you for making these requests. If you request to delete your account, you can create a new account on our Platform at any time.
- Verification. We will verify your request either through a message sent to the email address associated with your account (so you must have access to this email account) or by asking you to provide information matching what we have for you within our systems. We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor.
- Authorized Agents. You or your authorized agent may request to exercise your rights. Before we can act on a request from your authorized agent, we may require verification of your identity and proof from the authorized agent that they can act on your behalf. We may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
- Contacting Us. If you have a request regarding your personal information that cannot be fulfilled from your account settings, please contact us at support@smartbran.io
- Denials and Appeals. If we deny your request, we will notify you and provide our reasons for the denial and instructions regarding the rights you may have under applicable laws to appeal the decision. If the appeal is denied, we will notify you of your rights under applicable laws to contact the Attorney General to submit a complaint.
Opting Out of Direct Marketing. If you have a SmartBran account, you can opt-out of receiving SmartBran’s email or SMS marketing via the "Communication Preferences" section in your SmartBran.app account settings. Alternatively, you can opt-out by contacting us at support@smartbran.io.
Managing your cookie and advertising preferences. There are several ways that you can manage your preferences for cookies and advertising by us and on our websites. You can review or change your preferences for most cookies and tags on our websites, other than those that are necessary for operation and functionality, by adjusting your cookie settings in your browser. These preferences are browser and device specific, so you will need to set your preferences for each browser and device you use, and if you subsequently delete or block cookies, you may need to reapply these settings.

Opt-out of Targeted Advertising. We share your personal information with third parties (such as marketing and advertising networks and social platforms) for targeted advertising. These types of disclosures of your personal information may be deemed a “sale” or “sharing” of your personal information under applicable privacy laws. However, SmartBran does not disclose, sell, share, or rent your personal information for money or compensation.

You may opt-in or opt-out of targeted advertising by emailing us at support@smartbran.io. If you opt-in again, your personal information will be shared with third-party partners for targeted advertising purposes. If you opt-out as a guest, your preferences will only apply to the device or browser where you made the selection.

Update Your Profile Information. You can update certain personal information, like, address, and phone number, by logging in and updating it through your SmartBran account settings. Emails CANNOT be updated by users. Each email is specifically linked to your access to SmartBran.app. If you require a change or update to your email, contact us at support@smartbran.io.
Managing the content you post: You can request removal of content you have posted on the Platform, but please note that removal may not encompass all possible locations, for example, back-ups or sharing by other users initiated prior to removal.

• • Manage Profile Visibility. If you have administrator access you can adjust how others may interact with you on the Platform by logging into your SmartBran account and adjusting your profile visibility settings. Otherwise, contact your administrator to adjust your account information.

10. ABOUT COOKIES AND SIMILAR TECHNOLOGIES

SmartBran, our service providers and third parties collect information, which may include personal information, from your browser, devices, or apps when you use our Platform using a variety of methods, such as cookies, pixel tags, identifiers for mobile devices, and other similar technologies. The information collected by these cookies and similar technologies may include your: IP address; unique cookie identifier and information obtained through cookies; unique device identifier and device type; domain, browser type and language, operating system, and system settings; country and time zone; previously visited websites; information about your interaction with our Platform such as click behavior, purchases and indicated preferences; and access times and referring URLs.

We use cookies and similar technologies to analyze and understand how you access, use, and interact with our Platform and our consumer’s preferences (such as country and language choices), as well as to assess, secure, protect, optimize, and improve the performance of our Platform. This enables us to provide services to our consumers and improve their online experience. We also use cookies and pixel tags to obtain aggregate data about Platform traffic and interaction, to conduct analytics, identify trends and obtain statistics so that we can improve our Platform. We also use cookies and similar technologies to target advertising and content across our Platform and third-party sites and services.

Third-Party Technologies and Services. Some of the cookies and similar technologies we use are operated by third party companies. We use third-party services, such as Google Analytics and its advertising products, such as Google Signals and Google Ads, that may collect usage data (using cookies, pixel tags and similar tools) about our Platform to provide us with reports and metrics that help us to evaluate usage of our Platform, improve performance and user experiences, and serve relevant advertising to you. We also use third-party technologies and services, to support the security of our Platform and protect against fraud and abuse. In some cases, the processing of this data is subject to these third parties’ privacy policies (for example, for Google Analytics, see Google’s Privacy & Terms).

You may see our ads on other websites, such as our partner’s websites, because we use third-party ad services. Through these ad services, we can show you ads that may be tailored to your individual interests. These ad services may also track your online activities over time and across multiple websites and apps by collecting information through automated means. This data collection takes place both on our Platform and on third-party websites and apps that participate in these ad services.

11. USING THE SMARTBRAN PLATFORM WITH THIRD-PARTY PRODUCTS AND SERVICES

Our Platform may provide links to other third-party websites and apps for your convenience or information. Linked sites and apps have their own privacy notices or policies, which we strongly encourage you to review. To the extent any linked websites or apps are not owned or controlled by us, we are not responsible for their content, any use of the websites or apps, or the privacy practices of the websites or apps.

12. CHANGES TO OUR PRIVACY POLICY

Applicable law and our practices change over time. If we decide to update our Privacy Policy, we will post the changes on our Platform. If we materially change the way in which we process your personal information, we will provide you with prior notice, including via email to the address we have on file, or where legally required, request your consent prior to implementing such changes. We strongly encourage you to read our Privacy Policy and keep yourself informed of our practices.

13. QUESTIONS, FEEDBACK AND METRICS

We welcome questions, comments and concerns about our privacy policy and privacy practices.

If you wish to provide feedback or if you have questions or concerns or wish to exercise your rights related to your personal information, please email us at support@smartbran.io.

You may also contact Consumer Services via mail at: 665 E Dublin Granville Suite 330, Columbus, OH 43229 USA or send us an email at support@smartbran.io.

Last Updated: 12/1/2025

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