Consumer Health Data Privacy Notice

Last Updated: 1 September 2026

The Sword Consumer Health Privacy Notice supplements Sword's Privacy Statement and applies only to our users in Washington (under Washington's My Health, My Data Act), Nevada (under Nevada's Consumer Health Data Privacy Law, NRS 603A.490–.520) and Connecticut (under Connecticut Data Privacy Act).

What does the Sword Consumer Health Data Privacy Notice cover

This Notice applies only to "consumer health data," meaning personal information that identifies your past, present or future physical or mental health status, as defined by applicable law.

Consumer health data does not include protected health information subject to HIPAA, publicly available information or deidentified information.

Categories of Consumer Health Data We May Collect:

Information or data regarding
- Individual health conditions, treatment, status, disease or diagnosis;
- Information identifying a health-related surgery or procedure.
- Social, physiological, behavioral and medical interventions;
- Bodily functions, vital signs, symptoms or measurements;
- Diagnosis or diagnostic testing
Wearable sensor data and biometric data (including health-related measurements)
Information that identifies an individual's intention to seek health care services.
Information inferred from data that is not consumer health data but is used to associate an individual to the information listed above.

What is the Purpose for Collecting, Using, and Sharing Consumer Health Data

To provide and deliver our services through the Dawn App, including improving and personalizing the services you receive.
To provide customer service and respond to your requests and inquiries.
To operate our business, including billing, accounting, improving our internal operations.
To make our systems secure, detecting illegal, fraudulent and suspicious activity, including technical notices, updates, security updates.
To provide you information, such as confirmations, reminders, support, and general administrative information.
To meet our legal obligations.
For other purposes with your consent.

How We Process Consumer Health Data

We process consumer health data through a combination of automated and manual means, including through the Dawn App platform, secure cloud-based systems, and internal analytical tools. Processing includes collecting, storing, organizing, analyzing, using, sharing, and deleting consumer health data as described in this Notice. No third party independently collects consumer health data through our services unless separately disclosed.

What are the Categories of Sources From Which We Collect Your Consumer Health Data:

Provided directly by you when you sign up for the Dawn App
Collected from your devices and connected wearables that you choose to use with the Dawn App
Collected from our affiliates where you use other services we provide (as applicable)

How we share Consumer Health Data:

We may share consumer health data with our service providers and affiliates only as necessary to provide the Services, maintain security, prevent fraud, and comply with law. All service providers that process consumer health data on our behalf are bound by written agreements that restrict their use of such data to the purposes specified by Sword, require them to implement reasonable security measures, and obligate them to delete or return consumer health data upon the conclusion of services.
Where required by applicable law, we will obtain your consent before we share your consumer health data with third parties for purposes other than providing the Services you request.

Categories of Third Parties and Affiliates with whom We May Share Consumer Health Data:

Our service providers acting as processors on our behalf to provide the Services you request
Corporate transactions such as a merger, financing, acquisition, bankruptcy, dissolution or sale or transfer of all or a portion of our business or assets.
Governmental agencies
Affiliates of Sword: Sword Health SA

Data Retention

We retain consumer health data for as long as reasonably necessary to fulfill the purposes described in this Notice, to provide the Services you have requested, or as required by applicable law. The specific retention period depends on the nature of the data, our ongoing relationship with you, and our legal obligations. When consumer health data is no longer needed for these purposes, we will securely delete or de-identify it. If you request deletion of your consumer health data, we will process your request as described in the "Your Rights" section below.

Your Rights

Right to Know — You may confirm whether we are collecting, sharing, or selling consumer health data about you, and access that data, including a list of all third parties and affiliates with whom we have shared your data and an active email address or other online mechanism you can use to contact those third parties
Right to Request Correction or Deletion — You may request that we correct inaccurate consumer health data or delete consumer health data we hold about you. Upon receiving a verified deletion request, we will delete the data from our systems (including archived and backup systems within six months) and notify our affiliates, processors, and third parties to do the same
Right to Withdraw Consent (where we process consumer health data based on your consent)

How to Exercise Your Rights

You may exercise the rights described above by emailing support@joindawn.com or by writing to the address in the Contact Us section below. We will respond to your request without undue delay and within forty-five (45) days of receipt. If reasonably necessary, we may extend the response period by an additional forty-five (45) days, provided we notify you of the extension and the reason for it.

You may also withdraw consent (where we rely on consent) by contacting us in the Contact Us section at the bottom of the main Privacy Notice.

Changes to This Notice

If we make material changes to this Notice, we will notify you by posting the updated Notice on our website with a revised effective date and, where required by applicable law, providing additional notice (such as by email or through the Dawn App). We encourage you to review this Notice periodically.

Contact Us

If you have any questions or comments regarding this Privacy Notice, please contact us at:

Sword Health, Inc.
ATTN: Privacy Office
169 Madison Ave
Suite 15501
New York, New York 10016

support@joindawn.com

Last Updated and Effective Date: September 1, 2026