Privacy Policy

Privacy Policy

Effective as of December 2025.

Glucobit Inc., doing business as Reframe and Reframe App ("Reframe," "we", "us" or "our") is dedicated to helping individuals build a healthier relationship with alcohol, regardless of the amount they consume. This Privacy Policy describes how Reframe processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile application, and social media pages) as well as our marketing activities, and other activities described in this Privacy Policy (collectively, the "Service"). We may provide additional or supplemental privacy policies to individuals for specific products or services. For individuals who reside in states with laws that apply to consumer health data, please view our Consumer Health Data Privacy Policy.

INDEX

• Our privacy principles
• Personal information we collect
• Tracking Technologies
• How we use your personal information
• Retention
• How we share your personal information
• Your choices
• Other sites and services
• Security
• International data transfers
• Children
• Changes to this Privacy Policy
• How to contact us

OUR PRIVACY PRINCIPLES

At Reframe, we understand how personal the topic of drinking and alcohol may be for you, which is why we take privacy seriously. Our mission is to help you moderate your alcohol consumption to reach your goals, and this requires trust. We have outlined our privacy principles to be transparent:

• We collect personal information necessary to provide our services — assisting you in moderating your alcohol consumption.
• We are particularly cautious about how we use self-reported personal information about your alcohol consumption and drinking goals. We primarily use this information to provide and personalize our services to you, and we do not share self-reported alcohol consumption data with third-party advertising partners.
• The service providers we work with have contracts in place designed to limit their use of your personal information.
• We generally limit access to your personal information to a subset of our team and access it in detail when trying to provide guidance and support to you.

If you have questions, you can email us directly at privacy@reframeapp.com and our team will respond.

PERSONAL INFORMATION WE COLLECT

Information you provide to us or that we generate about you. Personal information you may provide to us through the Service or otherwise or that we may generate about you includes:

• Contact data: your name, email address, billing and mailing addresses, and phone number.
• Demographic data: your age, sex, and gender identity.
• Profile data: the username and password you may set to establish an online account on the Service, biographical details, redemption codes, photographs or pictures, links to your social network profiles, interests, preferences, and any other information you add to your account profile.
• Alcohol-related data: your alcohol consumption patterns and drinking goals.
• Communications data: information from our exchanges with you, including when you contact us through the Service, social media, or other channels.
• Transactional data: information relating to or needed to complete your orders through the Service (including order numbers and transaction history).
• Assessment performance data: your usage, progress, and performance through the Service offerings.
• Health-related data: your self-reported pregnancy status, medical history, prescription history, allergies, and other similar information.
• Marketing data: your preferences for receiving our marketing communications and details about your engagement with them.
• User-generated content data: photos, images, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where, and by whom content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or have added to their content, such as keywords, geographical or location information, and other similar data.
• Payment data: information needed to complete transactions, including payment card information or bank account number.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

• Data providers, such as data licensors.
• Partners, such as marketing and service partners and event co-sponsors.
• Service providers that provide services on our behalf or help us operate the Service or our business.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data: your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state, or geographic area.
• Online activity data: pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
• Communication interaction data: your interactions with our email, text, or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (also known as clear GIFs), which may be embedded invisibly in our emails.

For more information concerning our automatic collection of data, please see the Tracking Technologies section below.

TRACKING TECHNOLOGIES

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

• Cookies: small text files that websites store on user devices that allow web servers to record users' web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both "session cookies" that are deleted when a session ends, "persistent cookies" that remain longer, "first party" cookies that we place, and "third party" cookies that our third-party business partners and service providers place.
• Local storage technologies: like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Web beacons: also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

For information concerning your choices with respect to the use of tracking technologies, see the Your Choices section below.

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• provide and operate the Service;
• enable security features of the Service (such as by sending you security codes via email or SMS, and remembering devices from which you have previously accessed the Service);
• establish and maintain your user profile on the Service;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
• communicate with you about events or contests in which you participate; and
• provide support for the Service, and respond to your requests, questions and feedback.

Service personalization. We may use your personal information to:

• understand your needs and interests;
• personalize your experience with the Service and our Service-related communications; and
• remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of Communications section below.
• Interest-based advertising. We and our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the Tracking Technologies section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. We do not share self-reported alcohol consumption data (including your drinking goals) with third-party advertising partners.

Mobile information. We will not share your mobile information (such as phone numbers collected for SMS communications) with third parties or our corporate affiliates for their own direct marketing purposes.

Events, promotions and contests. We may use your personal information to:

• administer promotions and contests;
• communicate with you about promotions or contests in which you participate; and
• contact or market to you after collecting your personal information at an event.

Data sharing in the context of corporate events. We may share certain personal information in the context of actual or prospective corporate events – for more information, see How We Share Your Personal Information below.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including for research and other analytical purposes as well as to analyze and improve the Service and promote our business.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the cookies and similar technologies described above for the following purposes:

• Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
• Functionality. To enhance the performance and functionality of our services.
• Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.
• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails.

Further uses. In some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

RETENTION

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, artificial intelligence providers, email delivery, marketing, consumer research and website analytics).

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.

Partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and Protection purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in or financings of Reframe, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Reframe as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Other third parties. If you request immediate assistance related to your health or wellbeing, we may, at your direction, connect you to first responders, mental health and medical professionals, and support hotlines.

Other users. Your profile and other user-generated content data (except for messages) may be visible to other users of the Service. For example, other users of the Service or the public may have access to your information if you choose to make your profile or other personal information available to them through the Service, such as when you provide posts, comments, or share other content. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

YOUR CHOICES

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

If you receive text messages from us, you may opt out of receiving further text messages from us by replying STOP to our message.

Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

• Browser settings. Changing your internet web browser settings to block third-party cookies.
• Privacy browsers/plug-ins. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
• Platform settings. Certain platforms offer opt-out features that let you opt-out of use of your information for interest-based advertising. For example, you may be able to exercise that option for Google and Facebook, respectively, at the following websites:
   - Google: https://adssettings.google.com/
   - Facebook: https://www.facebook.com/about/ads
• Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
   - Network Advertising Initiative: https://www.networkadvertising.org/managing/opt_out.asp
   - Digital Advertising Alliance: https://optout.aboutads.info
   - AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
• Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.

We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.

Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, email us at help@reframeapp.com.

OTHER SITES AND SERVICES

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

SECURITY

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

INTERNATIONAL DATA TRANSFERS

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

CHILDREN

The Service is not intended for use by anyone under 21 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or through other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledgment that the modified Privacy Policy applies to your interactions with the Service and our business.

HOW TO CONTACT US

Email: privacy@reframeapp.com

Glucobit Inc.
Atlanta, Georgia