Pivot (“the app,” “we,” “us,” “our”) is a product of Pebbles, LLC, designed to help you build simple, sustainable habits—one day at a time. Your privacy matters deeply to us. This Privacy Policy explains what information we collect, how we use it, and the choices and rights you have.

If you have any questions, you can always reach us at support@trypivot.com.

1. Information We Collect

We collect two types of information: (a) information you provide, and (b) information that’s automatically collected when you use the app.

1.1 Information You Provide

• Health-related entries: such as daily check-ins, lifestyle habits, GLP-1 injection logs, symptoms, or any information you choose to track about your health or habits.

• Account information (optional): if you create an account, we collect basic details like your name, email address, password, and profile details.

• Reminder and notification settings: such as your preferred times for habit reminders or medication reminders.

• Support requests: if you contact us for help, we collect the information you provide so we can assist you.

• Connected devices or services (optional): if you link Pivot with third-party apps or devices (for example, a wearable fitness tracker or health app), we will collect information from those sources with your permission (e.g., step count or other wellness data you agree to share).

1.2 Information Collected Automatically

• Device information: details about the device and software you use, such as device type, operating system, and app version.

• Usage information: how you interact with the app – for example, buttons you tap, screens you view, session length, and feature usage (we use this to improve app performance and user experience).

• Crash and performance data: technical information if the app crashes or has errors, used to identify bugs and improve reliability.

Note: We do not collect your precise GPS location.

2. How We Use Your Information

We use your information to:

• Power your daily check-ins, habits, and reminders.

• Personalize your in-app experience and provide tailored insights.

• Track your progress and generate weekly reports for you.

• Improve app performance, add new features, and enhance stability.

• Communicate with you about app updates, support responses, or relevant information.

• Maintain the safety and security of the app and our users.

We may also use automated algorithms (including AI) to analyze your data and provide personalized tips or insights. These insights are for general wellness purposes and not medical advice.

Importantly, we never sell your data.

3. Health Information & Privacy

Some information you enter may be health-related or sensitive. This data is used only to support your experience inside the app. It is not shared with your healthcare provider or anyone else unless you explicitly authorize a connection or integration.

By entering health information into Pivot, you are consenting to our processing of that data to provide the app’s features (for example, generating your charts or suggestions). If we ever want to use your health data for a purpose beyond what’s described in this Policy, we will seek your permission.

Unless you are using Pivot as part of a clinical program offered by a telehealth partner such as Shed (tryshed.com) that is accompanied by a HIPAA Notice of Privacy Practices, the information you enter into the app is not regulated by HIPAA. Pivot is a consumer wellness app, and in most cases it is not a “covered entity” under HIPAA. However, we still protect your health-related information under this Privacy Policy and with strict security measures.

(In short: outside of a special medical program context, your Pivot data is private and protected by this Policy, not by HIPAA.)

4. How Your Data Is Stored and Protected

We use industry-standard security measures to protect your information, including:

• Encryption in transit: Data is encrypted (HTTPS) when it’s sent between your device and our servers.

• Secure infrastructure: We store data on modern, secure cloud services with safeguards in place.

• Restricted access: Internally, only authorized personnel who need to access your information to operate the service are allowed to do so.

• Regular reviews: We perform regular security reviews and updates to address new threats and protect your data.

While no system can be 100% secure, we work hard to keep your data safe and secure.

5. When We Share Information

We do not share your personal information unless it falls under one of the following situations:

5.1 Service Providers

We may share data with trusted third-party vendors who help us operate and support Pivot. For example, this includes:

• Cloud storage providers (to securely store data).

• Analytics services (to help us understand app usage and improve the product).

• Notification systems (to send you reminders or alerts you set up).

These partners are bound to only use your data to perform these tasks for us and not for their own purposes.

5.2 Legal Requirements

We may disclose information if we are required to do so by law or legal process – for instance, in response to a court order or government regulation – or if disclosure is necessary to protect the safety, rights, or property of our users, the public, or Pebbles, LLC.

5.3 Wellness Programs and Sponsors

If you use Pivot as part of a program supported by a third party – for example, an employer-sponsored wellness program, health plan, or a wellness program offered by a telehealth provider like Shed – we may share limited information with the program organizer to facilitate that program. This could include confirming your participation or sharing aggregate progress metrics (such as completion of goals or usage frequency) for rewards or program management. We will always make clear what information would be shared and obtain appropriate consent from you when you enroll in such a program.

(In plain terms: if your employer or another company gave you access to Pivot as part of a wellness initiative, we might report back things like that you’re using the app, but not your private journal entries. And we’d only do so with your knowledge.)

5.4 Business Transfers

If Pebbles, LLC is involved in a merger, acquisition, investment, or sale of all or part of its assets, your information (as part of the business assets) may be transferred to the new owner or party as part of that deal. If that happens, we will ensure the new owner honors the commitments in this Privacy Policy, and we will notify you (for example, via email or a notice in the app) of any such change in ownership or control of your personal information.

We never share your personal information with advertisers or third parties for their own marketing purposes.

6. Your Choices and Rights

You have control over your information and how it’s used. For example, you can:

• Use Pivot without an account: You are free to use the app without creating a personal account. In that case, your data is stored locally on your device (unless we explicitly state otherwise for a particular feature).

• Adjust reminders and notifications: Turn in-app reminders or notifications on or off at any time.

• Update or delete your entries: You can edit or remove any of your logged habits, check-ins, or other entries in the app at any time.

• Opt out of communications: You can unsubscribe from promotional emails or newsletters, and you can disable certain push notifications or in-app messages if they are not relevant to your use.

• Delete your account and data: You may request deletion of your account and all associated personal data at any time.

6.1 Deleting Your Data

If you decide to stop using Pivot, you can request that we delete your account and the data we have about you. Simply email us at support@trypivot.com with your deletion request. Once we receive such a request, we will delete your personal data from our active systems and records within a reasonable time frame. (Keep in mind that removal from backups may take a bit longer, but we will not retain your data longer than necessary.)

6.2 Your Privacy Rights

Depending on where you live and applicable privacy laws, you may have additional rights regarding your personal information. For example, residents of Utah have certain rights under the Utah Consumer Privacy Act (UCPA). In general (and we extend these principles to our users as applicable), you may have the right to:

• Access your data: You can ask us to confirm if we’re processing your personal information and request a copy of the information we hold about you in a portable format.

• Delete your data: You can ask us to delete personal information we have collected from you (subject to certain exceptions required by law). This is in addition to the deletion rights described above in 6.1.

• Correct your data: If you believe any personal information we have is inaccurate or incomplete, you can request that we correct or update it.

• Opt out of “sales” or certain sharing: You have the right to opt out of the sale of your personal data or use of your data for targeted advertising. (Note: Pivot does not sell personal data, and we do not share your data for third-party targeted advertising. If that ever changes, we will update this Policy and provide opt-out options.)

• Non-discrimination: We will never discriminate against you (for example, denying service or charging different prices) for exercising any of these privacy rights.

To exercise any of your privacy rights or choices, you can contact us at support@trypivot.com. We may need to verify your identity (to protect your privacy) before processing certain requests. If we cannot fulfill your request, we will explain the reason (for instance, if it’s exempt under law). If you feel we have not addressed a request or concern adequately, you also have the right to contact your state’s Attorney General or appropriate data protection authority.

7. Children’s Privacy

Pivot is not intended for children under 13 years of age. We do not knowingly collect personal information from anyone under 13. If you are a parent or guardian and believe your child under 13 has provided personal information in Pivot, please contact us so we can delete that information.

8. Data Retention

We keep your information only as long as necessary to provide the app’s features and services, or as required for legal compliance and legitimate business purposes.

If you delete your account (or request deletion), we will remove your personal data from our systems within a reasonable time frame. In practice, this means your data will be securely deleted from our active databases, typically within [a short period, e.g., 30 days], except for any information we are required to keep by law. Backup copies may persist for a limited time, but will be purged according to our regular backup retention schedule.

9. Changes to This Policy

We may update this Privacy Policy from time to time. If we make changes, we will post the new version and update the “Effective Date” at the top. For any significant changes, we will also notify you through the app or via email. We encourage you to review this Policy periodically. Continued use of Pivot after an update means you accept the revised Policy.

10. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please reach out to us:

• Email: support@trypivot.com

• Company: Pebbles, LLC (maker of Pivot)

We’re here to help and will do our best to address your inquiry promptly.

Pivot Terms of Use

Effective Date: [Insert date]

Welcome to Pivot (“the app,” “we,” “us,” or “our”), which is provided by Pebbles, LLC. Pivot is designed to help you build simple, sustainable habits that support your health and lifestyle. By using the app, you agree to these Terms of Use (“Terms”). Please read them carefully. If you do not agree to these Terms, please do not use the app.

1. About Pivot

Pivot is a habit-building and wellness tracking app. It includes features such as daily check-ins, reminders, habit tracking, and helpful insights to support your healthy lifestyle. Some users may also choose to track health-related activities like GLP-1 injections or other wellness metrics.

Pivot may also use automated algorithms (including artificial intelligence) to provide personalized tips or insights based on the information you input. These insights are for general wellness purposes and not medical advice.

Pivot is not a medical device and does not provide diagnosis, treatment, or medical advice. Always consult a healthcare professional for any medical concerns. If you’re experiencing a medical issue or emergency, do not rely on Pivot – seek professional medical help.

2. Eligibility

To use Pivot, you must:

• Be at least 13 years old.

• Reside in a country where the app is officially available.

• Use the app only for your personal, non-commercial purposes.

If you are under 18, you must have permission from a parent or legal guardian to use the app.

3. Subscriptions & Payments

Some features of Pivot may require a paid subscription or enrollment in a program:

• App Store Subscriptions: If you subscribe via the Apple App Store or Google Play Store, all billing and payments are handled by the respective app store. Your subscription will automatically renew unless you cancel it in your app store account settings before the renewal date. Refund requests, if any, should be directed to the app store, as we do not manage billing or have access to your full payment information.

• Program-Based Access: If Pivot is provided to you as part of another program (for example, an employer wellness program or a health plan, or a program offered by Shed), your access to certain features (or to the app itself) may depend on your eligibility or membership status in that program. For instance, if your employer offers Pivot as a benefit, you might lose access if your employment or that wellness program ends. In any such case, you will be informed of any special terms that apply.

4. Accounts

Creating a Pivot account is optional. If you do choose to create an account, you agree to:

• Provide accurate and up-to-date information about yourself.

• Keep your login credentials secure and confidential. You are responsible for protecting your password.

• Be responsible for all activities that occur under your account. If you suspect unauthorized use of your account, notify us immediately.

We reserve the right to suspend or terminate any account that violates these Terms or is used inappropriately.

5. Your Content

You may input data into Pivot (for example, habits, check-in responses, notes, or other health and lifestyle information). You retain ownership of the content you create. By using the app, you grant us a limited, non-exclusive license to use, host, store, and process this information solely for the purpose of operating, improving, and personalizing the app experience for you and other users. This license allows us to, for example, back up your data, analyze usage for improvements, and send you relevant reminders.

We want to be clear: we do not sell your data. Our Privacy Policy details how we handle and protect the information you provide. In short, your data is used to help make Pivot work better for you, and for no other purpose.

6. Not Medical Advice

Pivot provides general wellness and habit-building guidance. It does not under any circumstances:

• Diagnose, treat, or cure any medical condition.

• Replace professional medical, psychological, or other healthcare advice.

• Provide personalized medical recommendations or drug dosage instructions.

Any health-related information or insights in the app (including those generated by AI or algorithms) are for informational and motivational purposes only. Individual results may vary. Always consult a qualified healthcare professional for questions about your health.

If you choose to log medications or health metrics (for example, GLP-1 injection details), that information is for your personal tracking only. Pivot does not monitor this information in real time, and no healthcare provider is reviewing it unless you are explicitly using Pivot as part of a supervised program that has its own medical oversight.

7. Acceptable Use

When using Pivot, you agree not to:

• Reverse engineer, decompile, or attempt to extract the app’s source code.

• Use the app in any unlawful, harmful, fraudulent, or disruptive manner.

• Upload or transmit any content that is illegal, threatening, abusive, defamatory, or that infringes on anyone’s rights.

• Attempt to interfere with or compromise the app’s normal functionality or security (for example, by introducing viruses, overloading, or attacking the app’s servers).

• Use any automated system or software (such as bots or scraping tools) to extract data from the app or to interact with the app on your behalf, outside of the app’s intended use.

We may monitor usage of the app to ensure compliance with these rules and to maintain the security and integrity of the service. Violation of the above rules may result in suspension or termination of your access to Pivot.

8. App Modifications & Availability

We are always working to improve Pivot. This means we may add, change, or remove features of the app at any time. We might also need to temporarily suspend or limit access to the app for maintenance, updates, or other reasons (for example, to resolve a security issue).

We will try to give you advance notice if we make significant changes or if the app will be down for maintenance, but we cannot guarantee it in every case.Pebbles, LLC is not liable if the app (or any part of it) is unavailable at any given time or if any feature is changed or removed. Your use of the app after we make changes indicates your acceptance of those changes.

9. Third-Party Services and Integrations

Pivot may integrate with or link to third-party services or devices to enhance your experience. For example, you might connect Pivot to a wearable fitness tracker, import data from another health app, or use services like analytics, cloud storage, or app store platforms in conjunction with Pivot.

Please note:

• We do not own or control third-party services. Each third-party service has its own terms and privacy policies, and you should review those when you decide to use them.

• We are not responsible for the content, accuracy, or practices of any third-party services. If you follow a link to a third-party website or enable a third-party integration, you do so at your own risk.

• Your use of third-party services is governed by their terms, not ours. For instance, if you connect a wearable device, any data that device collects is also subject to the device manufacturer’s terms and privacy policy.

10. Intellectual Property

All content, branding, logos, graphics, software code, and features in the app are the property of Pebbles, LLC (the creator of Pivot) or its licensors. This includes the “Pivot” name and logo, and all design elements and content provided through the app.

You agree not to copy, distribute, modify, or create derivative works based on any part of Pivot without our prior written permission. This means you cannot, for example, reuse our graphics or text for your own app, or incorporate our features into another product, unless you have our explicit consent.

11. Termination

You are free to stop using Pivot at any time. Likewise, we reserve the right to suspend or terminate your access to the app (or certain features of the app) if:

• You violate these Terms or our Privacy Policy.

• We discontinue the app or any part of it.

• We are required to do so for legal reasons.

If your access is terminated (by you or by us), your rights under these Terms will immediately end. This means you must stop using the app, and we may delete or disable your account and data (though you still can request data deletion if not already done).

Sections of these Terms that by their nature should survive termination (such as disclaimers of warranties, limitations of liability, and governing law) will continue to apply even after termination.

(If you decide to leave, remember you can request deletion of your data at any time by contacting us.)

12. Disclaimer of Warranties

Pivot is provided to you “as is” and “as available.” This means that you use the app at your own risk. To the fullest extent permitted by law, we disclaim all warranties of any kind, either express or implied. In particular, we make no warranties or guarantees regarding:

• Accuracy: We do not guarantee that the information or content in the app (including any insights or data analysis) is completely accurate, current, or error-free.

• Reliability: We do not warrant that the app will be reliable or that it will operate without interruptions or errors.

• Availability: We make no guarantee that the app will be available 100% of the time. There may be downtime, delays, or errors.

• Suitability for a particular purpose: We do not promise that Pivot will meet your specific needs or achieve any particular results. (For example, we can’t guarantee that using Pivot will improve your health or help you achieve a specific goal — that’s up to you and various factors outside our control.)

• Outcomes or results: We do not guarantee any specific health outcomes or improvements from using the app. Everyone’s experience is unique.

To put it plainly, we hope Pivot is useful and enjoyable, but we don’t make promises that it will be perfect or that it will work magic for your health. Use your own judgment and common sense when using the app.

13. Limitation of Liability

To the fullest extent permitted by law, Pebbles, LLC and its officers, employees, partners, and agents will not be liable for any indirect, incidental, consequential, special, or punitive damages, or any loss of data, revenues, or profits, arising out of or in connection with your use of Pivot. This limitation applies even if we have been advised that such damages were possible.

In particular, we are not responsible for:

• Any indirect or consequential losses or damages (for example, the loss of your data entries, or if the app failing to function properly somehow causes you inconvenience or harm).

• Any loss of profits or business opportunities.

• Any unauthorized access to or use of our servers and/or any personal information stored in the app, unless such access is due to our failure to take reasonable security measures.

In all cases, our total liability to you for any claim arising from or related to your use of the app is limited to the amount you paid us, if anything, in the 12 months prior to the event giving rise to the liability. If you have not paid anything (for example, if you are on a free plan), our total liability is $0.

Some jurisdictions do not allow certain limitations of liability. If laws that apply to you do not allow the exclusions or limitations above, those limitations may not apply to you to the extent prohibited.

14. Governing Law

These Terms are governed by the laws of the State of Utah, U.S.A., without regard to its conflict-of-law principles. This means that the laws of Utah will be used to interpret these Terms and govern any dispute that might arise between you and us regarding Pivot.

By using Pivot, you agree that any dispute or claim arising out of or related to these Terms or the app will be decided exclusively by the state or federal courts located in Salt Lake County, Utah, and you consent to the jurisdiction of those courts. (If you’re using the app from outside the United States, be aware that you are still agreeing that Utah law applies and to jurisdiction in Utah.)

15. Changes to These Terms

We may update or modify these Terms of Use from time to time. If we make a significant change, we will notify you by posting the updated Terms in the app and updating the “Effective Date” at the top. In some cases, we might also notify you via email or an in-app message.

It’s important that you review any changes. If you continue to use Pivot after the Terms have been updated, that means you accept and agree to the new Terms. If you do not agree with the changes, you must stop using the app.

16. Contact Us

If you have any questions, feedback, or concerns about these Terms or the app, please feel free to contact us:

• Email: support@trypivot.com

• Company: Pebbles, LLC (developer of Pivot)

We value our users and will do our best to address your inquiry promptly.

By using Pivot, you acknowledge that you have read and understood these Terms and agree to be bound by them. Thank you for choosing Pivot to support your wellness journey!