PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
[Last Modified: March 15, 2026]
This CCPA Notice is an integral part of Sweetch Health Ltd. (Collectively with its affiliates and subsidiaries shall be referred to as “Company”, “we”, “us” or “our”) Privacy Policy and Terms of Service, and applies to California residents’ Personal Information, which we collect directly or indirectly while in our role as a Business operating our website. The California Consumer Privacy Act of 2018 together with any other applicable California privacy-related laws (“CCPA”), may apply to users of our services including our Application Users, our Customers, visitors of our website, and others who are California residents (“consumers” or “you”) visiting and using our website or using any of our Services, where and to the extent the CCPA applies. Unless otherwise defined herein, capitalized terms used in this CCPA Notice shall have the meanings assigned to them under the CCPA, the Privacy Policy, or the applicable Terms of Service governing the use of the Services, as the context requires.
PART I: A COMPREHENSIVE DESCRIPTION OF THE INFORMATION PRACTICES:
- Categories Of Personal Information
We collect Personal Information as defined under the CCPA, meaning information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device, as detailed in the table below. Personal Information may also include Sensitive Personal Information, which may include certain health-related information (“SPI”).
Personal Information does not include: publicly available information that is lawfully made available from government records, that a consumer has otherwise made available to the public; De-identified or aggregated consumer information; Information excluded from the CCPA’s or CPRA’s scope, such as: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.
Please see below a table detailing the categories of Personal Information that we collect (and has collected within the last 12 months) as a Business from visitors and users of our website:
| Category | Examples of Personal Information | Collected |
|---|---|---|
| A. Identifiers. | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers. | Yes. We collect identifiers such as name, email address, account credentials, and device identifiers when you create an account, interact with the website or Application, contact us, or otherwise use the Services. These identifiers are used for account management, authentication, service delivery, communications, and security purposes. We may use your contact info, subject to applicable law, to send you promotional emails and marketing content via email or SMS. You may withdraw consent at any time through the “unsubscribe” link within any email sent to you or by contacting us directly. |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. | Yes. When you subscribe to or purchase our Services we may collect billing and payment information, typically processed through third-party payment processors. Certain elements of this information may overlap with other categories listed in this table. |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | Yes. Certain health-related information voluntarily provided by users through the Application may fall within this category, such as information relating to health conditions or wellness indicators used in connection with the Services. |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Yes. We may collect information relating to subscriptions, purchases of Services, and related transactional data. |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | No. |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. | Yes. We collect information about interactions with our website and Application, including device logs, engagement with content, and usage analytics to operate and improve the Services. |
| G. Geolocation data. | Physical location, approximate location derived from IP address or movements. | Yes. We may collect approximate geolocation derived from IP address when you access the website or Application. In certain cases, precise location data may be collected subject to your device permissions. |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | Yes. When you use the Application or connect compatible devices or wearables, we may collect sensor-based signals generated by your device or connected equipment (such as accelerometer or gyroscope data) in order to measure activity levels, support functionality of the Services, and improve behavioral insights and personalization within the Application. |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | No. |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | No. |
| K. Inferences drawn from other personal information. | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | Yes. We may derive insights and inferences from other Personal Information collected through the Services, including usage patterns, behavioral signals, lifestyle inputs, and health-related information, in order to personalize the Services, generate recommendations, adapt digital coaching features, and improve the functionality of the Application. These inferences are used solely to support the operation and personalization of the Services. |
| L. Sensitive personal information. | Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life. | Yes. The Services process certain health-related and precise location information provided by users in order to deliver personalized wellness programs and recommendations. We do not use Sensitive Personal Information for purposes requiring the right to limit such use under the CCPA. |
- Disclosures Of Personal Information for a Business Purpose
We may disclose your Personal Information to a contractor or service provider for our business purposes. When we disclose Personal Information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except fulfilling the contract. In the preceding twelve (12) months, we disclosed the following categories of Personal Information for a business purpose:
| Category (corresponding with the table above) | Category of Recipient | Business Purpose | |
|---|---|---|---|
| 1 | Category A Category B Category C Category D Category F Category G Category H Category K Category L | Cloud computing and storage vendors. | Storage, hosting. |
| 2 | Government entities/Law enforcement. | Subject to a law requirement, such as tax authorities. | |
| 3 | Operating systems. | Operating the website and the Services. | |
| 4 | Category A Category B Category D | Clerance and Payment processors | Paying for our services. |
| 5 | Category A Category F Category G | Data analysis providers. | Providing analytic data on the use of our website and Services. |
| 6 | Category A Category B Category F Category G | Marketing & promotions providers, CRM providers, social networks, advertising networks. | Marketing, ad delivery, etc.. |
| 7 | Category A Category F | Security service providers. | Debugging, security, fraud prevention. |
- How We Collect Personal Information
We collect the Personal Information detailed above, in the following ways:
Directly from you. For example, when you create an account, register to use the Application, complete forms on the website, subscribe to our Services, contact us for support, respond to surveys or questionnaires, participate in wellness programs or assessments, or otherwise voluntarily provide information through the Services.
Automatically through your use of the Services. When you access or use the website or the Application, certain information is automatically generated and collected by our systems and technologies, including device information, system logs, usage data, interaction events, configuration data, and analytics information relating to your activity within the Services.
From devices, sensors, or connected equipment. Where the functionality of the Application relies on device capabilities or compatible wearable devices, we may collect sensor-based information generated by your device or connected equipment (such as accelerometer, gyroscope, motion, or activity-related signals) in order to measure activity patterns, enable the functionality of the Services, and generate behavioral insights and personalized recommendations.
From third-party services and integrations. If you choose to connect or authorize third-party services, platforms, or devices (for example health platforms, wearable device ecosystems, or other connected services), we may receive certain information from those providers in accordance with your authorization and the applicable permissions granted by you through those platforms.
Through marketing and advertising interactions. We may collect information regarding your interactions with our marketing campaigns, advertisements, or online content, including when you view, access, or interact with advertisements, websites, or promotional materials associated with the Services.
- Use Of Personal Information
We may use, or disclose the Personal Information we collect for one or more of the following business purposes:
To fulfill or meet the reason you provided Personal Information. For example, if you are a customer of our Services, to provide you with such Services, or when you contact us with an inquiry and share your name and contact information, we will use that Personal Information to respond to your inquiry, as well as for support, etc.
For security and fraud detection purposes, monitoring and maintaining the safety, security, and integrity of our website and Services.
To improve our services, which includes but not limited to, analyze which types of ads should be provided as part of the website; analyzing your use of the website and Services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your Personal Information or as otherwise set forth in the Privacy Policy.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you with notice.
- Sale Of Personal Information
In the preceding twelve (12) months, we do not “sell” information as most people would commonly understand that term, we do not, and will not, disclose your Personal Information in direct exchange for money or some other form of actual payment. We may “share” Personal Information for “interest-based advertising” or “cross-context behavioral advertising”. The CCPA defines “sharing” as “communicating orally, in writing, or by electronic or other means, a consumer’s Personal Information” to “a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration”. In other words, we may share your Personal Information with a third party to help serve personalized content or ads that may be more relevant to your interests, and to perform other advertising-related services such as enabling our partners to serve such personalized content.
In the preceding twelve (12) months, we “sell” or “share” the following categories of Personal Information shared with third parties:
| Category (corresponding with the table above) | Category Recipient | Purpose of Sale or Share |
|---|---|---|
| Category A Category F Category G | Ad-network and advertising partners. | Sale/Share for cross-context behavioral advertising. |
Please note that we will never Share or Sale Sensitive or Health-related data with a third party, unless such sharing is permitted under law, and after having proper contractual arrangements in place, ensuring, inter alia, that such data will not be used by such third party for marketing or any other unlawful purpose (unless authorized to do so under law, e.g., per your consent).
- Data Retention
In general, we retain the Personal Information we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulations, or until you express your preference to opt-out, where applicable.
The retention periods are determined according to the following criteria:
For as long as it remains necessary in order to achieve the purpose for which the Personal Information was initially processed. For example, if you contacted us, we would retain your contact information at least until we address your inquiry.
To comply with our regulatory obligations. For example, transactional data will usually be retained for seven years as part of termination of engagement (or even more under certain circumstances) for compliance with our bookkeeping obligations purposes.
To resolve a claim, we might have a dispute with you, including any legal proceeding between us, until such dispute is resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.
We retain Personal Information only for as long as reasonably necessary to fulfill the purposes described in this Notice, unless a longer retention period is required or permitted by law.
- Amendments
As required under the CCPA, we will update this Privacy Notice every 12 months. The last revision date will be reflected in the “Last Modified” heading located at the header of the Privacy Notice.
- Children Under Age 16
We do not knowingly collect information from children under the age of 16 residing in California.
PART II: EXPLANATION OF YOUR RIGHTS UNDER THE CCPA AND HOW TO EXERCISE THEM
- Users’ Rights
If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law, all as detailed herein and in the Data Subject Request Form available HERE.
| California Privacy Right | Details |
|---|---|
| The right to know what Personal Information the business has collected. | The right to know what Personal Information the business has collected about the consumer, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom the business discloses Personal Information, and the specific pieces of Personal Information the business has collected about the consumer. |
| Deletion rights. | The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions. |
| Correct inaccurate information | The right to correct inaccurate Personal Information that a business maintains about a consumer. |
| Opt-Out of sharing for cross-contextual behavioral advertising | You have the right to opt-out of the “sharing” of your Personal Information for “cross-contextual behavioral advertising”, often referred to as “interest-based advertising” or “targeted advertising”. |
| Opt-out from selling | the right to opt-out of the sale or sharing of Personal Information by the business. |
| Limit the Use or Disclosure of SPI | Under certain circumstances, If the business uses or discloses SPI, the right to limit the use or disclosure of SPI by the business. |
| Opt-out of the use of automated decision making | In certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your Personal Information. |
| Non-discrimination | The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicants, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information. |
| Data portability | You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format. |
To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.
- How Can You Exercise the Rights?
We provide option to opt out of Sharing for Cross-Contextual Behavioral Advertising or Selling Personal Information by using the following opt-out options:
Use the “Do Not Sell or Share My Information” or “Reject All” option through the cookie setting tool available on our Site.
- To opt out from cross contextual ads you can further use these links:
Network Advertising Initiative’s (“NAI”) HERE;
Digital Advertising Alliance’s (“DAA”) HERE Or the European Interactive Digital Advertising Alliance (“EDAA”) HERE;
California and Colorado residents that wish to opt-out from having your data used for interest-based advertising, you may exercise your right here: https://optout.privacyrights.info/.
We honor Global Privacy Control (GPC) signals where such signals are recognized as a valid request to opt-out of the sale or sharing of Personal Information.
Other rights may be exercised by using the Data Subject Request Form HERE and sending it to us by email at: support@sweetch.com. The instructions for submission, the general description of the process, verification requirements, when applicable, including any information the consumer or employee must provide are all detailed therein.
- Authorized Agents
“Authorized Agents” may submit opt out requests on a consumer’s behalf. If you have elected to use an authorized agent, or if you were an authorized agent who would like to submit requests on behalf of a consumer, the following procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer. Usually, we will accept requests from qualified third parties on behalf of other consumers, regardless of either the consumer or the authorized agent’s state of residence, provided that the third party successfully completes the following qualification procedures:
- When a consumer uses an authorized agent to submit a request to know or a request to delete, a business may require that the consumer does the following:
Provide the authorized agent signed permission to do so or power of attorney.
Verify their own identity directly with the business.
Directly confirm with the business that they provided the authorized agent with permission to submit the request.
- A business may deny a request from an authorized agent that does not submit proof that they have been authorized by the consumer to act on their behalf.
- Notice Of Financial Incentive
We do not offer financial incentives to consumers for providing Personal Information.
PART III: OTHER CALIFORNIA OBLIGATIONS
- Direct Marketing Requests:
California Civil Code Section 1798.83 permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please use the Data Subject Request Form available HERE.
- Do Not Track Settings:
Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we so not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.
- California’s “Shine the Light” law (Civil Code Section § 1798.83):
Permits California residents to request information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send us the Data Subject Request Form available HERE.
CONTACT US:
By email: support@sweetch.com
By Mail: 5 Jabotinsky St. Ramat Gan, Israel