Platform and Services Privacy Notice

1. Information We Collect

We collect information necessary to provide, improve, secure, and evaluate the Services.

Account Information

When creating an account, we may collect:

• Name
• Email address
• Age range
• Gender (optional)
• Institution, employer, or organization affiliation
• Program, year of study, department, or similar organizational information where applicable
• Login credentials and account settings

Survey and Assessment Information

Users may voluntarily provide information through assessments, reflections, surveys, journals, habit tracking, coaching interactions, or other platform activities, including:

• Stress levels
• Sleep habits and quality
• Focus and concentration
• Energy levels
• Mood and emotional wellbeing
• Exercise and physical activity
• Nutrition and dietary habits
• Substance use habits
• Work, academic, or personal challenges
• Goal-setting information
• Behavioral patterns and habits
• Cognitive performance indicators

Support and Communication Information

We may collect information you provide when:

• Contacting support
• Participating in onboarding
• Submitting feedback
• Responding to surveys
• Communicating with Autonomic personnel

Automatically Collected Information

We may automatically collect:

• IP address
• Browser type
• Device information
• Operating system
• Session activity
• Feature usage
• Log data
• Referral sources
• Cookies and similar technologies

2. Sensitive Information

Certain information collected through the Services may be considered sensitive personal information, including information relating to wellbeing, mental health, emotional state, lifestyle habits, or personal challenges.

We collect and process such information only with appropriate consent and only for purposes described in this Privacy Notice.

You may withdraw consent where permitted by law, subject to contractual, institutional, legal, safety, or operational requirements.

3. How We Use Information

We may use personal information to:

• Deliver and operate the Services
• Generate personalized recommendations and coaching
• Improve cognitive performance and wellbeing outcomes
• Monitor engagement and platform effectiveness
• Provide customer support
• Maintain platform security
• Conduct analytics and reporting
• Improve products and services
• Develop artificial intelligence and machine learning systems
• Conduct scientific and educational research
• Comply with legal obligations
• Protect users and others from harm

4. Human Review, Safety Monitoring, and Crisis Response

Autonomic combines artificial intelligence, automated systems, and authorized human review processes to support the safety, quality, and effectiveness of the Services.

Certain user submissions may be reviewed by authorized Autonomic personnel for purposes including:

• Quality assurance
• Validation of AI-generated recommendations
• Investigation of Community Standards violations
• Safety and crisis assessment
• Imminent threat assessment
• Platform improvement
• Legal and contractual compliance

Autonomic utilizes role-based access controls designed to limit access to personal information. Access is restricted to authorized personnel whose responsibilities require such access.

Different personnel may have different levels of access based on their role, training, and operational responsibilities.

5. Crisis, Safety, and Imminent Threat Situations

Autonomic is not an emergency service, crisis hotline, healthcare provider, or replacement for professional medical or mental health care.

However, where Autonomic reasonably believes there may be a risk of serious harm to a user or another person, we may review relevant information and take actions reasonably necessary to address the situation.

Such actions may include:

• Escalating content for review
• Referring users to support resources
• Contacting designated institutional representatives
• Contacting emergency contacts where appropriate
• Contacting emergency responders
• Contacting healthcare providers where legally permitted
• Contacting law enforcement where legally required or reasonably necessary to protect safety

Any disclosure will be limited to information reasonably necessary to address the identified safety concern.

6. Educational Institutions and Organizational Partners

Autonomic may provide participating institutions, employers, athletic organizations, or other approved partners with aggregated and de-identified reports regarding:

• Student or participant engagement
• Wellbeing trends
• Cognitive performance indicators
• Habit adoption
• Program effectiveness
• Crisis trends
• Service utilization
• Outcome measurements

Except as otherwise described in this Privacy Notice, Autonomic does not disclose identifiable personal information to institutions or organizational partners without appropriate authorization, consent, contractual authority, or legal basis.

7. Artificial Intelligence and Automated Processing

Autonomic utilizes artificial intelligence, machine learning, analytics systems, and decision-support technologies to:

• Generate recommendations
• Identify behavioral patterns
• Personalize content
• Improve interventions
• Prioritize content for review
• Improve platform effectiveness

These systems assist users and authorized personnel but do not replace professional medical, psychological, educational, or clinical judgment.

Where appropriate, AI-generated outputs may be reviewed, modified, validated, or overridden by authorized personnel.

8. Research, Analytics, and Scientific Validation

Autonomic may use aggregated and de-identified information to:

• Improve the Services
• Validate interventions
• Improve recommendation systems
• Develop artificial intelligence systems
• Conduct scientific research
• Support academic collaborations
• Publish research findings
• Advance cognitive science and behavioral science

Research activities may be conducted independently or in collaboration with academic institutions and research partners.

Where required, research activities will be conducted under appropriate ethics approvals.

9. Use of Data for Artificial Intelligence and Model Improvement

Autonomic continually improves its recommendation systems, artificial intelligence models, analytics capabilities, and cognitive performance insights.

To support these activities, Autonomic may use aggregated, anonymized, and de-identified information generated through the Services to:

• Improve recommendation quality and accuracy.
• Evaluate intervention effectiveness.
• Develop new cognitive performance insights.
• Improve machine learning and artificial intelligence systems.
• Identify behavioral patterns and outcome trends.
• Validate scientific and operational hypotheses.
• Enhance platform safety, quality, and effectiveness.

Autonomic does not use identifiable personal information to train publicly available artificial intelligence models.

Where information is used for model development, research, analytics, or platform improvement, Autonomic takes reasonable measures designed to remove or reduce direct identifiers and limit the risk of re-identification.

Users may opt out of having their personal information and future platform activity used for model improvement, research, analytics, or product development purposes by contacting [email protected] or adjusting available account preferences where provided.

An opt-out request will not affect Autonomic's ability to process information necessary to provide the Services, maintain platform security, conduct safety monitoring, investigate Community Standards violations, respond to crisis or imminent threat situations, comply with legal obligations, or fulfill contractual commitments to participating institutions.

Models, algorithms, insights, and improvements developed using previously aggregated, anonymized, or de-identified information prior to an opt-out request will remain the intellectual property of Autonomic and may continue to be used, provided such information does not identify a specific individual.

10. Disclosure of Information

We do not sell personal information.

We may disclose personal information:

• To service providers supporting our operations
• To affiliated entities
• To participating institutions as authorized
• During mergers, acquisitions, financings, or corporate restructurings
• To comply with legal obligations
• To investigate fraud, security incidents, or unlawful conduct
• To protect the rights, safety, or property of users or others
• As described in this Privacy Notice

All service providers are required to protect personal information and may only use it for authorized purposes.

11. International Data Transfers

Information may be stored, processed, or accessed in Canada, the United States, or other jurisdictions where Autonomic or its service providers operate.

Where required by law, Autonomic implements appropriate safeguards for international transfers of personal information.

12. Data Governance and Security

Autonomic implements administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, misuse, alteration, or destruction.

Safeguards may include:

• Role-based access controls
• Authentication controls
• Encryption where appropriate
• Audit logging
• Security monitoring
• Vendor management controls
• Confidentiality obligations
• Operational review procedures
• Access restrictions based on business need

Access is granted according to the principle of least privilege.

13. Data Retention

Autonomic retains personal information only as long as reasonably necessary to:

• Provide the Services
• Fulfill contractual obligations
• Conduct research and reporting
• Comply with legal obligations
• Resolve disputes
• Maintain platform security

When information is no longer required, it will be securely deleted, anonymized, or destroyed where reasonably practicable.

14. Your Privacy Rights

Subject to applicable law, you may have the right to:

• Access your personal information
• Correct inaccurate information
• Request deletion of information
• Request a copy of your information
• Withdraw consent
• Object to certain processing activities
• Request information about how your information is used
• File a complaint with an applicable privacy regulator

Requests may be submitted to [email protected].

We may require identity verification before fulfilling requests.

15. Children's Privacy

The Services are not intended for children under the age of 16 unless participation occurs through an authorized program with appropriate permissions and legal authority.

We do not knowingly collect information from children in violation of applicable law.

16. Cookies and Analytics

We use cookies, analytics technologies, and similar tools to:

• Operate the Services
• Improve user experience
• Measure engagement
• Analyze usage patterns
• Improve performance

Users may manage cookie preferences through browser settings, although certain features may not function properly if cookies are disabled.

17. Changes to This Privacy Notice

We may update this Privacy Notice from time to time.

Material changes will be communicated through the Platform, email, or other appropriate means.

Continued use of the Services following the effective date of an updated Privacy Notice constitutes acceptance of the revised Privacy Notice.

18. Contact Information

Autonomic is committed to maintaining the trust, privacy, and safety of all users while advancing cognitive performance, wellbeing, and student success through responsible innovation.