Last Updated: Oct 12, 2026 (Revision for the Women’s Health and Fertility Tracking Feature; new front-section “About the Controller of Your Personal Data”)

Effective Date: Oct 12, 2026

Version: 1.4.0

You can view this Privacy Policy in the RingConn App and/or at the bottom of our website at https://www.ringconn.com.

0. About the Controller of Your Personal Data

Onovo Technology (Hong Kong) Limited (“Onovo”) is the controller of your personal data in the RingConn app. Onovo is wholly owned (100%) by Shenzhen Ninenovo Technology Limited (“Ninenovo”), and the two companies are affiliates within the same corporate group.

If you are an existing user (you registered and used the RingConn app before the controller change): as part of an intra-group restructuring, the controller of your personal data changed from Ninenovo to Onovo, and your existing data was transferred from Ninenovo to Onovo.

If you are a new user (you registered after the controller change): Onovo has been the controller of your personal data since your registration, and your data is provided by you directly and/or collected as described in Section 2 of this Policy.

In either case, Ninenovo continues to provide development, technical support, and operation and maintenance services for the App as Onovo’s processor (service provider), and processes your personal data only on Onovo’s documented instructions and not for its own purposes (see Sections 7 and 8 of this Policy). The purposes for which your data is used remain the same, and your rights under this Policy and the ways to exercise them are not affected.

• Controller identity and contact details: ONOVO TECHNOLOGY (HONG KONG) LIMITED, Storeroom 2, 7/F, Block B, Wah Tat Industrial Centre, 8 Wah Sing Street, Kwai Chung, Hong Kong; Data Protection Officer (DPO): dpo@ringconn.com; Customer Support: cs@ringconn.com.

• EU Representative (GDPR Art. 27): Bird & Bird GDPR Representative Services SRL, Avenue Louise 235, 1050 Bruxelles, Belgium; email: RingConn@twobirds.com.

• UK Representative (UK GDPR): Bird & Bird GDPR Representative Services UK, 12 New Fetter Lane, London, EC4A 1JP, United Kingdom; email: RingConn@twobirds.com.

• Source of your data (GDPR Art. 14(2)(f)): your existing data was received from the previous controller, Ninenovo (internal restructuring transfer); if you registered afterwards, your data is provided by you directly and/or collected as described in Section 2 of this Policy.

• Your rights: you have the rights of access, rectification, erasure, data portability, withdrawal of consent, and objection to or restriction of processing; please see Sections 10 and 11 of this Policy for these rights and how to exercise them. You also have the right to lodge a complaint with the supervisory authority in your jurisdiction.

This Privacy Policy covers:

0. About the Controller of Your Personal Data (see front section)

1. Introduction and Important Notices

2. Data We Collect

3. How We Use Your Data

4. Special Terms for the Blood Pressure Trends Feature

5. Special Terms for Sleep PRO (Lab Version)

6. Automated Processing, Algorithmic Transparency, and Health Insights

7. How We Share and Disclose Data

8. Data Storage and Transfers

9. Data Retention and Security

10. Your Rights

11. Terms for Users in the European Union / EEA / United Kingdom

12. Terms for California Residents

13. Special Notice Regarding U.S. Consumer Health Data

14. Terms for Users in Japan

15. Our Policy Regarding Children

16. Cookies, SDKs, and Similar Technologies

17. Updates to This Privacy Policy

18. Contact Us

1. Introduction and Important Notices

1.1 Introduction

ONOVO TECHNOLOGY (HONG KONG) LIMITED and its affiliates (collectively, “RingConn,” “we,” or “us”) understand the importance of privacy and personal data to our customers.

Our affiliate, Shenzhen Ninenovo Technology Limited, is responsible for the development, technical support, operation, and maintenance of the RingConn App. See Sections 7 and 8 of this Policy for information about processing on our behalf and cross-border remote access. For a consolidated explanation of the data controller change (including the controller’s identity, contact details, EU/UK representatives, and your rights), please see the front-section “About the Controller of Your Personal Data” of this Policy.

This Privacy Policy is intended to help you understand what data we collect, why we collect it, how we process, store, and protect it, and how you can update, manage, export, and delete your data. Please take the time to read this Policy carefully.

This Privacy Policy applies to personal data that we collect and process through our “Services,” including our RingConn devices (“Devices”), applications (“Apps”), websites, software, application programming interfaces, emails, newsletters, and other services.

This Policy applies to users of the overseas version of the RingConn App. Users in mainland China should use the RingConn Health App; the privacy policy published in the RingConn Health App governs the processing of their personal information.

If a particular product or service has a separate privacy policy, health data notice, or user service agreement, that policy or agreement will govern that product or service. This Policy will govern any matters not covered by that separate policy or agreement. This Policy also applies where an affiliate uses a product or service we provide in its own product or service and has not adopted a separate privacy policy. Unless otherwise stated, terms used in this Policy have the same meanings as those defined in the RingConn App Terms of Use.

Please note that this Policy does not apply to information collected by other means, such as offline channels or any other website operated by the company or a third party. In addition, third-party applications or content (including advertisements) that may link to or be accessible from this website are not covered by this Policy. This Policy is not intended to replace any contractual terms between you and us or any rights you may have under other applicable data privacy laws. Please take time to familiarize yourself with our privacy practices. If you have any questions or concerns, contact us at dpo@ringconn.com.

1.2 Important Notices

1. Health Data and Sensitive Personal Information: RingConn products and Apps may collect or generate information relating to your health, physical condition, or lifestyle habits where based on your consent or necessary for performance of a contract, such as heart rate, blood oxygen, sleep status, skin temperature, activity information, stress and recovery metrics, weekly health reports, Blood Pressure Trends data (including vascular load, blood pressure records, calibration/assessment records, and related questionnaire responses), and Sleep PRO (Lab version) data.

• Under the laws of the European Union, European Economic Area, and United Kingdom, some of the information described above may constitute “health data” or other special-category personal data. Under the laws of certain U.S. states, it may also constitute “consumer health data” or “sensitive personal information.”

• We will process this information only as permitted by law and will obtain your explicit consent where required.

• Terminology: In this Policy, “separate consent” means express consent that we obtain from you separately and for each specific processing activity (such as processing sensitive personal information or collecting or sharing consumer health data), as required by China’s Personal Information Protection Law and laws of certain U.S. states, including Washington’s My Health My Data Act and Nevada SB 370. “Explicit consent” means consent obtained through your clear affirmative action to the processing of special-category personal data, such as health data, in the context of Article 9(2)(a) of the GDPR/UK GDPR. We use these terms consistently with these meanings below.

2. Special Notice for the Blood Pressure Trends Feature: Blood Pressure Trends is an optional feature that involves in-depth processing of health data, including questionnaire information, blood pressure data that you enter manually, PPG signals collected by the Ring, accelerometer data, skin temperature, activity information, and algorithm-generated analysis results. Before you first use this feature, we will obtain your explicit consent through a separate screen, an unchecked checkbox, a confirmation button, or another affirmative action. The feature is available only to adults aged 18 or older. It involves processing special-category health data and is subject to the special terms in Section 4 of this Policy and the detailed provisions of the appendix, “RingConn Blood Pressure Trends Feature Privacy Agreement.” This feature and all assessment statuses are not intended for disease diagnosis or treatment, or to provide medical advice. If you feel unwell, consult a qualified medical provider promptly.

3. Special Notice for Sleep PRO (Lab Version): Sleep PRO (Lab version) is an optional beta feature available only to certain users. You must apply through the RingConn Lab feature and be approved and granted access before using it. The feature uses PPG signals collected by the Ring, together with multiple physiological signals such as heart rate, heart rate variability, blood oxygen, and movement, and applies an optimized sleep-staging algorithm to provide a more detailed analysis and reconstruction of your sleep throughout the night, including sleep stages, sleep onset and wake detection, and micro-awakening detection. The feature processes your health data (sleep-related physiological data). Before you first apply to use it, we will obtain your explicit consent through a separate screen, an unchecked checkbox, a confirmation button, or another affirmative action. The feature involves processing special-category health data and is subject to the special terms in Section 5 of this Policy and the detailed provisions of the appendix, “RingConn Sleep PRO (Lab Version) Privacy Agreement.” This feature is not intended for disease diagnosis or treatment, or to provide medical advice. If you feel unwell, consult a qualified medical provider promptly.

4. Special Notice for RingConn Partner+: RingConn Partner+ is a value-added service within the RingConn App, available only to users outside mainland China. Its core benefit is ten times the usage allowance for AI Health Insights / AI Health Chat. The feature processes ordinary personal information such as plan orders, transaction status, benefit status, and order matching to your user ID. AI Health Insights may use health data you have authorized and health reports, trends, metrics, or records generated by the RingConn App, and may therefore involve sensitive personal information such as health data. We will make the RingConn Partner+ Terms of Service and RingConn Partner+ Privacy Agreement available on the purchase page and/or the feature-use page.

5. Payment Notice: Purchases, charges, cancellations, refunds, and plan management for RingConn Partner+ are handled through the App Store or Google Play. RingConn does not collect or store your bank card number, credit card number, payment account password, or complete payment credentials; we receive and process only transaction identifiers, plan status, and order-related information necessary to verify plan status, grant benefits, investigate missing orders, provide customer support, and handle disputes.

6. Special Notice for the AI Chat Feature: RingConn Partner (AI Chat) / RingConn Partner AI Chat is an optional AI health assistant and health-information interpretation feature. It may be accessed through the Partner icon in the upper-left corner of the Awareness page, Suggested Questions, AI Insights, Women’s Health AI Chat, web-search answers, or other entry points. Because this version does not yet display a separate AI Chat privacy agreement pop-up, the relevant personal-data processing rules are set out in this App Privacy Policy. When you first enable or enter the feature, we will obtain your separate consent / explicit consent on the “Legal Summary” / feature activation confirmation screen to import and process health data, consumer health data, and other sensitive personal information. When you first enter the AI Chat interface and during the conversation, clear interface labels and text will inform you that you are interacting with an artificial intelligence system, not a human. The feature uses RingConn App data that you authorize to provide a personalized health experience. Specifically, AI Chat obtains necessary data from the data you have authorized based on your chat instructions: it accesses only data relevant to your current question when you ask a question or the feature is triggered (for example, periodic generation of Suggested Questions); it does not load all of your health data when you enable the feature. We retain data-access logs (including the trigger time and scope of data accessed) as a record of how the on-demand access mechanism operates. The data may include health scores and their component metrics, activity and tags, profile information, health records, algorithm-generated metrics, weekly health report data (such as weekly summary metrics for sleep, activity, steps, calories, and stress), Blood Pressure Trends and related blood pressure data (such as vascular load, blood pressure records, calibration periods, Blood Pressure Trends factors, questionnaire responses, and related assessment records). Blood pressure data is not available in Japan: AI Chat for users in Japan does not connect to or process any blood pressure data; if users in Japan ask about blood pressure, AI Chat will not interpret the question and will only state that blood pressure-related AI services are not currently available in their region. The data may also include your interactions with AI Chat. AI responses are for informational, educational, and everyday health-management reference only; they do not constitute medical advice, diagnosis, treatment, disease prevention, or medication advice.

7. AI Chat Data Use Restrictions: Under the current product design, data involved in AI Chat is processed only as necessary to provide the current feature and is not used for algorithm optimization, model training, research analysis, or product iteration. Unless we notify you separately and obtain your separate consent / explicit consent where required by applicable law, we will not use health data that identifies you, chat records, user questions, AI outputs, or feedback for model training, algorithm optimization, research analysis, or product iteration that is not directly necessary to provide the current AI Chat feature.

8. Non-Medical Use Notice: Unless we expressly state otherwise and obtain the applicable regulatory approval, RingConn products and services are not intended to be used as medical devices, medical diagnostic tools, or treatment tools. Sleep, stress, recovery, heart rate, blood oxygen, Blood Pressure Trends, Sleep PRO (Lab version), and other health information displayed in the App is for health-management and lifestyle reference only and should not replace the advice, diagnosis, or treatment of a physician or other qualified medical professional.

9. Prominent Disclaimer Principle: All disclaimers and limitations for health features will be displayed on the same screen as the feature description and will not be provided solely in a footnote or through a link.

10. Special Notice for Wellness Squad: Our Wellness Squad feature (called “Wellness Squad” in the overseas English version) is an optional extension available to all adult users. It allows you to invite other users to share health data in three ways: (1) a one-time invitation link, which you control; (2) RingConn ID search, which is enabled by default, meaning other users can search for your RingConn ID (only your RingConn ID, username, and profile photo are exposed) so that they can more easily find you and send a sharing invitation. You can disable this feature at any time in the App (path: Wellness Squad > Settings > RingConn ID Search Visibility); once disabled, other users will not be able to find you by searching your RingConn ID; or (3) a one-time invitation code (an eight-character alphanumeric combination). Each invitation code expires three days after it is generated and becomes invalid after it is used once by one friend. You may generate no more than 15 invitation codes in any 24-hour period. You may have sharing relationships with up to five friends at a time, and each friend may accept data from up to five users at a time. This feature is available only to users aged 18 or older. Establishing a friend relationship requires sharing your profile photo, nickname, and RingConn ID. You select any additional data to share. The available metrics include sleep data (total sleep time, sleep efficiency, sleep heart rate, and blood oxygen saturation during sleep); stress (stress level and total stress duration); vital signs (heart rate, blood oxygen, and heart rate variability); activity (total calories burned, steps, and all-day activity intensity); health alerts (headache signs, abnormal vital signs, and sun-exposure/dehydration alerts); and reports (weekly health reports and comprehensive sleep apnea risk assessment reports). Blood Pressure Trends data (vascular load and blood pressure records) and Sleep PRO (Lab version) data (sleep stages, sleep onset and wake times, number and level of micro-awakenings, and sleep continuity and stability metrics) have separate sharing toggles and are shared only if you actively enable them, even if you have already enabled Wellness Squad. To protect your privacy, before a friend relationship is established, the other person can see only the names of your sections and metrics, not their values; after the relationship is established, the other person can view only the data within the scope you selected to share. You must confirm each time you share data with a new friend. After the recipient accepts an invitation, if you have enabled the “I must confirm after a friend accepts an invitation” setting, you must provide a second confirmation within 48 hours or the invitation will expire automatically. You can manage shared data and notifications for friends’ health alerts and reports, or stop sharing, at any time by tapping the relevant friend’s profile photo on the Wellness Squad main page to open their details page. This feature is available only to users aged 18 or older.

11. No Sale of Personal Information: We do not sell your personal information. We also do not share your sensitive health data or consumer health data for cross-context behavioral advertising. If we plan to engage in processing that may be considered a “sale” or “sharing” under applicable law, we will provide the required notice and opt-out mechanism and obtain your consent where required by law.

12. Special Notice for the Women’s Health and Fertility Tracking Feature: The Women’s Health feature (Period Tracking / Fertility Tracking) is optional. Following the redesign in version 4.5.0, the feature involves in-depth processing of sensitive personal information related to reproductive health, including: basic questionnaire information (date of birth [synchronized bidirectionally with the primary App account], average menstrual cycle length, period duration, cycle regularity, start date of the most recent period, and medical conditions); fertility questionnaire information (how long you have been trying to conceive, conception-related history, and contraceptive methods used in the past six months); period records; symptom records (including ovulation status, intimacy details, vaginal discharge, unusual bleeding, tobacco and alcohol consumption, and physical changes, among 23 categories, as well as free-text notes); intimacy logs and reminders; pregnancy status; skin temperature collected by the Ring; previous-day sleep; exercise duration over the past seven days; previous-day stress; and algorithm-generated period predictions, Body Readiness assessments, health analysis, and cycle statistics. This information may constitute health data, reproductive health data, or sensitive personal information / special-category personal data related to sex life. Before you first use the feature or upgrade to version 4.5.0, we will obtain your explicit consent through a separate screen, an unchecked checkbox, a confirmation button, or another affirmative action. The feature is available only to users aged 18 or older. In Fertility Tracking mode, you may share Body Readiness, a cycle overview, today’s symptoms, key recommendations, intimacy logs, and intimacy reminders with your partner through a one-time invitation link. In addition, after you manually set the “I’m pregnant” status marker, the system will send your partner a pregnancy notification (see Section 1.5 of the appendix). You may stop sharing unilaterally at any time without your partner’s confirmation. The feature is subject to the relevant sections of this Policy and the detailed provisions of the appendix, “Women’s Health and Fertility Tracking Privacy Policy.” This feature is not intended for disease diagnosis or treatment, medical advice, or contraception guidance. If you feel unwell, consult a qualified medical provider promptly.

Language Versions: This Policy is available in multiple languages. If the English version differs from or conflicts with another language version, the English version will prevail to the extent permitted by applicable law; however, if the law of your place of residence requires a local-language version to prevail, that requirement will apply.

2. Data We Collect

For a field-level description of the personal information we collect, please see the RingConn App Personal Information Collection List.

When you use our products, Apps, or services, we collect the following types of data.

2.1 Information We Collect from You

Account and Profile Information: When you create an account, you must provide a username (no real-name requirement), date of birth (year, month, and day), gender (female, male, or prefer not to say), height, weight, email address, mobile phone number, password, and country/region. You may also choose to add a profile photo.

Health and Wellness Features

1. Women’s Health (Menstrual Cycle Tracking, including “Period Tracking / Fertility Tracking”): If you activate this feature and have provided your consent, we collect the following information:

• Basic questionnaire information: date of birth [synchronized bidirectionally with the primary App account], average menstrual cycle length, period duration, cycle regularity, start date of the most recent period, and medical conditions (such as polycystic ovary syndrome, endometriosis, and thyroid disorders);

• Fertility questionnaire information: how long you have been trying to conceive, conception-related history, contraceptive methods used in the past six months, and similar information;

• Period records: menstrual cycle timelines, period start and end dates, and other period records (which you may enter, add, edit, or delete within the calendar range);

• Symptom records: ovulation status; intimacy details (sexual activity, contraceptive measures, orgasm, sexual desire, and similar information); menstrual flow, menstrual blood color, clots, menstrual pain severity, vaginal discharge, mood, interests, physical sensations, physical changes, custom symptoms, nutritional supplements and medications, unusual bleeding, tobacco and alcohol consumption, changes in appetite, and 23 other categories of symptom options; and free-text notes;

• Intimacy logs and reminders: information about intimacy that you record manually and reminders you set (which you may add, edit, or delete). In Fertility Tracking mode with a linked partner, your partner may also record intimacy, and the records will be synchronized between you;

• Pregnancy status: pregnancy status that you set;

• Device sensor and derived data: skin temperature and related sensor data and derived data from the RingConn Device used for Body Readiness assessments, such as previous-day sleep, exercise duration over the past seven days, and previous-day stress; and algorithm-generated derived data such as period predictions, Body Readiness assessments, health analysis, and cycle statistics;

• Feature usage records: records of usage activities such as enabling or disabling features and switching modules (collected through Sensors Data analytics and processed in pseudonymized form linked to your user ID, without the content of identifiable health data).

2. Sleep Apnea Risk Monitoring (OSAHS): If you enable this feature and have provided your consent, we collect data such as height, weight, BMI, gender, age, neck circumference, medical history, sleep quality, and symptoms related to OSA.

3. Blood Pressure Trends: This feature is available only to adults aged 18 or older. If you use Blood Pressure Trends, with your explicit consent, we collect the following additional information:

• Questionnaire information: your gender, date of birth, height, weight, blood pressure status (normal, high, low, or uncertain), whether you have taken blood pressure medication in the past 30 days, family history of high blood pressure, and whether you have been diagnosed with certain conditions (such as stroke, coronary heart disease, heart failure, atrial fibrillation, sleep apnea, hyperlipidemia, or diabetes).

• Calibration and assessment activity information: activity tags you select before calibrating or assessing vascular load (such as eating, drinking alcohol, exercising, mood fluctuations, or taking blood pressure medication) or custom activity information.

• Manually entered data: systolic and diastolic blood pressure readings that you measure with a blood pressure monitor and enter manually.

• Important Notice: The collection and storage of the health information described above, including but not limited to data for Blood Pressure Trends, may involve processing your special-category personal data (health data). Under the GDPR and CCPA-related requirements, we process such data only with your explicit consent. Consent is obtained through a separate screen and an affirmative checkbox and may not be preselected. You may withdraw your consent at any time in the App settings. After withdrawal, we will stop collecting new data and handle existing data in accordance with Section 9.1 of this Policy and the appendices.

4. Sleep PRO (Lab Version): If you apply for and are granted access to Sleep PRO (Lab version), with your explicit consent, we collect the following additional information:

• Basic information: your user ID, phone model, mobile operating system, operating system platform, and similar information;

• Physiological data: multiple physiological signals collected by the Ring, including PPG signals, heart rate, heart rate variability, blood oxygen, and movement;

• Analysis results: sleep stages (awake/light/deep/REM), sleep onset and wake times, number and level of micro-awakenings (low/medium/high), and sleep continuity and stability metrics;

• Device computing information: to run the sleep algorithm, the App uses your phone’s GPU to calculate sleep data, which may slightly increase your phone’s power consumption.

• Important Notice: Sleep PRO (Lab version) involves processing your health data (sleep-related physiological data). Under the GDPR and CCPA-related requirements, we process such data only with your explicit consent. Consent is obtained through a separate screen and an affirmative checkbox and may not be preselected. You may withdraw your consent at any time in the App settings. After withdrawal, we will stop collecting new data and handle existing data in accordance with Section 9.1 of this Policy and the appendices.

5. Other Health Features: You may choose to enter other health-related information, such as your daily stress level, mood, or health-related notes. Depending on the specific features you use, we may also collect:

• Exercise feature data: If you use the exercise logging feature, we may collect information such as exercise type, exercise intensity (RPE), distance, start and end times, calories burned, and location (if authorized). If you use the cardiorespiratory fitness estimation feature, we may collect information such as your weekly exercise habits, running ability, medical history, and symptoms;

• Health alert data: If you use the health alert feature, we may collect information such as the date and time of headache symptoms, headache severity, symptoms, contributing factors, symptom notes, and location (if authorized);

• Plan feature data: If you use the plan feature, we may collect information such as plan name, category, frequency, recurrence cycle, target time, reminder settings, planned bedtime and wake time, planned daily sleep duration, planned daily moderate-to-vigorous activity duration, and planned number of exercise days per week.

User Communications: When you contact us or participate in feedback, surveys, contests, or promotional activities, we collect the information you submit, such as your name, contact information, and message content.

2.2 Information Generated and Collected Automatically

As part of our core services, your RingConn Device and mobile App automatically generate and collect a broad range of health and device-related data, including:

RingConn Device Data: The RingConn smart ring uses built-in sensors (such as PPG [optical] sensors, accelerometers, temperature sensors, and SpO₂ sensors) to collect raw measurement data. These measurements are used to estimate and generate a range of biometric and activity data, including:

1. Sleep tracking data: sleep stages, duration, quality, and related vital signs (such as heart rate, respiratory rate, skin temperature, and blood oxygen levels during sleep).

2. Heart rate and heart rate variability (HRV): real-time heart rate, heart rate variability, and trends over time.

3. Blood oxygen (SpO₂): blood oxygen levels, particularly during sleep.

4. Respiratory rate: respiratory rate during sleep or rest.

5. Stress and recovery metrics: data related to stress detection and stress-management recommendations.

6. Daily activity and health overview: steps, active minutes, calories burned, activity intensity, and sedentary behavior.

7. Vital sign monitoring: including skin temperature trends and fluctuations.

8. Periodic health reports: based on the metrics collected, the App may generate personalized weekly, monthly, or annual health reports summarizing your sleep, activity, readiness, and overall health trends.

9. Blood Pressure Trends Data:

• Vascular load data: When you use Blood Pressure Trends for calibration or assessment, the Ring collects data through its PPG sensor and accelerometer. An algorithmic model analyzes the data to generate the “vascular load” metric used to describe blood pressure status and related qualitative assessment statuses (such as stable, slight change, or significant change).

• Related factor data: To assess your blood pressure status comprehensively, the system combines PPG and accelerometer data collected by the Ring to generate related factors such as “circadian rhythm adaptation,” “sleep respiratory health,” “post-exercise vascular recovery,” and “all-day vascular stability.”

• Processing Notice: Processing of the Blood Pressure Trends data described above is based on your explicit consent. Apart from processing necessary to provide the feature, processing for feature optimization and algorithm iteration will be subject to a separate consent choice. See the appendix to this Policy for detailed processing rules.

• Important Notice: This data is for everyday lifestyle reference only and does not constitute medical advice. If you feel unwell, seek medical attention promptly regardless of what the data indicates.

10. Sleep PRO (Lab Version) Data:

• Sleep PRO data: When you use Sleep PRO (Lab version), the Ring collects data through its PPG sensor, accelerometer, temperature sensor, and other sensors. An optimized sleep-staging algorithm analyzes the data to generate sleep stages (awake/light/deep/REM), sleep onset and wake detection, the number and level of micro-awakenings (low/medium/high, displayed in different colors), and sleep continuity and stability metrics.

• Processing Notice: Processing of the Sleep PRO (Lab version) data described above is based on your explicit consent. Apart from processing necessary to provide the feature, processing for feature optimization and algorithm iteration will be subject to a separate consent choice. See Section 5 and the appendix to this Policy for detailed processing rules.

11. App Data

1. Device and system information: device identifiers, synchronized RingConn Device data, mobile operating system version, system language, browser type, and IP address.

2. App usage and activity logs: interactions with App features, navigation behavior, search history, and user-generated content.

3. Performance data: diagnostic logs, system crash reports, performance statistics, and feature usage analytics.

4. User behavior analytics data: To conduct user research, optimize products, and improve user experience, we use the Sensors Data platform to collect your in-App behavior data, including page-view paths, clicks, feature usage frequency, time spent, and page navigation paths. This data is pseudonymized and linked to your user ID. It is not used for targeted advertising or profiling and is used only to analyze user behavior patterns and improve product design and feature experience. To send product research surveys, feature testing invitations, or product-improvement notices, we may use your user ID to segment behavior data and contact you through App push notifications, email, or other means. If you do not wish to receive this targeted content, you may exercise your right to object through the opt-out link in the email, the App notification settings, or by emailing dpo@ringconn.com. For users in the EU/EEA/UK, we will obtain your consent before conducting in-App behavior analytics, and consent is the legal basis for that processing. For users in other regions, this processing is based on our legitimate interests (improving service quality and user experience) or on your consent where required by applicable law.

Location data: If you enable Bluetooth and location access, some operating systems require the App to obtain location permission before it can scan for or connect to Bluetooth devices. In this case, we use the location permission only for device connection, Find My Ring, and data synchronization. We collect approximate or precise location data and, unless otherwise stated, do not continuously track your precise location. This data may be collected through GPS, Wi-Fi, or network-provider data and is collected only with your consent. We will not collect or use precise location data without your express permission. You may revoke permission or disable location access at any time in your device settings. We may also infer an approximate location from your IP address to optimize regional services.

Special Notice (Find My Ring): Location information involved in Find My Ring is sensitive personal information. We collect it only with your authorization and solely to locate your Ring; it is not used for any other purpose.

Third-Party SDK Data: Integrated SDKs may collect device parameters, App logs, and limited analytics data as needed for their operation. Some SDKs may request access to the device’s MAC address. RingConn does not authorize or encourage third parties to collect unnecessary or sensitive device-level data. Information about apps installed on your mobile device is used only to detect whether Google Health Connect is installed and authorized when you use the Google Health Connect data-sync feature; third-party SDKs do not read your complete list of installed apps (see the special notice in Section 7 of this Policy).

2.3 Information from Third Parties

When you choose to log in through or integrate with a third-party account or platform, we may collect information from that third party:

Login providers: If you log in with or link a Google or Apple account, we receive the following data from those services, depending on your authorization: - Google: third-party account ID, display name, and profile photo; - Apple: stable user identifier provided by Apple (user/identifier), name/nickname, and email address. Health platforms and integrations (if supported): You may choose to synchronize RingConn data with third-party health platforms such as Apple Health or Google Fit. In that case, we may receive or share certain health metrics according to your permissions and settings on those platforms and the scope of your authorization.

2.4 Customer Service Information

When you use the online customer service feature in our App, we collect and use the following information to verify your identity and efficiently identify and resolve the issue you encounter:

1. Account identification information: your RingConn user ID and device serial number (SN).

2. Basic profile information: the name you have set for yourself and your contact email address.

3. Device information: the type of Ring you use.

4. Communications: the complete record of your communications with customer service, including your description of the issue and any screenshots or other files you provide.

This information is necessary to provide customer support and helps us quickly understand your issue and provide an accurate solution. Depending on the communication method you use, we may also access your photo library, camera, or microphone to enable you to send images, videos, or voice messages.

2.5 RingConn Partner+ Value-Added Services and AI Health Insights Data

When you access, try, purchase, renew, cancel, restore, or manage RingConn Partner+, we may process the following information: the region associated with the Google/Apple account used on your phone, product ID, plan name, price, currency, billing period, promotional information, RingConn order number, plan status, purchase date, renewal date, expiration date, order number or transaction ID, product ID, transaction status, and RingConn user ID. This information is used to display available plans, determine regional pricing, initiate purchases, verify plan status, grant and restore benefits, identify duplicate activations or missing orders, provide customer support, and handle disputes.

To provide RingConn Partner (AI Chat) / AI Health Insights, we may process health data collected or generated by the RingConn Device, health metrics in the App, health reports, trends, records, and questions and context you submit in AI Chat, within the scope you have authorized and separately consented to. This data may constitute health data, consumer health data, or sensitive personal information. We will not use health data that identifies you for model training, algorithm optimization, research analysis, or product iteration that is not directly necessary to provide the current feature, unless we notify you separately and obtain your separate consent / explicit consent where required by applicable law.

2.6 RingConn AI Chat Data

When you enable or use the AI Chat feature, we may process your questions, conversation context, chat history, AI responses, reference sources, likes/dislikes/feedback, records of actions such as delete/copy/stop generating, AI Chat entry point, usage allowance consumption, error logs, style settings, health-profile settings, long-term memory selections, and language and region information.

Within the scope you have authorized, AI Chat may process health data collected or generated by the RingConn Device and data recorded in the App or generated by algorithms, including sleep, activity, stress, vital signs, OSA, Women’s Health, Blood Pressure Trends, exercise, weekly health reports, and wellness summaries (Blood Pressure Trends and related blood pressure data are not available in Japan: AI Chat for users in Japan does not connect to or process any blood pressure data). This information may constitute health data, consumer health data, or sensitive personal information.

Data access method: Based on your chat instructions, AI Chat obtains necessary data from the data you have authorized. It accesses only data relevant to the current question when you submit a question or the feature is triggered (for example, periodic generation of Suggested Questions); it does not load all of your health data when you enable the feature. We retain data-access logs (including the trigger time and scope of data accessed) as a record of how this mechanism operates.

AI Chat involves importing and automatically processing extensive health data, consumer health data, and other sensitive personal information. Because this version does not yet display a separate AI Chat privacy agreement pop-up, we will obtain your separate consent / explicit consent to the processing of sensitive personal information through a revision to the App Privacy Policy, the “Legal Summary” / activation confirmation screen at the feature entry point, and an affirmative confirmation method that is not preselected. The confirmation text is: “I have read the rules in the RingConn App Privacy Policy concerning the processing of personal information for RingConn Partner (AI Conversations), and separately consent to RingConn importing and processing my health data, consumer health data, and other sensitive personal information (excluding blood pressure-related data in Japan), including the Weekly Health Report data, Blood Pressure Trends, and blood pressure-related data I have authorized, within the scope of my authorization, to provide AI Conversations, Suggested Questions, AI Insights, Women’s Health AI Questions and Answers, Web Search Answers, conversation history, and continuous-context experiences.” The button text is “Agree and Continue.” If a checkbox is used, it must be unchecked by default; the feature must not be enabled until the user confirms. We will retain the version of the consent, time, account identifier, and action record. If you refuse or withdraw consent, this will not affect the basic functions of the RingConn App, but you may not be able to use RingConn Partner (AI Chat), Suggested Questions, AI Insights, personalized health interpretations, chat history, or related features. We will supplement or update the separate AI Chat privacy notice / pop-up mechanism in a subsequent version.

AI Chat Legal Summary: RingConn Partner (AI Chat) is not a substitute for medical professionals or medical services. AI Chat may provide supporting information for your health-management decisions, but its responses may not be entirely accurate. When making any health-related decision, follow the advice of a physician or other qualified healthcare provider and use your own judgment. We recognize that health data is highly private personal information. Before you enable the feature, we will provide a concise notice of the main categories of data AI Chat uses, its purposes, how chat history is retained and deleted, its non-medical limitations, and how you can withdraw consent or disable the feature.

AI Chat History: Information you submit to AI Chat, AI responses, and related interaction records are saved as chat history so that you can review past conversations and have continuous conversational context.

AI Chat Disablement and Withdrawal Notice: You can disable the feature, or disable it and clear data, in the RingConn Partner / AI Chat settings. After you disable it, we will stop using your health data for new AI Chat processing. Deleted or cleared conversations, long-term memory, and related data should no longer be used as input for new conversations or Suggested Questions.

3. How We Use Your Data

We use the personal data we collect for the following purposes:

3.1 Providing and Maintaining Our Services

We use your data to provide and operate our Services effectively, including to create and manage your account; connect, pair, synchronize, and manage your Devices; display health metrics, trends, reports, and personalized recommendations; provide sleep, activity, recovery, stress, heart rate, blood oxygen, and temperature features; provide optional health features you enable (such as Blood Pressure Trends, Sleep PRO (Lab version), exercise, plans, and health alerts); provide Lab features for which you apply; and provide RingConn Partner+ value-added services.

For RingConn Partner+, we use plan and benefit data to display plan products and prices, confirm your eligibility to purchase or try a plan, verify plan status, grant benefits to your RingConn account, display benefit status and expiration/renewal dates, restore purchases, identify duplicate activations, investigate missing orders, and provide customer support.

For AI Chat, we use relevant data to provide RingConn Partner (AI Chat), Suggested Questions, AI Insights, Women’s Health AI Q&A, web-search answers, chat history, and continuous context; access data on demand based on your instructions, without loading all of your health data when you enable the feature; and, for users in Japan, exclude blood pressure-related data from AI Chat. We use data that you have authorized and separately consented to import to generate health-information interpretations, trend analyses, general health-management suggestions, and related reminders. When a question involves general medical knowledge and requires external support, we search approved authoritative sources and display references. We manage the free and benefit usage allowances, allowance periods, limit notices, and reset times for AI Chat; display the Legal Summary and record your activation consent, consent withdrawal, and disablement/clearance actions; and handle user feedback, corrections, complaints, service security, and troubleshooting. Except as necessary to address specific feedback or provide the current feature, we do not use identifiable feedback content, user questions, chat history, or AI outputs for model training, algorithm optimization, research analysis, or product iteration. If we plan to use such content to improve service quality, we will notify you separately and obtain separate consent / explicit consent where required by applicable law.

For Blood Pressure Trends, we use questionnaire information and blood pressure readings you enter manually, together with PPG and accelerometer data collected by the Ring, to analyze your blood pressure status and provide a qualitative assessment and related factor analysis. Depending on the notification permissions you grant, certain features may activate automatically to enhance your experience, such as reminders and feature alerts, so that you receive important and timely updates related to the App.

For Sleep PRO (Lab version), we use your basic information and multiple physiological signals collected by the Ring, including PPG signals, heart rate, heart rate variability, blood oxygen, and movement, and analyze them with an optimized sleep-staging algorithm to provide sleep analysis results such as more precise sleep stages, sleep onset and wake detection, and micro-awakening detection. This feature uses your phone’s GPU to calculate sleep data and therefore may slightly increase your phone’s power consumption.

3.2 Improving and Developing Our Products and Services

Technical stability and security improvements: We may use personal data (including data collected through third-party software development kits (SDKs); see the RingConn App SDK Personal Information Collection Terms) to process crash logs, diagnostic logs, device models, operating system versions, firmware versions, App versions, and error codes to fix faults, enhance security, improve compatibility, and increase stability. Where feasible, we prioritize de-identified, aggregated, or minimized data. We also process technical data related to firmware updates to improve device stability, ensure compatibility across software versions, and proactively address performance or security vulnerabilities. If you grant access to location data and enable map or navigation features in the App, we may use a third-party map SDK to provide the requested service. Such SDKs may collect additional information, including your precise location, device type, hardware parameters, and system information.

User research and product optimization: We use pseudonymized user behavior data collected through the Sensors Data platform (such as page views, clicks, feature usage paths, and time spent) to analyze behavior patterns, understand feature usage, identify product experience issues, and optimize product design and feature experience. We may use your user ID to segment behavior data and send you surveys, product research invitations, or feature testing notices. If you do not wish to receive this targeted content, you may exercise your right to object through the email opt-out link, App notification settings, or by contacting dpo@ringconn.com. For users in the EU/EEA/UK, we will obtain your consent before conducting in-App behavior analytics, and consent is the legal basis for that processing. For users in other regions, this processing is based on our legitimate interests (improving service quality and user experience) or on your consent where required by applicable law.

Special Notice for Blood Pressure Trends: Unless we clearly explain otherwise on a separate screen and obtain your authorization, we will not use health data that identifies you for algorithm training, model validation, research analysis, new feature development, or product iteration that is not directly necessary to provide the current feature.

Special Notice for Sleep PRO (Lab version): Unless we clearly explain otherwise on a separate screen and obtain your authorization, we will not use health data that identifies you for algorithm training, model validation, research analysis, new feature development, or product iteration that is not directly necessary to provide the current feature. Data you provide or that is collected by the Device is used only for technical development and feature optimization for this project, and not for advertising or other commercial purposes.

3.3 Providing Customer Support and Online Customer Service

We process personal data to provide customer service, including to manage real-time communications with you through online customer service. When you contact our support team about a Device, App data, or any other issue, we use the account identification information, basic profile information, Device information, and communications you provide to handle your inquiry, verify your identity, track the progress of the issue, and help resolve it. Depending on the communication method you use, we may access your photo library, camera, or microphone to enable you to send images, videos, or voice messages.

3.4 Compliance with Legal Obligations

We may process your personal data where necessary to comply with legal and regulatory requirements, such as requirements relating to accounting, tax, legal claims, or other legal obligations.

3.5 Algorithm Optimization and Model Iteration

For algorithm optimization, model training, model validation, research analysis, or product iteration involving health data, we distinguish between the following:

1. Algorithmic processing necessary to provide the current feature to you, such as generating the health insight you request;

2. Additional processing for algorithm optimization, model training, model validation, research analysis, or product iteration that is not strictly necessary for the current feature.

For the second category of processing, we will obtain your separate explicit consent where required by law. Refusing this additional processing will not affect your use of the core service for the relevant feature, unless the processing is strictly necessary to provide that feature.

4. Special Terms for the Blood Pressure Trends Feature

4.1 Nature of the Feature

Blood Pressure Trends is an optional feature for adults aged 18 or older only. It uses information you enter manually, questionnaire information, bodily signals collected by the Ring, and algorithmic analysis results to provide trends, qualitative descriptions, or health-management references relating to your blood pressure status.

This feature does not measure clinical blood pressure in the medical sense, is not intended to diagnose high or low blood pressure or any disease, is not intended to treat or prevent disease, and does not constitute medical advice.

4.2 Data We Process

To provide Blood Pressure Trends, we may process: gender, date of birth, height, and weight; blood pressure status, use of blood pressure medication, family medical history, and a list of diagnosed conditions; systolic and diastolic blood pressure readings you enter manually; PPG signals, accelerometer data, and skin temperature collected by the Ring; activity tags and custom activity information entered before calibration or assessment; vascular load metrics, qualitative descriptions of blood pressure status, and related factors; and calibration records, assessment records, and feature usage records.

4.3 Legal Basis and Consent

The Blood Pressure Trends feature involves at least the following two categories of processing:

1. Data processing necessary to provide the Blood Pressure Trends feature to you;

2. Additional processing for algorithm optimization, model validation, model training, research analysis, new feature development, or product iteration.

We will explain these separately and obtain the corresponding consent. You may choose not to consent to the second category of additional processing. Unless that processing is strictly necessary to provide the current feature, your refusal will not affect the core Blood Pressure Trends service.

For users in the European Union, European Economic Area, and United Kingdom, the legal bases for processing data related to Blood Pressure Trends are:

1. GDPR/UK GDPR Article 6(1)(a): your consent;

2. GDPR/UK GDPR Article 9(2)(a): your explicit consent to the processing of health data.

For users in other regions, we will obtain your consent or explicit consent to the extent required by applicable law.

4.4 Withdrawal of Consent

You may withdraw your consent to Blood Pressure Trends at any time by:

1. Going to “Settings — Privacy — Blood Pressure Trends — Withdraw Consent” in the App;

2. Deleting Blood Pressure Trends data in the App;

3. Emailing dpo@ringconn.com.

After you withdraw consent: you may no longer be able to use Blood Pressure Trends; we will stop collecting new data related to Blood Pressure Trends; we will stop using related identifiable health data for the Blood Pressure Trends service, algorithm validation, model training, or product iteration; and existing data will be handled in accordance with this Policy’s data retention and deletion rules. Withdrawal does not affect the lawfulness of processing based on consent before withdrawal.

5. Special Terms for Sleep PRO (Lab Version)

5.1 Nature of the Feature

Sleep PRO (Lab version) is an optional feature offered in beta and available only to certain users. You must apply through the RingConn Lab feature and be approved and enabled on the backend before using it. The feature uses PPG signals collected by the Ring together with multiple physiological signals such as heart rate, heart rate variability, blood oxygen, and movement, and applies an optimized sleep-staging algorithm to provide a more detailed analysis and reconstruction of your sleep throughout the night. It can more precisely identify sleep stages and sleep dynamics and provide more reliable sleep analysis results.

Compared with previous versions, this upgrade primarily improves the accuracy of sleep staging (awake/light/deep/REM), sleep onset and wake detection, continuity and stability during sleep, and detection of subtle micro-awakenings. It is intended to help you better understand the quality of each night’s sleep and changes in your sleep trends.

Note: In this version, the App uses your phone’s GPU to calculate sleep data using the sleep algorithm, which may slightly increase your phone’s power consumption.

This public beta is primarily intended to validate the technical feasibility of the new sleep algorithm and collect feedback from real-world use to support future product optimization and algorithm iteration. It is not intended for disease diagnosis or treatment, or to provide medical advice.

5.2 Data We Process

To provide Sleep PRO (Lab version), we may process the following data: - Basic information: your user ID, phone model, mobile operating system, operating system platform, and similar information; - Physiological data: multiple physiological signals collected by the Ring, including PPG signals, heart rate, heart rate variability, blood oxygen, and movement; - Analysis results: sleep stages (awake/light/deep/REM), sleep onset and wake times, number and level of micro-awakenings (low/medium/high, displayed in different colors), and sleep continuity and stability metrics; - Device computing information: to run the sleep algorithm, the App uses your phone’s GPU to calculate sleep data, which may slightly increase your phone’s power consumption; - Feature usage records: Lab application records, review results, algorithm switching records, feature usage duration and frequency, and similar information.

5.3 Legal Basis and Consent

Sleep PRO (Lab version) involves processing your health data (sleep-related physiological data). Before you first apply to use this feature, we will obtain your explicit consent through a separate screen, an unchecked checkbox, a confirmation button, or another affirmative action. The feature is available only to adults aged 18 or older (or older if required by local law).

Sleep PRO (Lab version) involves at least the following two categories of processing:

1. Data processing necessary to provide the Sleep PRO (Lab version) feature to you;

2. Additional processing for algorithm optimization, model validation, model training, research analysis, new feature development, or product iteration.

For users in the European Union, European Economic Area, and United Kingdom, the legal bases for processing data related to Sleep PRO (Lab version) are:

1. GDPR/UK GDPR Article 6(1)(a): your consent;

2. GDPR/UK GDPR Article 9(2)(a): your explicit consent to the processing of health data.

For users in other regions, we will obtain your consent or explicit consent to the extent required by applicable law.

5.4 Data Use

Data you provide or that is collected by the Device is used only for technical development and feature optimization for this project, and not for advertising or other commercial purposes.

5.5 Data Storage

At present, personal data of overseas users of the RingConn App (including users in the United States, United Kingdom, European Economic Area, and other regions outside mainland China) is centrally stored on cloud servers / in a data center in the United Kingdom. U.S. user data has not yet been migrated to a U.S. data center. If we migrate it to a U.S. data center in the future, we will update this Policy and provide any required notice before or at the time of migration, as required by applicable law.

5.6 Data Retention

As an experimental feature, Sleep PRO (Lab version) data is retained according to the following rules: - During the experiment: while you participate in Sleep PRO (Lab version) testing, related data is retained to support feature validation and algorithm optimization. - Withdrawal from the experiment or withdrawal of consent: if you withdraw from Sleep PRO (Lab version) testing or withdraw consent, we will delete or irreversibly anonymize your related data within 30 days, unless otherwise required by law. Until then, the data will be retained in pseudonymized form and used only for algorithm validation. - End of the experiment: if the experiment ends and the feature does not become a formal feature, we will delete or irreversibly anonymize related data within 30 days after the experiment ends. - Transition to a formal feature: if Sleep PRO (Lab version) later becomes a formal App feature, we will update this Privacy Policy and obtain your consent again before transferring experiment-period data to the production environment. If you do not consent, you may request deletion of the related data. Important Notice: If you wish to delete Sleep PRO (Lab version) data earlier, email dpo@ringconn.com to request withdrawal of your consent to the feature. We will process your request within 30 days after verifying your identity.

5.7 Withdrawal of Consent

You may withdraw your consent to Sleep PRO (Lab version) at any time by:

1. Going to “Settings - Privacy - Sleep PRO (Lab version) - Withdraw Consent” in the App;

2. Deleting Sleep PRO (Lab version) data in the App;

3. Emailing dpo@ringconn.com.

After you withdraw consent: you may no longer be able to use Sleep PRO (Lab version); we will stop collecting new data related to Sleep PRO (Lab version); we will stop using related identifiable health data for the Sleep PRO (Lab version) service, algorithm validation, model training, or product iteration; and existing data will be handled in accordance with the retention rules above. Withdrawal does not affect the lawfulness of processing based on consent before withdrawal.

6. Automated Processing, Algorithmic Transparency, and Health Insights

To ensure that the App displays data correctly and that we can provide our Services, we may use algorithms, models, or automated analysis methods to process data collected by the Device and information you provide, in order to generate health-related metrics or trends such as sleep, recovery, stress, activity, heart rate, blood oxygen, temperature, Blood Pressure Trends, and Sleep PRO (Lab version).

AI Chat Automated Processing and Algorithmic Transparency: AI Chat involves automated processing. The feature may use large language models, rules engines, retrieval-augmented generation, content-safety checks, and output restrictions to identify the intent of a user’s question; select the scope of data the user has authorized and that is relevant to the current question; and generate responses, recommend Suggested Questions, trigger web searches, or display references using health scores and component metrics, activity and tags, profile information, health records, weekly health reports, Blood Pressure Trends / related blood pressure data, and interaction history.

Main processing logic: AI Chat first analyzes your question and its context to determine whether it can be answered using App data you have authorized. When necessary, it accesses health metrics, trends, records, or information you entered that are relevant to the question. If a question relates to a health summary for the previous calendar week or an earlier period, it may access the relevant weekly health report data. If a question relates to blood pressure, vascular load, or Blood Pressure Trends, it may access Blood Pressure Trends and related blood pressure data that you have authorized (not available to users in Japan; if a user in Japan asks about blood pressure, AI Chat will not interpret the question and will only state that the service is not currently available in the region). AI Chat does not load all of your health data when you enable it; each data access is triggered as needed and logged. For general health knowledge questions, it may search authoritative sources on RingConn’s approved list. It then generates a natural-language response and applies safety restrictions, non-medical-use notices, and output quality checks.

Impact and Limitations of Automated Processing: AI Chat outputs are not used as a basis for medical diagnosis, treatment, disease prevention, medication, insurance, employment, credit, or other decisions that produce legal effects or similarly significant effects on you. AI-generated content may be inaccurate, incomplete, delayed, or unsuitable for your individual circumstances. We will not make decisions that produce legal effects or similarly significant effects on you based solely on automated processing by AI Chat.

Your Choices and Remedies: You may choose not to enable AI Chat or, after enabling it, delete an individual conversation, clear your chat history, or disable the feature and clear related data. You may also contact us through in-App customer service, cs@ringconn.com, or dpo@ringconn.com with questions about AI Chat’s automated processing logic, data scope, output, or the exercise of your rights. We will provide explanations and support to a reasonable extent.

These automated analysis results are used only to provide health-management reference. We will not make decisions that produce legal effects or similarly significant effects on you based solely on automated processing, including profiling.

If you have questions about automated analysis results, contact us at dpo@ringconn.com. We will provide relevant explanations or support to a reasonable extent.

7. How We Share and Disclose Data

For details about the circumstances in which we share personal information with third parties, please see the RingConn App Third-Party Information Sharing Terms.

We do not sell users’ personal data. Except in the limited circumstances described below, we do not share your personal data.

We do not share or disclose your health and physiological data (including sleep, heart rate, blood oxygen, temperature, and menstrual cycle data) to advertising technology providers or data analytics providers for advertising or marketing purposes. Our health-data processing systems are logically separated from our advertising systems. The pixel code used to track website conversions does not involve any of your health data.

Special Notice: On Android, information about apps installed on your mobile device is used only to detect whether Google Health Connect is installed and authorized when you use the Google Health Connect data-sync feature; third-party SDKs do not read your complete list of installed apps.

7.1 Processing by External Third Parties

We share your personal data with certain trusted partners, including our affiliates, service providers, and technology vendors, to provide our Services, maintain our platform, and support our business operations. We require our partners to process your personal data in accordance with our instructions and this Policy, and to implement appropriate confidentiality and security measures. We also require them to protect your personal data to at least the same standard that we do.

Processing by an affiliate on our behalf: Our affiliate, Shenzhen Ninenovo Technology Limited, acts as a processor on our behalf to provide development, technical support, operation, and maintenance for the RingConn App. It processes your personal data only to the extent necessary to perform those duties and in accordance with our written instructions, and may not use the data for its own purposes. We have entered into a data processing agreement with it setting out the purposes and duration of processing, processing methods, data types, safeguards, and the parties’ rights and obligations, and we supervise its processing activities.

External processing services we use include: - storing our users’ data; - providing customer support (including online customer service): we use a third-party customer-support platform and online chat tool to operate our online customer service system. For this purpose, we share your RingConn ID, device SN, name you use, contact email, Ring type, and communications with the platform so that customer service representatives can assist you. The service provider may process this data only in accordance with our instructions and is subject to strict confidentiality obligations. - managing and organizing our marketing activities: we share website usage data only with our advertising network partners to analyze and optimize our marketing. This shared data does not include health data and does not involve cross-context sharing based on advertising identifiers. We do not share health-related data or other sensitive personal data with third-party advertisers, and no advertising pixels are deployed on our health-related pages. - analyzing use of our online services to improve service quality. - user behavior analytics and product research: we use the Sensors Data platform to analyze App usage, understand user behavior patterns, optimize product features, and improve user experience. For this purpose, we provide the platform with de-identified user behavior data (such as page views, clicks, feature usage paths, and time spent). The service provider may process this data only in accordance with our instructions and is subject to strict confidentiality obligations. Sensors Data may not use the data for its own commercial purposes or share it with other third parties. Sensors Data processing is deployed on nodes outside mainland China; if a cross-border transfer or remote access from abroad occurs, we will apply the safeguards described in Section 8 of this Policy.

Special Notice Regarding Data Sharing for Blood Pressure Trends

All data for Blood Pressure Trends is processed on cloud servers controlled by RingConn. We do not share raw data or analysis results used for this feature with any third party (this does not prevent you from sharing Blood Pressure Trends data (vascular load and blood pressure records) with friends you select through a separate sharing toggle in Wellness Squad). We do not sell your Blood Pressure Trends data or use it for targeted advertising.

Special Notice Regarding Data Sharing for Sleep PRO (Lab Version)

All data for Sleep PRO (Lab version) is processed on cloud servers controlled by RingConn and no raw data or analysis results used for this feature are shared with third-party companies, SDKs, or advertising technology partners. Only after you actively enable the separate Sleep PRO (Lab version) sharing toggle in Wellness Squad may the related data be shared, at your direction, with other registered users you select. We do not sell your Sleep PRO (Lab version) data or use it for targeted advertising.

Special Notice Regarding Data Sharing and Processing on Behalf of RingConn for AI Chat: AI Chat questions, conversation records, AI outputs, and health data you have authorized (including weekly health report data and Blood Pressure Trends / related blood pressure data) are processed and stored by systems controlled by RingConn in the United Kingdom. Except for processing on our behalf disclosed in this Policy and the RingConn App Third-Party Information Sharing Terms, this data is not transferred to other processors. Current processing on our behalf includes: (1) Shenzhen Ninenovo Technology Limited may remotely access necessary data on U.K. servers / in the U.K. data center from within China for development, technical support, operation, maintenance, service security, and troubleshooting; (2) Functional Software, Inc. (Sentry; processing location: the United States / configured service nodes) and Beijing Volcano Engine Technology Co., Ltd. (Application Performance Monitoring Full-Chain SDK; processing location: Johor, Malaysia) process only error logs, crash logs, performance data, and necessary device information related to AI Chat operation. They do not receive complete user questions, chat records, AI outputs, or identifiable health-data content (including weekly health reports or the content of blood pressure data); (3) Sensors Network Technology (Beijing) Co., Ltd. (Sensors Data platform; processing location: nodes outside mainland China) processes only pseudonymized page views, clicks, feature usage paths, time spent, and other user behavior data. It does not receive complete user questions, chat records, AI outputs, or identifiable health-data content (including weekly health reports or the content of blood pressure data); and (4) Alibaba Cloud Computing Co., Ltd.’s object storage SDK processes files that you actively upload only when you submit feedback files, screenshots, or attachments. Processing takes place on U.K. servers / in the U.K. data center. None of these processors may use the data for advertising, tracking, cross-app identification, model training, algorithm optimization, research analysis, or product iteration. Except for system-level health platform functions such as Apple HealthKit and Google Health Connect / Google Fit that you actively authorize for health-data synchronization, other third-party SDKs do not collect your health, blood pressure, or sleep data. These health platforms read or write health data only within the scope you authorize; Blood Pressure Trends data and Sleep PRO (Lab version) data are not synchronized with them.

7.2 With Your Consent or at Your Direction

Sharing with Third-Party Applications: We share your personal data with third parties only with your explicit consent or at your direction. This includes the following: when you authorize a third-party application (such as Apple Health or Google Fit) to access your data, we may share relevant health data with it as you direct. Please note that each third party’s use of your data is governed by its own privacy policy and terms. We recommend that you read those policies carefully. You may withdraw your consent at any time through your account settings. RingConn uses the following Google Fit scopes to synchronize your health data (such as sleep, heart rate, and blood oxygen saturation) to your Google Fit account:

https://www.googleapis.com/auth/fitness.sleep.write

https://www.googleapis.com/auth/fitness.sleep.read

https://www.googleapis.com/auth/fitness.heart_rate.write

https://www.googleapis.com/auth/fitness.body_temperature.write

https://www.googleapis.com/auth/fitness.oxygen_saturation.write

https://www.googleapis.com/auth/fitness.body.write

https://www.googleapis.com/auth/fitness.activity.write

RingConn’s use and transfer of information received through Google APIs fully complies with the Google API Services User Data Policy, including its Limited Use requirements.

Restrictions on third-party sharing for Blood Pressure Trends: Data from Blood Pressure Trends (including PPG signals, accelerometer data, blood pressure assessment status, and health questionnaires) is not synchronized with Apple Health, Google Fit, or any third-party platform. Data for this feature is stored with logical separation on cloud servers controlled by RingConn.

Restrictions on third-party sharing for Sleep PRO (Lab Version): Data from Sleep PRO (Lab Version) (including PPG signals, accelerometer data, sleep-stage data, micro-awakening data, and similar data) is not synchronized with Apple Health, Google Fit, or other system-level health platforms; it may be shared only with other registered users you designate through Wellness Squad after you affirmatively enable the separate sharing control. Data for this feature is stored with logical separation on cloud servers controlled by RingConn.

Wellness Squad (optional feature): Wellness Squad is an optional extension available to all adult users. If you choose to enable Wellness Squad in the App (called “Wellness Squad” in the overseas English version), you agree to share your personal health data with other registered App users whom you expressly invite. The information you must share includes your profile photo, nickname, and RingConn ID; you select any other data to share, including: sleep data (total sleep duration, sleep efficiency, sleep heart rate, and sleep blood oxygen saturation); stress (stress level and total stress duration); vital signs (heart rate, blood oxygen, and heart rate variability); activity (total calories burned, steps, and all-day activity intensity); health alerts (headache indicators, abnormal vital signs, and sun-exposure dehydration); and reports (weekly health report and comprehensive sleep apnea risk assessment report). Blood Pressure Trends data (circulation stress and blood pressure records) and Sleep PRO (Lab Version) data (sleep stages, sleep and wake times, number and level of micro-awakenings, and sleep continuity and stability indicators) have separate sharing controls and are shared only if you affirmatively enable them, even if you have enabled Wellness Squad. These shared data may include measurements and metrics collected by your RingConn device, as well as information you voluntarily provide when using the App. Sharing can be established in any of three ways: (1) a one-time invitation link under your control; (2) RingConn ID search, which is on by default, meaning other users can search for your RingConn ID (exposing only your RingConn ID, username, and profile photo) so that you can find friends and family and invite them to share more easily. You may turn this off at any time in the App (Wellness Squad > Settings > RingConn ID Search Visibility); once disabled, other users cannot find you by RingConn ID search; or (3) a one-time invitation code (eight alphanumeric characters), valid for three days from generation and usable once by one friend or family member, after which it expires. You may generate no more than 15 invitation codes in any 24-hour period. You may have sharing relationships with up to five people at a time, and each person may accept sharing from up to five users at a time. To protect your privacy, before a relationship is established, the other person can see only the names of sections and metrics, not their values; after it is established, they may view only data within the scope you selected. When you first enable this feature, we will obtain your separate consent on a dedicated screen (see the RingConn App Wellness Squad Data Sharing Authorization Agreement); each time you share with a new friend or family member, you must confirm that sharing separately. After the recipient accepts your invitation, if you have enabled the setting requiring your confirmation after acceptance, you must complete a second confirmation within 48 hours or the invitation will expire automatically. You may manage shared data or stop sharing at any time by tapping the relevant person’s profile photo on the Wellness Squad home page. This feature is available only to users aged 18 or older. The recipient’s App does not persistently store your shared data, but we cannot rule out the recipient retaining it by taking screenshots or photographs. Please choose whom you share with carefully. Shared data is not used to train algorithms.

You may stop sharing your data with friends or family, or remove them from your sharing list, at any time:

Under “People I Care About,” tap the relevant person’s profile photo to open their details page. You may view their data, turn health-alert and health-report notifications on or off, or remove them.

Under “People Who Care About Me,” tap the relevant person’s profile photo to open their details page. You may manage the data you share with them or stop sharing.

Once a person is removed or you stop sharing, that person immediately loses access in their App and is no longer authorized to access any data previously shared.

By enabling this feature, you agree to share your data only to enhance your experience and receive support from people you trust. If you do not want to share your data, do not activate this feature.

Important notice to recipients of shared data: If another registered user invites you to access their shared health data, before you accept the invitation you can see only section and metric names, not specific values. Shared health data may include weekly reports, sleep and activity metrics, stress levels, vital signs, or high-heart-rate alerts. You agree not to disclose, forward, copy, download, or share these data with any third party not authorized by the data owner. Any misuse or unauthorized use of shared data may violate privacy laws. We will be liable for a recipient’s conduct beyond the scope of authorization to the extent of our own fault, and reserve the right to pursue remedies against users who violate these restrictions.

Special notice on sharing with a fertility partner (Fertility Tracking mode; optional feature): Partner sharing is person-to-person sharing between registered users in Fertility Tracking mode. The shared data include readiness, cycle overview, today’s symptoms, key recommendations, intercourse records, and intercourse reminders (for the previous week, current week, and following week). Sharing is established through a one-time invitation link under your control. Once the relationship is established, either party may record intercourse, and the record will sync to both parties. Intercourse reminders and “Nudge” notifications are sent to both you and your partner (up to 10 “Nudges” per day). The sharing party may stop sharing unilaterally at any time without the other party’s confirmation, and may disconnect and delete data from the sharing period. These data are highly sensitive data relating to reproductive health and sexual life. We do not sell them or use them for targeted advertising; the recipient is another individual registered user, not a third-party business. Disclosure of these data to another individual user at your direction does not constitute a “sale” or “sharing” under the CCPA. We cannot rule out the recipient retaining shared data by taking screenshots or photographs. Please choose whom you share with carefully.

Cross-platform account linking: To provide a consistent user experience across platforms, we allow you to link the same account between our App and website. You may choose to link the same account on the website and in the App; we will not automatically create a corresponding account for you without your confirmation. When you initiate account linking, we may process and sync the following data to support this feature: basic account information (such as email address, username, and user ID); purchase records; and account status and login activity. We will not use your sensitive data for undisclosed purposes without your express permission. You can review and manage your data-processing preferences in your privacy settings.

7.3 Legal Compliance and Law Enforcement

We reserve the right to disclose personal data to protect our legal rights and property and to comply with valid legal requirements. We may retain or disclose data about you to comply with laws, regulations, legal process, or government requests; establish or defend legal claims; or prevent, detect, or investigate illegal activity, fraud, abuse, violations of our terms, or threats to the security of the Services or anyone’s physical safety. We may share aggregated, non-personal data that cannot reasonably be used to identify an individual, whether or not combined with other information. We may publicly disclose such data and disclose it to third parties, for example in public reports on exercise and activity, to partners under our agreements, or as part of community benchmark data provided to users. We will not transfer your personal information to any company, organization, or individual except in the following circumstances:

1. Transfer with express consent: We will transfer your personal information to another party after obtaining your express consent.

2. In the event of a merger, acquisition, or sale of assets, we will continue to take steps to protect the privacy of personal data and notify affected users before transferring any personal data to a new entity. We will require the new entity to remain bound by this Privacy Policy in connection with the transfer before seeking your separate consent to the collection and processing of your data. If the purposes or means of processing, or the recipients of personal information, materially change after the transaction, we will notify you promptly and obtain your consent again where required.

8. Data Storage and Transfers

Because we provide our products and services using global resources and servers, we process and back up personal data using infrastructure that we operate and control around the world.

1. U.S. users: At present, U.S. user data has not been migrated to a U.S. data center and is stored centrally with data of other overseas users on cloud servers/data platforms in the United Kingdom.

2. Users in the United Kingdom, European Economic Area (EEA), and other overseas regions: We use cloud servers/data platforms located in the United Kingdom to process and store relevant personal data.

3. The actual server location may change due to service deployment, disaster recovery, or compliance requirements. We will update this Policy if a material change occurs.

We rely on several legal mechanisms to transfer personal data lawfully around the world. These mechanisms include your consent (where applicable) and the Standard Contractual Clauses approved by the European Commission, which require specified privacy and security protections. You may contact us to obtain a copy of the Standard Contractual Clauses.

For users in the EU, EEA, and United Kingdom, if personal information is transferred to a country or region that has not been recognized as providing an adequate level of protection, we will implement appropriate safeguards, such as the European Commission’s Standard Contractual Clauses; the UK International Data Transfer Agreement or UK Addendum; a transfer impact assessment; supplementary measures such as encryption, access controls, pseudonymization, access minimization, and log audits; and your consent where required by applicable law.

Remote access from mainland China: Under the entrusted-processing arrangement described above, technical and operations personnel of Shenzhen Ninenovo Technology Limited may remotely access overseas users’ personal data stored on UK servers/data platforms while performing their duties from mainland China. Such remote access constitutes a cross-border transfer of data under applicable law. We have put in place data-processing agreements, access approvals and log audits, encrypted transmission (TLS 1.3), and least-privilege controls to protect such access, and, where required by applicable law, will provide appropriate safeguards through mechanisms such as Standard Contractual Clauses.

If you have a complaint about our international data transfers, please contact us using the methods described in the “Contact Us” section. You may also lodge a complaint with the competent supervisory authority in your jurisdiction.

9. Data Retention and Security

9.1 Data Retention

We store your personal information only for as long as needed for the purposes described in this Policy and for the periods required by laws, regulations, and regulatory requirements, unless mandatory retention is required by law. If we discontinue the Services or our operations, we will immediately stop collecting your personal information and, unless otherwise required by applicable law, delete or irreversibly anonymize it. If you withdraw consent, request deletion, or close your account, data in primary systems will be deleted within 30 days. If data is stored in backup archives and immediate deletion is not feasible, backup copies will be securely isolated from any further processing and deleted on a rolling basis according to the backup update cycle (no longer than 12 months). If we irreversibly anonymize your personal information so that it is no longer associated with you, we may use it indefinitely without further notice.

Customer service and after-sales records: To fulfill warranty obligations and handle disputes, we retain customer service communications and after-sales service records for two years after the product warranty expires, unless a longer period is required by law.

Special retention rules for Blood Pressure Trends:

Data category	Retention period	Deletion method	Notes
Raw PPG signal and accelerometer data collected by the ring	Within 30 days after you withdraw consent, request deletion, or close your account	Physical deletion or irreversible anonymization	Until then, the data is retained in pseudonymized form solely for algorithm validation.
Assessment records	Within 30 days after you withdraw consent, request deletion, or close your account	Physical deletion	You may delete these records in the App at any time.
Blood pressure data entered manually	Within 30 days after you withdraw consent, request deletion, or close your account	Physical deletion	Calibration data is retained until account closure.
Questionnaire information	Within 30 days after you withdraw consent, request deletion, or close your account	Physical deletion or anonymization	You may update or delete this information in the App at any time.
Algorithmically inferred results	Deleted at the same time as the raw PPG signals	Physical deletion or anonymization	Includes circulation-stress metrics and qualitative assessments.

Important: If you wish to delete raw PPG signals collected by the ring before the end of the retention period, email dpo@ringconn.com to request withdrawal of your consent to Blood Pressure Trends. We will process your request within 30 days after verifying your identity.

Special retention rules for Sleep PRO (Lab Version):

Data category	Retention period	Deletion method	Notes
Raw PPG signal and accelerometer data collected by the ring	Within 30 days after you leave the experiment, withdraw consent, request deletion, or close your account	Physical deletion or irreversible anonymization	Until then, the data is retained in pseudonymized form solely for algorithm validation.
Sleep-stage, micro-awakening, and other analysis results	Within 30 days after you leave the experiment, withdraw consent, request deletion, or close your account	Physical deletion	You may delete these results in the App at any time.
Lab application records, review records, and feature-usage records	Within 30 days after you leave the experiment, withdraw consent, request deletion, or close your account	Physical deletion or anonymization	You may view these records in the App at any time.
Questionnaire information (if any)	Within 30 days after you leave the experiment, withdraw consent, request deletion, or close your account	Physical deletion or anonymization	You may update or delete this information in the App at any time.

Important: If you wish to delete data relating to Sleep PRO (Lab Version) before the end of the retention period, email dpo@ringconn.com to request withdrawal of your consent to Sleep PRO (Lab Version). We will process your request within 30 days after verifying your identity. If the experiment ends without the feature becoming generally available, we will delete or irreversibly anonymize the related data within 30 days after the experiment ends. If the feature becomes generally available, before moving experiment data to the production environment we will update this Privacy Policy and obtain your consent again. If you do not consent, you may request deletion of the relevant data.

Special retention rules for Wellness Squad:

Data category	Retention period	Deletion method	Notes
Sharing-authorization records and sharing-relationship data	Within 30 days after a user removes a friend or family member, stops sharing, or closes their account	Physical deletion or irreversible anonymization	After a user removes a friend or family member or stops sharing, the other person immediately loses access in their App.
Logs of access to shared data	Retained while the sharing relationship exists; deleted within 30 days after it ends	Physical deletion or anonymization	Used for security auditing.

Important: If you wish to delete data relating to Wellness Squad before the end of the retention period, email dpo@ringconn.com to request withdrawal of your consent to Wellness Squad. We will process your request within 30 days after verifying your identity. Sleep PRO (Lab Version) data shared through Wellness Squad is also subject to the retention rules for Sleep PRO (Lab Version) in this table. If you leave the Sleep PRO (Lab Version) experiment or withdraw consent to that feature, the sharing authorization will also end, and the data will be handled under the Sleep PRO (Lab Version) retention rules.

Special retention rules for Women’s Health and Fertility Tracking:

Data category	Retention period	Deletion method	Notes
Questionnaire information (basic questionnaire and trying-to-conceive questionnaire)	Within 30 days after you withdraw consent, request deletion, or close your account (45 days in the United States)	Physical deletion or irreversible anonymization	You may update or delete this information in the App at any time.
Menstrual records, symptom records, intercourse records and reminders, and pregnancy-status indicators	Within 30 days after you withdraw consent, request deletion, or close your account (45 days in the United States)	Physical deletion or irreversible anonymization	You may delete these records in the App at any time.
Algorithmically generated results (period predictions, readiness assessments, health analyses, and cycle statistics)	Deleted at the same time as the source data	Physical deletion or irreversible anonymization	Deleted when the source data is deleted.
Data shared with a partner	After sharing stops or the connection is disconnected, the other person immediately loses access	Physical deletion or irreversible anonymization	If you select “Disconnect and delete data,” data from the sharing period is deleted at the same time.
Backup copies	Securely isolated and deleted on a rolling basis according to the backup update cycle (no longer than 12 months)	Cleared through the backup cycle	Isolated from any further processing.

Important: To delete data relating to Women’s Health and Fertility Tracking, you may turn off the feature in the App under “Me > App Settings > Women’s Health,” or email dpo@ringconn.com / datacompliance@ninenovo.com. We will process your request within 30 days after verifying your identity (within 45 days in the United States).

Special retention terms for RingConn Partner+: Region and product display information is retrieved in real time and, as a general rule, is not retained long-term if no order is placed; after an order is placed, it is retained with the order record. Orders, transactions, and plan status are retained while your account is active and for as long as needed to perform the contract and for tax, accounting, audit, dispute-resolution, anti-fraud, and legal-compliance purposes. Following account closure or a deletion request, they will be deleted or anonymized under this Policy, except where retention is required by law. AI health-interpretation context and outputs are handled under the rules specific to the AI feature and the health-data retention rules. After consent is withdrawn or a deletion request is made, we will stop new processing and delete or irreversibly anonymize the data within the applicable period; backup copies will be cleared through the backup cycle.

Special retention terms for RingConn AI conversations: AI conversation histories, personalization settings, health-profile settings, long-term memory, and related usage records are retained for as long as needed to fulfill the feature’s purposes. When you delete an individual conversation, clear your conversation history, or choose to turn off and clear the data, the relevant data will no longer be used as input for new conversations or suggested follow-up questions. The applicable retention approach is: deletion or disabling takes effect immediately in the user interface; data in primary systems is deleted or anonymized within 30 days; backup copies are cleared through the backup cycle, no later than 12 months, except where retention is required by law or needed to handle a dispute. Underlying health data accessed by AI, including weekly health report data and Blood Pressure Trends or other blood-pressure-related data, remains subject to the retention period for the corresponding original feature. Withdrawing consent to AI use stops use of that data in AI conversations but does not automatically delete the underlying feature data.

9.2 Data Security

We have implemented reasonable and practicable security measures consistent with industry standards to protect your information against unauthorized access, disclosure, use, modification, damage, or loss. We take the following steps to protect your data:

1. Use encryption to enhance the security of personal information, including encryption in transit (TLS 1.3) and at rest (AES-256).

2. Use trusted protection mechanisms to prevent malicious attacks on personal information.

3. Deploy access-control mechanisms and make reasonable efforts to ensure that only authorized personnel can access personal information.

4. Provide regular security and privacy training to increase employee awareness of the importance of protecting personal information.

5. Establish dedicated data-compliance management systems, processes, and teams to protect information. For example, we strictly limit the personnel authorized to access information, require them to comply with confidentiality obligations, and audit access.

6. Encrypt or otherwise protect sensitive data while it is stored.

7. Establish logging, access auditing, and anomaly-monitoring mechanisms.

8. Establish data-compliance management processes, appoint a dedicated data-compliance officer, and maintain a data-security incident-response mechanism.

Additional security measures for Blood Pressure Trends: pseudonymization—raw PPG signals are stored separately from user identifiers and linked using random identifiers; enhanced encryption—Blood Pressure Trends data is encrypted in transit (TLS 1.3) and at rest (AES-256); access auditing—all access to Blood Pressure Trends data is recorded in audit logs retained for 12 months; regular penetration testing—security scans and penetration tests are performed quarterly. Additional security measures for Sleep PRO (Lab Version): pseudonymization—raw PPG signals are stored separately from user identifiers and linked using random identifiers; enhanced encryption—Sleep PRO (Lab Version) data is encrypted in transit (TLS 1.3) and at rest (AES-256); access auditing—all access to Sleep PRO (Lab Version) data is recorded in audit logs retained for 12 months; regular penetration testing—security scans and penetration tests are performed quarterly; experiment-data isolation—Sleep PRO (Lab Version) data is stored with logical separation from production data and may be migrated only when necessary and after approval. Additional security measures for AI conversations: AI conversation data should be protected by encryption in transit and at rest. Based on the current materials, transmission uses HTTPS and storage uses AES encryption. RingConn’s existing access controls, log audits, least-privilege controls, data segregation, and security-incident response mechanisms also apply. We will minimize AI conversation logs, feedback, and health-data access, and avoid recording complete health-data or conversation text in performance monitoring, crash logs, or behavioral analytics unless necessary to handle a customer-support issue that you submit. We will take all reasonable and practicable steps to ensure that irrelevant personal information is not collected. We retain your personal information only for the shortest period necessary to achieve the purposes described in this Policy, unless otherwise required by the laws and regulations in your region.

The internet is not 100% secure, and we will do our best to ensure or guarantee the security of any information you send to us. If a breach of our physical, technical, or administrative safeguards results in unauthorized access, public disclosure, alteration, or destruction of information and harms your lawful rights and interests, we will bear the corresponding legal liability. After a personal-information security incident, we will initiate our internal response process as required by law, including incident classification, containment, investigation, remediation, impact assessment, and recordkeeping. We will also comply strictly with the laws and regulations applicable in your region and determine as required by law whether we must notify regulatory authorities and/or affected individuals. If notification is required, it will include, among other things, the basic facts and potential effects of the incident; measures taken or to be taken; recommendations to help you independently prevent or reduce risks; and remedies available to you. We will notify you promptly through email, mail, telephone, push notification, or other means. If it is difficult to notify individuals one by one, we will provide notice in a reasonable and effective manner. We will also proactively report our handling of personal-information security incidents to regulators and fulfill other duties required by applicable laws and regulations as directed by them.

10. Your Rights

10.1 Rights Under Applicable Law

Under applicable law, you have rights and choices regarding your data. Some rights apply generally, while others apply only in specific circumstances. These rights may be subject to limitations depending on the circumstances. Please note that exercising certain rights (for example, withdrawing your consent to this Privacy Policy) may prevent us from continuing to provide the Services to you.

You may exercise the following rights regarding your data:

1. Right to confirmation and access: You may ask us to confirm whether we process your data, request access to your data, and receive a copy of the personal data we collect and store about you.

2. Right to rectification: You can update, correct, or change your data in your account settings in the App. If your data is inaccurate, you may ask us to update, correct, or change it.

3. Right to erasure: Subject to applicable law, you may ask us to delete, destroy, or irreversibly anonymize your personal data. In certain circumstances specified by applicable law, you may ask us to stop providing personal data to third parties.

4. Right to data portability: Where we rely on contractual necessity or consent as the legal basis for processing, you have the right to data portability. This means you may receive your data in a structured, commonly used, machine-readable format and transmit it to a third party.

5. Right to withdraw consent: You may withdraw consent to processing of your personal data based on consent, unless withdrawal is restricted by law or contract. Withdrawal does not affect the lawfulness or validity of processing based on your consent before it was withdrawn.

• You may withdraw consent in your account settings in the App.

• To opt out of marketing communications, such as electronic marketing messages, review the notification settings in your account settings in the App to control the marketing communications we send you.

6. Right to object to or restrict processing: Where permitted by applicable law, you may object to or restrict our processing of your data in certain circumstances, including where we rely on legitimate interests or a public interest. For example, under applicable law you may ask us to stop or not begin using your personal data for direct marketing. In particular, you may object to our use, based on legitimate interests, of pseudonymized user-behavior data to target you with user-research questionnaires, product-experience invitations, or notices relating to product improvement. You may exercise this right by using an opt-out link in an email, changing notification settings in the App, or emailing dpo@ringconn.com. In certain circumstances specified by applicable law, you may object to decisions based solely on automated processing, including profiling, of your personal data.

Special channel for exercising rights relating to Blood Pressure Trends: access/correction/deletion—App > “Blood Pressure Trends” > “More” > “My Records”; to stop using the feature or delete all data, email dpo@ringconn.com to submit a request.

Special channel for exercising rights relating to Sleep PRO (Lab Version): access/correction/deletion—App > “Sleep PRO (Lab Version)” > “History” or the relevant page; to stop using the feature, delete all data, or leave the experiment, email dpo@ringconn.com to submit a request.

Special channels for exercising rights relating to Wellness Squad:

Accessing/managing sharing and notification settings:

• Manage “People I Care About”: In the App, go to “Wellness Squad > Feature Home > People I Care About,” then tap the relevant person’s profile photo to open their details page. You may view their data, turn health-alert and health-report notifications on or off, or remove them.

• Manage “People Who Care About Me”: In the App, go to “Wellness Squad > Feature Home > People Who Care About Me,” then tap the relevant person’s profile photo to open their details page. You may manage the scope of data shared with them or stop sharing.

• Turn off RingConn ID search visibility: In the App, go to “Wellness Squad > Settings” and turn it off.

• To stop using the feature or delete all data, email dpo@ringconn.com to submit a request.

When you submit an objection or restriction request, you should explain the specific processing activity to which you object or which you want restricted, and why processing should stop. We will stop the specific processing unless we have compelling legitimate grounds to continue or need to retain the data to establish, exercise, or defend legal claims.

10.2 How to Exercise Your Rights

You may exercise these rights by signing in to your account and using the account settings, or by contacting us in writing or by another method permitted by applicable law as described in the “Contact Us” section.

We will ensure that you can exercise your rights under applicable law. Applicable law may allow us to deny a request in certain circumstances—for example, where denial is required by a court order or where exercising the right would adversely affect the rights and freedoms of others.

When you exercise your rights, we may ask you to verify your identity, for example through your RingConn account.

You generally do not have to pay a fee to exercise your rights under applicable law. However, where permitted by applicable law, we reserve the right to charge a reasonable fee for handling a data access request, correction request, or other request.

We will respond to your request within the time limit set by applicable law (for users in the EU/EEA/United Kingdom, no later than one month).

If you have questions about this Privacy Policy or exercising your rights, you may submit a request to us using the email address listed in the “Contact Us” section below.

If you believe that our processing of your personal data violates this Privacy Policy or applicable law, you have the right to lodge a complaint with the competent supervisory authority in your jurisdiction.

11. Terms for Users in the EU/EEA and United Kingdom

When the General Data Protection Regulation (GDPR) applies to RingConn, the information and rights in this section apply to users residing in the EU/EEA/United Kingdom.

We act as a “controller” when we decide how to use personal information to provide the Services, and as a “processor” when we process personal information only on a customer’s instructions, in each case as defined by the GDPR.

11.1 Legal Bases for Processing

Under the GDPR and UK GDPR, we rely on the following legal bases to process personal information:

1. Performance of a contract: processing is necessary to provide the products or services you request.

2. Consent: you have consented to a specific processing activity.

3. Explicit consent: you have explicitly consented to processing health data or other special-category personal data.

4. Legitimate interests: processing is for reasonable purposes such as improving the Services, protecting security, troubleshooting, or operating our business, and we have assessed that those interests do not unduly prejudice your rights and freedoms.

5. Legal obligation: processing is necessary to comply with applicable laws and regulations.

6. Vital interests or public interest: this basis applies in exceptional circumstances where permitted by law.

For health data or other special-category personal data, we generally rely on explicit consent under GDPR Article 9(2)(a) and the corresponding UK GDPR condition for processing special-category data, unless otherwise permitted by applicable law.

11.2 Key Processing Activities, Data Categories, and Legal Bases

The table below describes how we plan to use your personal data and the legal bases on which we rely. Where appropriate, we also identify our legitimate interests. Depending on the specific purpose for which we use your data, we may process your personal data on more than one legal basis. If you would like to know the specific legal basis on which we rely to process your personal data when the table lists multiple bases, please contact us.

Please note that we process data for Blood Pressure Trends and Sleep PRO (Lab Version) strictly on the basis of your explicit consent, which is obtained through a dedicated screen and your affirmative selection, and may be withdrawn at any time.

Purpose / Activity	Data Types	Legal Basis for Processing
Account registration and profile creation	Username; email address; address; mobile phone number; password; date of birth; gender; height and weight; region/country; profile photo (optional).	Performance of our contract with you.
Device pairing and operation	Bluetooth connection data; device ID and serial number; firmware version; connection logs.	Performance of our contract with you.
Daily activity and health overview	Steps; calories burned; activity level and intensity; exercise data (from the accelerometer); sedentary-behavior data.	Performance of our contract with you; consent.
Sleep monitoring and reports	Sleep stages (light, deep, and REM); sleep duration and quality; nighttime heart rate; blood oxygen during sleep; respiratory rate during sleep; skin-temperature trends during sleep.	Explicit consent (GDPR/UK GDPR Article 9(2)(a)) and Article 6(1)(a).
Stress and recovery management	Heart-rate variability (HRV); stress-level trends; recovery metrics; mood/stress levels entered by the user.	Explicit consent (GDPR/UK GDPR Article 9(2)(a)) and Article 6(1)(a).
Heart-rate and SpO₂ monitoring	Real-time and average heart rate and heart-rate trends; blood oxygen (SpO₂) levels.	Explicit consent (GDPR/UK GDPR Article 9(2)(a)) and Article 6(1)(a).
Vital-sign monitoring	Skin temperature; respiratory rate; resting heart rate; changes in physiological signals.	Explicit consent (GDPR/UK GDPR Article 9(2)(a)) and Article 6(1)(a).
Weekly, monthly, and annual health reports	Aggregated weekly/monthly/yearly data on sleep, activity, heart rate, steps, calories, standing, stress, and similar metrics; summary charts; trend analysis; personalized recommendations; generation of weekly health reports and personalized interpretations in AI Conversations of questions relating to those reports.	Explicit consent (GDPR/UK GDPR Article 9(2)(a)) and Article 6(1)(a).
Women’s Health (menstrual-cycle tracking, including Period Tracking/Fertility Tracking; optional feature)	Basic questionnaire: date of birth [synced both ways with the main App account], average cycle length, period duration, cycle regularity, start date of the last period, and medical conditions. Trying-to-conceive questionnaire: time spent trying to conceive, conception-related experience, and contraception used in the past six months. Menstrual records: cycle timeline, period start/end dates, etc. Symptom records: 23 categories of symptoms, including ovulation status, details of sexual activity, vaginal discharge, unusual bleeding, alcohol/tobacco use, and physical changes, plus free-text notes. Intercourse records and reminders (after linking with a partner, the partner may also enter records and both parties’ data will sync). Pregnancy-status indicator. Device data: skin temperature, previous night’s sleep, seven-day exercise duration, and previous day’s stress data required to assess readiness. Algorithm-generated results: period predictions, readiness assessments, health analyses, and cycle statistics. Partner-shared data: readiness, cycle overview, today’s symptoms, key recommendations, intercourse records and reminders. Feature-usage records (Sensors Data analytics events, pseudonymized).	Explicit consent (GDPR/UK GDPR Article 9(2)(a)) and Article 6(1)(a). This is an optional feature. The version 4.5.0 redesign involves in-depth processing of special-category data relating to reproductive health; we will obtain your explicit consent on a separate screen when you first use the feature and when you upgrade to version 4.5.0. Separate consent is the basis for the additional processing for algorithm optimization, model training, research, and product iteration (de-identified/aggregated statistics of questionnaire selections and optimization of prediction models using historical menstrual records). Refusal does not affect use of core features.
Sleep apnea risk monitoring (OSAHS; optional feature)	Height, weight, BMI; age, gender, neck circumference; medical history; OSAHS symptoms; sleep reports.	Explicit consent (GDPR/UK GDPR Article 9(2)(a)) and Article 6(1)(a).
Blood Pressure Trends	Questionnaire information: gender, date of birth, height, weight, blood pressure status, use of blood-pressure medication, family medical history, and diagnosed conditions. Manually entered data: systolic and diastolic blood pressure. Raw data collected by the ring: PPG signals, accelerometer data, and skin temperature used to analyze circulation stress. Derived analysis results: circulation-stress metrics; qualitative blood-pressure status (stable/slight change/significant change); related factors; Blood Pressure Trends factors; calibration cycle and records; assessment records; questionnaire responses. Activity information: preset or custom activity labels before calibration/assessment. After you authorize and separately consent to processing of sensitive personal information in AI Conversations, the above data may be used to interpret questions about blood pressure, circulation stress, or Blood Pressure Trends in AI Conversations. (Not available in Japan: AI Conversations for users in Japan do not connect to or process any blood-pressure-related data.)	Explicit consent (GDPR/UK GDPR Article 9(2)(a)) and Article 6(1)(a). Blood Pressure Trends is optional and involves in-depth processing of your health data, particularly data relating to Blood Pressure Trends. Before you first use the feature, we will request your explicit authorization on a separate screen.
Blood Pressure Trends optimization and algorithm iteration	All data used for Blood Pressure Trends, including raw PPG signals collected by the ring, accelerometer data, blood pressure values entered manually, questionnaire information, activity information, and assessment status.	Explicit consent (GDPR/UK GDPR Article 9(2)(a)) and Article 6(1)(a). We technically analyze the relevant data and iterate models on the basis of your explicit consent; we have assessed and ensured that this processing does not unduly affect your rights and freedoms.
Sleep PRO (Lab Version)	Basic information: user ID, phone model, mobile operating system, and platform. Physiological data: PPG signals, heart rate, heart-rate variability, blood oxygen, movement, and other multidimensional physiological signals. Analysis results: sleep stages, sleep and wake times, number and level of micro-awakenings, and sleep-continuity and stability metrics. Device-computing information: GPU invocation records. Feature-usage records: Lab applications, reviews, and algorithm-switch records.	Explicit consent (GDPR/UK GDPR Article 9(2)(a)) and Article 6(1)(a). Sleep PRO (Lab Version) is an optional beta-testing feature involving in-depth processing of your health data (sleep-related physiological data). Before you first apply to use the feature, we will request your explicit authorization on a separate screen.
Sleep PRO (Lab Version) optimization and algorithm iteration	All data used for Sleep PRO (Lab Version), including raw PPG signals collected by the ring, accelerometer data, heart rate, heart-rate variability, blood oxygen, movement data, analysis results, and feature-usage records.	Explicit consent (GDPR/UK GDPR Article 9(2)(a)) and Article 6(1)(a). We technically analyze the relevant data and iterate models on the basis of your explicit consent; we have assessed and ensured that this processing does not unduly affect your rights and freedoms.
RingConn Partner+ plans, trials, renewals, benefit provisioning, and restore purchases	Region associated with the Google/Apple account signed in on the user’s phone; product ID; plan name; price; currency; billing period; promotional information; RingConn order number; plan status; purchase date; renewal date; expiration date; order number or transaction ID; transaction status; RingConn user ID.	Performance of a contract (GDPR/UK GDPR Article 6(1)(b)); legal obligations (Article 6(1)(c), such as tax, accounting, or disputes); legitimate interests (Article 6(1)(f), such as fraud prevention, investigating missing orders, and security maintenance).
RingConn Partner+ AI health interpretation	Health data, metrics, reports, trends, and records you have authorized (including weekly health report data and Blood Pressure Trends and other blood-pressure-related data), as well as AI conversation questions, context, and outputs.	Consent/performance of a contract; where health data is involved, explicit consent (GDPR/UK GDPR Article 9(2)(a)) and the corresponding legal basis under Article 6.
Wellness Squad data sharing	Profile photo, nickname, RingConn ID; sleep data (total sleep duration, sleep efficiency, sleep heart rate, sleep blood oxygen saturation); stress (stress level and total stress duration); vital signs (heart rate, blood oxygen, heart-rate variability); activity (total calories burned, steps, all-day activity intensity); health alerts (headache indicators, abnormal vital signs, sun-exposure dehydration); reports (weekly health report and comprehensive sleep apnea risk assessment report); Blood Pressure Trends data (circulation stress and blood pressure records); Sleep PRO (Lab Version) data (sleep stages, sleep and wake times, number and level of micro-awakenings, and sleep-continuity and stability metrics).	Consent (GDPR/UK GDPR Article 6(1)(a)) and explicit consent (Article 9(2)(a)) for health data. Wellness Squad is optional and involves sharing your health data. Before you first enable the feature, we will request your explicit authorization on a separate screen.
App usage analytics and troubleshooting	Crash logs; diagnostic logs; feature-interaction data; in-App navigation patterns.	Legitimate interests (improving the Services).
Mobile-device and system identification	Model; operating system; screen size; unique device identifier; IMEI; MAC address; browser type; network provider; language and time zone; push token.	Performance of our contract with you; legitimate interests.
Bluetooth and location services (for device connection)	Bluetooth signal data; approximate GPS location (if permission is granted); Wi-Fi/Bluetooth SSID information.	Consent.
Find My Ring (device finding)	Location information (sensitive personal information, collected with authorization); device information, model, and battery level.	Consent (limited to the purpose of finding the device).
Third-party analytics related to SDKs	Device information; App usage data; mobile-device app-installation-list information (used only to detect Google Health Connect availability; third-party SDKs do not read your full app installation list); crash data.	Performance of our contract with you; legitimate interests (App functionality and performance).
Customer support and communications	Name; email address; message content; App version and device data; feedback or survey responses.	Performance of our contract with you; legitimate interests.
Sign-in through third-party platforms (Google, Apple)	Third-party account ID (Google account ID or Apple stable user identifier); display name/nickname; profile photo; email address (if authorized).	Consent.
Integration with health platforms (such as Apple Health and Google Fit)	Health metrics shared through APIs, subject to the permissions you grant.	Consent.
Online customer support	RingConn ID; device serial number; name or preferred form of address; contact email; ring type; communications (including images, video, or audio you send, in which case we access photo-library, camera, or microphone permissions).	Performance of our contract with you (to fulfill our contractual obligation to provide customer support).
User-behavior analytics and product research (Sensors Data)	Pseudonymized user-behavior data such as page-view paths, clicks, feature-use frequency, time spent, and page-navigation paths; user ID (for user segmentation and delivery of surveys/research invitations).	Consent (for users in the EU/EEA/United Kingdom, we obtain your consent before conducting in-App behavioral analytics).

11.3 Your Rights

This section describes your rights under the GDPR. For security reasons, we may verify your identity before processing your request. We will respond within the time limit set by applicable law (for users in the EU/EEA/United Kingdom, no later than one month).

Right of access to personal information: You have the right to ask us to confirm whether we process your personal information and, if so, to request access to it. After signing in, you can view or access your personal data directly through the interface of our products or services. You can also use the feedback feature in the RingConn App or email dpo@ringconn.com to inquire about or access your personal data and request a copy.

Right to data portability: To the extent permitted by law, you may ask us to transfer personal information you have provided to a personal information processor of your choice. For requests that meet the conditions prescribed by law, we will provide a transfer mechanism or other feasible assistance. After providing formal authorization, you may exercise this right through the feedback feature in the RingConn App or by emailing dpo@ringconn.com.

Right to rectification of personal information: You may ask us to correct inaccurate personal information about you and, having regard to the purposes of processing, to complete incomplete personal information. You can correct or change some personal data directly on the relevant feature page of our products or services, or contact us at dpo@ringconn.com.

Right to erasure: You may ask us to delete some or all personal information about you. You can delete information you have submitted directly in the product interface associated with your account. You may also contact us using the feedback feature on our platform or by emailing dpo@ringconn.com.

Special deletion terms for Blood Pressure Trends data: assessment records and blood pressure values you entered manually—you may delete them in the App at any time, and we will physically delete or irreversibly anonymize them within 30 days; raw PPG signals collected by the ring—if you withdraw your consent to Blood Pressure Trends, we will physically delete or irreversibly anonymize these data within 30 days, unless otherwise required by law. Until then, the data will be stored in pseudonymized form for algorithm optimization; exception for immediate deletion—data in primary systems will be deleted within 30 days. If data is stored in backup systems, backup copies will be securely isolated and deleted on a rolling basis according to the backup update cycle (no longer than 12 months).

Special deletion terms for Sleep PRO (Lab Version) data: analysis results and feature-usage records—you may delete them in the App at any time, and we will physically delete or irreversibly anonymize them within 30 days; raw PPG signals collected by the ring—if you leave Sleep PRO (Lab Version) testing or withdraw consent, we will physically delete or irreversibly anonymize these data within 30 days, unless otherwise required by law. Until then, the data will be stored in pseudonymized form for algorithm optimization; deletion when the experiment ends—if the experiment ends without the feature becoming generally available, we will physically delete or irreversibly anonymize the data within 30 days after the experiment ends; if the feature becomes generally available—before moving the data to the production environment, we will update this Privacy Policy and obtain your consent again. If you do not consent, you may request deletion of the relevant data; exception for immediate deletion—data in primary systems will be deleted within 30 days. If data is stored in backup systems, backup copies will be securely isolated and deleted on a rolling basis according to the backup update cycle (no longer than 12 months).

Special deletion terms for Wellness Squad data: sharing-authorization records—you may remove a person or stop sharing in the App at any time, and we will physically delete or irreversibly anonymize the relevant data within 30 days; exception for immediate deletion—data in primary systems will be deleted within 30 days. If data is stored in backup systems, backup copies will be securely isolated and deleted on a rolling basis according to the backup update cycle (no longer than 12 months).

Right to restriction of processing: You may ask us to restrict further processing of your personal information. In that case, the relevant information will be marked as restricted. We will store the data and process it only to respond to your request or if you later give consent. You may submit a request to dpo@ringconn.com.

Right to object: You may object to our processing of your personal information on grounds relating to your particular situation, including processing based on legitimate interests, the exercise of official authority, direct marketing (including data aggregation), or statistical purposes. You may submit a request to dpo@ringconn.com.

Right to object to direct marketing: You may object to the use of your personal information for direct marketing. You may submit a request to dpo@ringconn.com. If you no longer wish to receive our commercial advertising, you may opt out at any time through the feedback feature on our platform or by emailing dpo@ringconn.com.

When we rely on your consent to process your data, you may withdraw the consent you have given at any time, and we will stop further processing. You may give consent again at any time in the future. You may submit a request by emailing dpo@ringconn.com. If necessary, we will send a confirmation link to your registered email address to protect your data.

Special terms for withdrawing consent to Blood Pressure Trends:

Withdrawing consent to Blood Pressure Trends means: you will no longer be able to use the feature; we will stop collecting new data relating to Blood Pressure Trends; existing data will be handled under the deletion policy above; and withdrawal will not affect the lawfulness of processing based on consent before withdrawal. To request withdrawal, email dpo@ringconn.com.

Special terms for withdrawing consent to Sleep PRO (Lab Version):

Withdrawing consent to Sleep PRO (Lab Version) means: you will no longer be able to use the feature; we will stop collecting new data relating to Sleep PRO (Lab Version); existing data will be handled under the deletion policy above; and withdrawal will not affect the lawfulness of processing based on consent before withdrawal. To request withdrawal, email dpo@ringconn.com.

Special terms for withdrawing consent to Wellness Squad:

Withdrawing consent to Wellness Squad means: you will no longer be able to use the feature; we will stop sharing new health data with your friends and family; existing sharing-authorization records will be handled under the deletion policy above; and withdrawal will not affect the lawfulness of processing based on consent before withdrawal. To request withdrawal, email dpo@ringconn.com.

Right not to be subject to automated decision-making: Under the GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you. We do not process your information in this way. If you have questions or concerns, please contact us at dpo@ringconn.com.

Right to lodge a complaint: If you are dissatisfied with our response to your request or how we handle your personal information, you have the right to lodge a complaint with the applicable supervisory authority or other regulator.

11.4 EU/UK Representatives: RingConn is a controller established outside the EU and the United Kingdom. In accordance with Article 27 of the GDPR and the equivalent requirements of the UK GDPR, we have appointed representatives in the EU and the United Kingdom as contact points for EU/UK data subjects and supervisory authorities regarding the processing of personal data. The representatives’ names and contact details are published in Chapter 18, “Contact Us,” of this Policy and in the Privacy Center on the RingConn website. You may also contact us at dpo@ringconn.com at any time.

Health data and other special-category personal data: To the extent that data we collect constitutes health data or other special-category personal data under the GDPR, we will obtain your explicit consent before processing it. We will obtain this consent separately when you take an action that results in our obtaining the data (for example, pairing a device with an account). You may withdraw consent at any time in the account settings in the App or in your mobile-device settings, including by unpairing your device or deleting your data or account. We encourage you to contact us at dpo@ringconn.com first or at the same time so that we have an opportunity to address your concerns directly. We will respond within the time limit set by applicable law (for users in the EU/EEA/United Kingdom, no later than one month) and communicate with you appropriately.

12. Terms for California Users

12.1 Data Collection

When the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), applies, the information and rights in this section apply to users who reside in California.

During the preceding twelve (12) months, we have collected the following categories of personal information from consumers:

Category	Information	Data Sharing	Retention Period
Identifiers	Name or alias; email address; address; telephone number; account name; device serial number; IMEI number; MAC address; unique device ID; advertising ID; RingConn user ID.	Yes. Shared with crash and performance-monitoring SDK providers (Sentry and the Application Performance Monitoring Full-Link SDK) and push-service SDK providers (Tencent Mobile Push SDK, with Google FCM embedded on Android) for performance monitoring, error tracking, and push notifications; also shared with customer-support platforms. No advertising-related sharing.	Account data is deleted after account closure as described in Section 9.1; other data is retained for the shortest period necessary to fulfill the processing purpose.
Contact information	Name; preferred form of address; email address; address; telephone number; region or country.	Yes. Shared with customer-support platforms and third-party communications tools. No advertising-related sharing.	Account data is deleted after account closure as described in Section 9.1; customer-service/after-sales records are retained for two years after the product warranty expires, unless a longer period is required by law.
Protected classification characteristics	Gender; date of birth (year, month, and day).	No.	Account data is deleted after account closure as described in Section 9.1.
Sensitive personal information (health data)	Heart rate; blood oxygen (SpO₂); sleep-stage data; skin temperature; respiratory rate; heart-rate variability (HRV); menstrual-cycle and reproductive-health data (including menstrual records, symptom records, intercourse records and reminders, pregnancy status, time spent trying to conceive, conception-related experience, contraception methods, medical conditions, and readiness assessments).	No.	See Section 9.1 for retention periods for feature data; account data is deleted after account closure as described in Section 9.1.
Sensitive personal information (health data)—partner sharing for trying to conceive	Data shared with a trying-to-conceive partner: readiness, cycle overview, today’s symptoms, key recommendations, intercourse records, and intercourse reminders (for the previous week, current week, and following week).	Disclosed to another registered user you select only when you affirmatively share it through an invitation link in Fertility Tracking mode. This disclosure is made at your direction and does not constitute a “sale” or “sharing.”	See the Women’s Health and Fertility Tracking retention table in Section 9.1. After sharing stops or the connection is disconnected, the other person immediately loses access. If you choose “Disconnect and delete data,” data from the sharing period is deleted at the same time; backup copies are securely isolated and deleted on a rolling basis according to the backup update cycle (no longer than 12 months).
Internet or other network activity	App usage history; crash logs; in-App navigation data; feature-interaction data.	Yes. Shared with crash and performance-monitoring SDK providers (Sentry and the Application Performance Monitoring Full-Link SDK) and the user-behavior analytics platform (Sensors Data, in pseudonymized form) to improve App performance and user experience. No advertising-related sharing.	Retained for the shortest period necessary to fulfill the processing purpose.
Geolocation data	Approximate or precise location (only if the user enables GPS for Bluetooth pairing); Find My Ring location information (sensitive personal information, collected with authorization and limited to the purpose of finding the device).	No.	Retained for the shortest period necessary to fulfill the processing purpose.
Sensory data	Not collected directly (no voice, video, or photos, unless you upload a profile photo or voluntarily send an image, video, or audio through online customer support).	No.	Profile photos are deleted after account closure as described in Section 9.1; customer-support communications are retained for two years after the product warranty expires, unless a longer period is required by law.
Inferred health information	Activity level; stress level; menstrual-cycle predictions; sleep-quality trends.	No.	See Section 9.1 for retention periods for feature data; account data is deleted after account closure as described in Section 9.1.
Device-related information	Phone model; operating system; screen size; system language; network provider; push-notification ID; time zone.	Yes. Shared with third-party SDKs for App operation and push services (push services are provided by Tencent Mobile Push SDK, with Google FCM embedded on Android). No advertising-related sharing.	Retained for the shortest period necessary to fulfill the processing purpose.
Inferences drawn from other personal information	Personalized health reports; stress levels or cycle phases predicted from sensor data.	No.	See Section 9.1 for retention periods for feature data; account data is deleted after account closure as described in Section 9.1.
Third-party sign-in credentials	Apple stable user identifier, Google account ID, and display name (if you use third-party sign-in).	Yes. Shared with sign-in providers to support authentication. No advertising-related sharing.	Retained until you unlink the third-party account or until account closure, after which it is deleted as described in Section 9.1.
Other personal information	Ring type and customer-support communications. Activity information before blood pressure calibration/assessment: preset or custom activity labels such as eating, drinking alcohol, smoking, exercise, insufficient sleep, taking blood-pressure medication, and mood fluctuations.	Yes. Shared with customer-support platforms only when you inquire about a relevant issue and sharing is necessary. No advertising-related sharing.	Customer-service/after-sales records are retained for two years after the product warranty expires, unless a longer period is required by law; other data is deleted after account closure as described in Section 9.1.
Sensitive personal information (health data)—Blood Pressure Trends	Questionnaire information: gender, date of birth, height, weight, blood pressure status, use of blood-pressure medication, family history of high blood pressure, and diagnosed conditions (such as stroke, coronary heart disease, heart failure, atrial fibrillation, sleep apnea, high cholesterol, and diabetes). Physiological signals: PPG signals collected by the ring and accelerometer data used to analyze circulation stress. Manually entered data: systolic and diastolic blood pressure.	Disclosed to another registered user you select only if you affirmatively enable sharing through Wellness Squad. This disclosure is made at your direction and does not constitute a “sale” or “sharing.” These data are used only to provide Blood Pressure Trends and, other than disclosures you direct as described above, are not shared with advertisers or external organizations.	See the Blood Pressure Trends retention table in Section 9.1. Data in primary systems is deleted within 30 days after you withdraw consent, request deletion, or close your account. Backup copies are securely isolated and deleted on a rolling basis according to the backup update cycle (no longer than 12 months).
Inferences drawn from personal information (Blood Pressure Trends)	Blood pressure status assessment: a qualitative description generated by an algorithmic model (stable, slight change, or significant change). Related factors: circadian-rhythm adaptation, sleep and respiratory health, vascular recovery after exercise, and all-day vascular stability. Circulation-stress metrics: metric names and values displayed externally.	No. These inferences are generated from personal information you provide and data collected by the ring and are not shared externally.	Deleted at the same time as the raw PPG signals; see the Blood Pressure Trends retention table in Section 9.1.
Sensitive personal information (health data)—Sleep PRO (Lab Version)	Questionnaire information (if any): gender, date of birth, height, weight, etc. Physiological signals: PPG signals, heart rate, heart-rate variability, blood oxygen, movement, and other multidimensional physiological signals. Analysis results: sleep stages, sleep and wake times, number and level of micro-awakenings, and sleep-continuity and stability metrics.	No. These data are used only to provide Sleep PRO (Lab Version) and optimize its algorithms and are not shared with advertisers or external organizations.	See the Sleep PRO (Lab Version) retention table in Section 9.1. Data in primary systems is deleted within 30 days after you leave the experiment, withdraw consent, request deletion, or close your account. Backup copies are securely isolated and deleted on a rolling basis according to the backup update cycle (no longer than 12 months).
Inferences drawn from personal information (Sleep PRO Lab Version)	Sleep-analysis results, such as sleep stages, micro-awakening levels, and sleep-continuity metrics.	No. These inferences are generated from personal information you provide and data collected by the ring and are not shared externally.	See the Sleep PRO (Lab Version) retention table in Section 9.1.
User-behavior analytics data (Sensors Data)	Pseudonymized user-behavior data such as page-view paths, clicks, feature-use frequency, time spent, and page-navigation paths; user ID (for user segmentation and delivery of surveys/research invitations).	No. These data are processed in pseudonymized form solely to improve products and are not shared with advertisers.	Retained in pseudonymized form for the shortest period necessary to fulfill the processing purpose.
Sensitive personal information (health data)—Wellness Squad sharing	Sleep data (total sleep duration, sleep efficiency, sleep heart rate, and sleep blood oxygen saturation); stress (stress level and total stress duration); vital signs (heart rate, blood oxygen, and heart-rate variability); activity (total calories burned, steps, and all-day activity intensity); health alerts (headache indicators, abnormal vital signs, and sun-exposure dehydration); reports (weekly health report and comprehensive sleep apnea risk assessment report); Blood Pressure Trends data (circulation stress and blood pressure records); Sleep PRO (Lab Version) data (sleep stages, sleep and wake times, number and level of micro-awakenings, and sleep-continuity and stability metrics).	Disclosed to another registered user you select only if you affirmatively enable sharing through Wellness Squad. This disclosure is made at your direction and does not constitute a “sale” or “sharing.” These data are used only for health-data sharing through Wellness Squad and, other than disclosures you direct as described above, are not shared with advertisers or external organizations.	See the Wellness Squad retention table in Section 9.1. Data in primary systems is deleted within 30 days after you stop sharing, remove a friend or family member, or close your account. Backup copies are securely isolated and deleted on a rolling basis according to the backup update cycle (no longer than 12 months).
Plan and transaction information	Product ID; plan name; price; currency; billing period; promotional information; order number; transaction ID; plan status; purchase date; renewal date; expiration date; transaction status; user ID.	Yes. Interactions with Apple Inc. and Google LLC for App-store plan transactions, plan-status verification, and platform plan management. No advertising-related sharing; not sold.	Retained while your account is active and for as long as needed to perform the contract and for tax, accounting, audit, dispute-resolution, anti-fraud, and legal-compliance purposes; following account closure or a deletion request, deleted or anonymized under this Policy except where retention is required by law.

12.2 Your Rights

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights. A request may be submitted directly by a user or, where applicable, by the user’s authorized agent.

Right to know and access: You may ask RingConn to disclose certain information about the personal information we collected and used during the past 12 months. After we receive and verify your verifiable consumer request, we will disclose: the categories of personal information we collected about you; the categories of sources from which we collected that information; our business or commercial purposes for collecting or sharing it; whether we shared or sold your personal information and, if so, the categories of third parties with whom we shared it; the specific personal information we collected about you (also known as a data portability request); and, if we disclosed your personal information for a business purpose, the categories of personal information received by each category of recipient. You can view or access your personal data directly in the interface of our products or services after signing in to your account. You may also use the feedback feature in the RingConn App or email dpo@ringconn.com to inquire about or access your personal data.

Right to data portability: To the extent permitted by law, you may obtain a copy of your personal data in a structured, commonly used, machine-readable format. After providing formal authorization, you may exercise this right through the feedback feature in the RingConn App or by emailing dpo@ringconn.com.

Right to correct personal information: You may ask us to correct inaccurate personal information about you and, having regard to the purposes of processing, to complete incomplete personal information. You can correct or change some personal data directly on the relevant feature page of our products or services, or contact us at dpo@ringconn.com.

Right to delete: You may ask us to delete some or all personal information about you. You can delete information you have submitted directly in the product interface associated with your account. You may also contact us using the feedback feature on our platform or by emailing dpo@ringconn.com.

Special terms on the right to delete Blood Pressure Trends data: under the CCPA, you may request deletion of data relating to Blood Pressure Trends; assessment records and blood pressure values you entered manually will be deleted within 30 days; if you request deletion of raw PPG signals collected by the ring, we will delete or irreversibly anonymize them within 30 days unless you consent to their use for subsequent algorithm optimization; exception—data in primary systems will be deleted within 30 days. If data is stored in backup systems, backup copies will be securely isolated and deleted on a rolling basis according to the backup update cycle (no longer than 12 months).

Special terms on the right to delete Sleep PRO (Lab Version) data: under the CCPA, you may request deletion of data relating to Sleep PRO (Lab Version); analysis results and feature-usage records will be deleted within 30 days; if you request deletion of raw PPG signals collected by the ring, we will delete or irreversibly anonymize them within 30 days unless you consent to their use for subsequent algorithm optimization; if the experiment ends without the feature becoming generally available, we will delete or irreversibly anonymize the data within 30 days after the experiment ends; exception—data in primary systems will be deleted within 30 days. If data is stored in backup systems, backup copies will be securely isolated and deleted on a rolling basis according to the backup update cycle (no longer than 12 months).

Special terms on the right to delete Wellness Squad data: under the CCPA, you may request deletion of data relating to Wellness Squad; sharing-authorization records will be deleted within 30 days; exception—data in primary systems will be deleted within 30 days. If data is stored in backup systems, backup copies will be securely isolated and deleted on a rolling basis according to the backup update cycle (no longer than 12 months).

Service-provider disclosures and the right to opt out of sale or sharing: We may disclose personal information to contractually restricted service providers or contractors to operate, maintain, and support our Services. Where the applicable CCPA/CPRA requirements are met, these disclosures are not a “sale” or “sharing” as defined by law. If any of our processing activities constitutes a sale, or sharing for cross-context behavioral advertising, you may exercise the opt-out right using the methods described in the next paragraph. For information about our third-party disclosures, contact dpo@ringconn.com.

Right to opt out of the sale or sharing of personal information: To the extent provided by applicable law, you may ask us to stop selling your personal information or sharing it with third parties for purposes such as cross-context behavioral advertising. You may exercise this right using any of the following methods, and we will process your request as required by law after verifying your identity: email dpo@ringconn.com; submit a request through the privacy settings in the App; or submit a request through the “Do Not Sell or Share My Personal Information” link provided on our website homepage and in the App privacy settings. Global Privacy Control (GPC): We honor and respond to Global Privacy Control browser signals that meet applicable technical standards and treat them as valid requests to opt out of the sale or sharing of personal information.

Right to limit the use or disclosure of sensitive personal information: If we use sensitive personal information beyond what is necessary to provide the Services you request, or in another circumstance in which applicable law provides a right to limit, you may ask us to limit its use or disclosure to what is necessary to provide the Services you request or to comply with legal obligations. We currently use sensitive personal information only to provide the Services you request. You may exercise this right through the privacy settings in the App (Me > App Settings > Privacy) or by emailing dpo@ringconn.com. We will process your request as required by law after verifying your identity.

Right to non-discrimination: We will not discriminate against you for exercising any CCPA right. Unless permitted by the CCPA, we will not: deny you goods or services; charge different prices or rates for the same goods or services, including by granting discounts or other benefits or imposing penalties; provide you with a different level or quality of the same goods or services; or suggest that you may be charged a different price or rate or receive a different level or quality of the same goods or services. Other California privacy rights: California’s “Shine the Light” law (Civil Code Section 1798.83) allows California residents to request certain information about our disclosure of personal information to third parties for their direct-marketing purposes.

13. Special Notice Regarding U.S. Consumer Health Data

This section applies to consumers in Washington, Nevada, and other states with similar mandatory requirements, including users covered by the Washington My Health My Data Act (MHMDA), Nevada consumer health data law (Nevada SB 370), and similar laws.

13.1 Categories of Consumer Health Data

With your consent, we may collect or generate the following consumer health data: heart rate and heart-rate variability; blood oxygen; sleep status, sleep stages, and sleep quality; skin temperature; activity, exercise, and recovery data; stress or physical-condition metrics; menstrual-cycle and reproductive-health data (including average cycle length, period duration, cycle regularity, relevant medical history, time spent trying to conceive, conception-related experience, contraception methods used in the past six months, menstrual records such as flow/spotting/menstrual pain/symptoms/ovulation/medication use/alcohol or tobacco use, intercourse records and reminders, pregnancy-status indicators, readiness assessments, partner-shared trying-to-conceive data, conception windows, fertility trends, and other fertility-awareness data you enter or that is generated through analysis); OSAHS-related risk alerts; Blood Pressure Trends questionnaire information, manually entered blood pressure values, PPG signals, accelerometer data, activity information, and algorithmic analysis results; Sleep PRO (Lab Version) questionnaire information (if any), PPG signals, heart rate, heart-rate variability, blood oxygen, movement data, sleep-stage data, micro-awakening data, and algorithmic analysis results; medical history, medication information, family medical history, or symptom information you provide; and health trends, reports, recommendations, or insights inferred or generated from the data above. Retention periods for these consumer health data are described in Section 9.1. The specific retention periods for feature-related health data are set out in the retention tables for Blood Pressure Trends and Sleep PRO (Lab Version) in Section 9.1. We retain other consumer health data for the shortest period necessary to fulfill the processing purposes and delete it after account closure in accordance with Section 9.1.

13.2 Sources of Data

Consumer health data may come from you directly; our products or the App; third-party health platforms you authorize; algorithmic analysis we perform using device data and information you provide; or your communications with customer service or support teams.

13.3 Purposes of Processing

Additional notice for RingConn Partner (AI Conversations) and RingConn Partner+: Processing purposes include providing RingConn Partner (AI Conversations), AI health-interpretation services, and related benefits. Within the scope of data you have authorized and separately consented to, AI Conversations/AI health interpretation may use consumer health data to generate health trends, reports, recommendations, or insights. We do not sell consumer health data and will not share it with third parties unless we have valid authorization or the law permits us to do so.

We process consumer health data to provide health features and reports you request; provide Blood Pressure Trends; provide optional features such as Sleep PRO (Lab Version); sync device and App data; perform calibration and trend analysis and provide personalized displays; provide customer support; protect security, troubleshoot, and maintain the Services; optimize algorithms, conduct research, or improve products after obtaining additional consent; and comply with legal obligations and handle disputes.

13.4 Sharing Consumer Health Data

We do not sell consumer health data. We will not share consumer health data with third parties unless we have your valid authorization or the law permits us to do so.

Separate consent for collection: We will obtain your separate consent to “collect” consumer health data before collecting it.

Separate consent for sharing: Before sharing your consumer health data with a third party, we will obtain your separate consent to “share” it, including sharing through Wellness Squad.

The separate-consent requirements and commitment not to sell also apply to menstrual-cycle and reproductive-health data, including fertility-awareness data, intercourse records and reminders, pregnancy-status indicators, readiness assessments, and partner-shared trying-to-conceive data.

If we ever sell consumer health data in the future (which we do not currently do), we will first obtain valid written authorization that meets legal requirements and specifies the categories of consumer health data to be sold, the buyer’s name, the purpose of the sale, the authorization’s validity period (no more than one year), and your right to revoke the authorization at any time.

We may disclose consumer health data to service providers (such as cloud-service, data-analytics, and customer-support providers) so that they can provide cloud storage, data processing, customer support, security maintenance, or technical services on our behalf. These service providers may process data only on our instructions and are subject to contractual restrictions. You may request the list of recipient categories by emailing dpo@ringconn.com.

We do not use geofencing technology to identify, track, or collect consumer data from medical facilities, health-service providers, or similar sensitive locations, or to send advertising or notifications to such locations.

13.5 Your Rights

To the extent permitted by applicable law, you may: confirm whether we collect, share, or sell your consumer health data; access your consumer health data; obtain a list of the categories of consumer health data we collect or share; obtain a list of categories of third-party or affiliate recipients; withdraw consent; request deletion of consumer health data; and appeal our denial of your request.

You may exercise your rights through the privacy settings in the App or by emailing dpo@ringconn.com. If we deny your request, you may appeal. We will process your appeal and respond to you in writing within 45 days after receiving it (or within the period required by applicable law).

14. Terms for Users in Japan

When Japan’s Act on the Protection of Personal Information (APPI) applies to RingConn, this section applies to users residing in Japan.

14.1 Notice and publication of purposes of use: Through this Policy and in-feature notices, we will notify you of or publish the purposes for which personal information is used by our features, including RingConn Partner (AI Conversations). If the purposes of use change, we will notify you or publish the changes through an update to this Policy or an in-feature notice before the change takes effect. If the changed purposes go beyond a reasonably related scope that you would ordinarily expect, we will obtain your consent in advance.

14.2 Special-care-required personal information: Your medical history, the fact that you have received medical care, and descriptions of medical history or symptoms that you voluntarily enter during AI Conversations may constitute special-care-required personal information under the APPI. We obtain and process such information only with your prior consent.

14.3 Regional exclusion of blood-pressure data: RingConn Partner (AI Conversations) for users in Japan does not connect to or process any blood-pressure-related data, including blood pressure records, circulation stress, calibration/assessment records, Blood Pressure Trends factors, questionnaire responses, or Blood Pressure Trends data.

14.4 Processing of AI conversation data: Based on your conversation instructions, AI Conversations accesses necessary data from the data you have authorized and retrieves only data relevant to the current question when you ask a question or trigger a feature; it does not load all data when you enable the feature. AI conversation data is stored on servers/data platforms in the United Kingdom, and the entrusted-processing arrangement is described in Chapter 7 of this Policy. We do not use identifiable health data or conversation records for model training, algorithm optimization, research, or product improvement.

14.5 Your rights: You may exercise your rights of disclosure, correction, suspension of use, deletion, and other rights under the APPI as described in Section 10 of this Policy. You may also delete individual conversations, clear your conversation history, or turn off and clear data relating to AI Conversations at any time.

15. Our Policy Regarding Children

Our products and services are not directed to minors. Minors may not register an account or provide personal information to us. Our products and services are available only to adults aged 18 or older, and every feature—including Blood Pressure Trends, Sleep PRO (Lab Version), Wellness Squad, and Women’s Health and Fertility Tracking—is available only to users aged 18 or older. If you are under 18, do not register an account, use our products or services, or provide any personal information to us.

We do not knowingly collect personal information from minors. As defined by the California Consumer Privacy Act (CCPA) and its regulations, we do not sell or share the personal information of minors.

If we become aware that we have collected personal information from a minor without appropriate authorization, we will delete the data and stop processing it as soon as practicable after becoming aware. If you believe that we may be improperly holding personal information of a minor, please contact us using the contact details in this Policy.

16. Cookies, SDKs, and Similar Technologies

We may use cookies, SDKs, pixel tags, local storage, log files, or similar technologies to provide website and App features, maintain login status, analyze usage, improve performance, troubleshoot, and protect security.

16.1 Types of Cookies

We may use:

1. Strictly necessary cookies: to operate the website, log in to your account, and maintain security;

2. Functional cookies: to remember your preferences;

3. Analytics cookies: to understand how the website and App are used;

4. Performance and diagnostic technologies: for crash analytics, troubleshooting, and performance improvement;

5. Advertising or marketing cookies, where consent has been obtained.

If we use non-essential cookies or similar technologies and applicable law requires consent, we will obtain your consent before using them.

16.2 SDK List

We describe the following information in the RingConn App Terms on SDK Collection of Personal Information:

1. SDK name;

2. provider;

3. purpose of use;

4. types of data collected;

5. whether cross-border transfers of personal information are involved;

6. whether the SDK is used for advertising, tracking, or cross-app identification; and

7. how users can disable or manage it.

The main third-party SDKs we currently use, grouped by purpose, include:

Special notice on third-party SDK processing of health data: Except for system-level health-platform capabilities such as Apple HealthKit and Google Health Connect / Google Fit, which you may authorize for health-data synchronization, other third-party SDKs do not collect your health, blood pressure, or sleep data. The health platforms above read and write health data only within the scope you authorize; Blood Pressure Trends data and Sleep PRO (Lab Version) data are not synchronized with those platforms.

1. Push notifications: Tencent Mobile Push SDK (Tencent Computer Systems Co., Ltd.; Google FCM is embedded on Android);

2. Crash and performance monitoring: Sentry (Functional Software, Inc.) and the Application Performance Monitoring Full-Link SDK (Beijing Volcano Engine Technology Co., Ltd.);

3. Object storage: Object Storage SDK (Alibaba Cloud Computing Co., Ltd.), used to upload and download files for feedback and similar purposes. At present, overseas user data is stored centrally on servers/data platforms in the United Kingdom and is not transferred back to mainland China;

4. Mapping services: Google Maps SDK (Google LLC);

5. User-behavior analytics: Sensors Analytics SDK (Sensors Data Technology Co., Ltd.);

6. Third-party sign-in: Google Sign-In (Google LLC) and Sign in with Apple (Apple Inc.);

7. Health-platform integration: Apple HealthKit (iOS) and Google Health Connect / Google Fit (Android).

8. App-store payments: StoreKit 2 (Apple Inc., iOS system capability) and Google Play Billing Library 8.0.0 (Google LLC, Android), used to display plan products, initiate purchases, check transaction status, verify plans, and restore entitlements.

For SDK versions, details of data collected, and links to third-party privacy policies, please see the terms referenced above. SDK processing locations: Tencent Mobile Push SDK processes overseas users’ data at a node in Singapore; the Application Performance Monitoring Full-Link SDK (Beijing Volcano Engine Technology Co., Ltd.) processes overseas users’ data at a node in Johor, Malaysia. Neither transfers overseas user data back to mainland China. Please note that Singapore and Malaysia are third countries not recognized as adequate by the EU/United Kingdom. For these transfers and any other activity involving transfers of your personal information to a country or region not recognized as adequate (including to servers in mainland China or through remote access from mainland China), we will implement the safeguards described in Chapter 8 of this Policy, including the EU Standard Contractual Clauses, the UK Addendum or IDTA, transfer impact assessments, and supplementary protections such as encryption.

Special notice: We use the Sensors Data platform SDK to analyze user behavior to support user research and product improvement. The Sensors SDK collects pseudonymized user-behavior data, such as page-view paths, clicks, feature-use frequency, and time spent; it is not used for advertising, tracking, or cross-app identification. For users in the EU/EEA/United Kingdom, we will obtain your consent before conducting in-App behavioral analytics. Sensors Data processing is deployed at overseas nodes; if a cross-border transfer or remote access from outside the deployment region occurs, we will apply the safeguards in Chapter 8 of this Policy. You may turn off the relevant data collection in the App settings or through your device permissions. If you do not want to receive questionnaires or research invitations based on user-behavior data, you may use an opt-out link in an email or contact dpo@ringconn.com to exercise your right to object.

If the processing purpose, data categories, access permissions, access frequency, or third-party recipients of an SDK change materially, we will notify you as required by law and obtain your consent again where required.

17. Updates to This Privacy Policy

This Policy may be updated to reflect changes in the Services, our business, or applicable law. We will not apply broader data-processing rules retroactively to personal data already collected merely by silently replacing this Policy. For material changes, we will actively notify you as described below and obtain your consent again where required by applicable law. The current version is always available in the RingConn App and on our website (https://www.ringconn.com). You may also use the “Version History” link in the website Privacy Center to view earlier versions that were publicly effective during the preceding twenty-four (24) months, their effective dates, and summaries of the principal changes. To request an earlier version, email dpo@ringconn.com. We retain version archives and applicable notice and consent records for as long as necessary to fulfill our legal obligations, handle disputes, and demonstrate compliance.

Special notice on updates to the Blood Pressure Trends privacy notice: If there is a material change to the purposes, methods, or categories of personal information collected or used, the names or frequency of permissions accessed, or the way data is processed, we will notify you by an in-App pop-up, a prominent on-screen notice, or another appropriate means and obtain your explicit consent again.

Special notice on updates to the Sleep PRO (Lab Version) privacy notice: If there is a material change to the purposes, methods, or categories of personal information collected or used, the names or frequency of permissions accessed, or the way data is processed, we will notify you by an in-App pop-up, a prominent on-screen notice, or another appropriate means and obtain your explicit consent again.

Special notice on updates to the Wellness Squad Data Sharing Authorization Agreement: If there is a material change to the RingConn App Wellness Squad Data Sharing Authorization Agreement (for example, a change to the scope of sharing, invitation method, or maximum number of people), we will obtain your separate consent again.

Special notice on updates to the Women’s Health and Fertility Tracking privacy policy: If there is a material change to the purposes, methods, or categories of personal information collected or used by Women’s Health and Fertility Tracking, or to the way data is processed (including the redesign in version 4.5.0), we will notify you through a separate screen or prominent notice when you upgrade or first enter the updated feature and obtain your explicit consent again. The updated Women’s Health feature will not be available until you consent, but other basic App features will not be affected.

Without your express consent, we will not diminish your rights under this Privacy Policy.

For material changes, we will also provide more prominent notice, including, for certain Services, an email describing the specific changes to the Privacy Policy.

Material changes include, but are not limited to:

1. A material change in our service model, such as the purposes or types of personal information processed or the way personal information is used;

2. A material change in our ownership or organizational structure, such as a change of control resulting from business restructuring, bankruptcy, or a merger or acquisition;

3. A change in the principal recipients of personal information that is shared, transferred, or publicly disclosed;

4. A material change in your rights relating to personal-information processing or the way you may exercise those rights;

5. A change in the department responsible for personal-information security, its contact information, or the channels for complaints; or

6. A high-risk finding in a personal-information security impact assessment.

18. Contact Us

If you have questions about this Policy or need help exercising your privacy rights, please contact us using the details below:

• Data Protection Officer (DPO): dpo@ringconn.com

• Personal Information Protection Team: datacompliance@ninenovo.com

• Customer Support: cs@ringconn.com

• Company address: Room 2, 7/F, Block B, Wah Tat Industrial Centre, 8 Wah Sing Street, Kwai Chung, Hong Kong

ONOVO TECHNOLOGY (HONG KONG) LIMITED

• EU Representative (GDPR Article 27 representative): If you are in the European Economic Area (EEA) and have questions about your personal data or wish to request access, an update, or deletion, you may contact our EU representative: Bird & Bird GDPR Representative Services SRL, Avenue Louise 235, 1050 Brussels, Belgium; email: RingConn@twobirds.com.

• UK Representative (UK GDPR representative): If you are in the United Kingdom and have questions about your personal data or wish to request access, an update, or deletion, you may contact our UK representative: Bird & Bird GDPR Representative Services UK, 12 New Fetter Lane, London, EC4A 1JP, United Kingdom; email: RingConn@twobirds.com.

Appendix: RingConn Blood Pressure Trends Privacy Notice / RingConn Sleep PRO (Lab Version) Privacy Notice / RingConn App Wellness Squad Data Sharing Authorization Agreement / RingConn Partner+ Privacy Agreement / Women’s Health and Fertility Tracking Privacy Policy

This Appendix forms part of the RingConn App Privacy Policy and applies respectively to Blood Pressure Trends, Sleep PRO (Lab Version), Wellness Squad, RingConn Partner+ services, and Women’s Health and Fertility Tracking. If this Appendix (including the RingConn Blood Pressure Trends Privacy Notice / RingConn Sleep PRO (Lab Version) Privacy Notice / RingConn App Wellness Squad Data Sharing Authorization Agreement / RingConn Partner+ Privacy Agreement / Women’s Health and Fertility Tracking Privacy Policy) conflicts with the main Privacy Policy, this Appendix controls.

For this version, RingConn Partner (AI Conversations) is subject to the special rules in the body of this Policy concerning AI Conversations, separate consent for sensitive personal information, algorithmic transparency, non-medical use, and disabling and clearing data. Any necessary consent is obtained through the legal summary displayed at the feature entry point.

RingConn APP Privacy Policy

0. About the Controller of Your Personal Data

This Privacy Policy covers:

1. Introduction and Important Notices

1.1 Introduction

1.2 Important Notices

2. Data We Collect

2.1 Information We Collect from You

2.2 Information Generated and Collected Automatically

2.3 Information from Third Parties

2.4 Customer Service Information

2.5 RingConn Partner+ Value-Added Services and AI Health Insights Data

2.6 RingConn AI Chat Data

3. How We Use Your Data

3.1 Providing and Maintaining Our Services

3.2 Improving and Developing Our Products and Services

3.3 Providing Customer Support and Online Customer Service

3.4 Compliance with Legal Obligations

3.5 Algorithm Optimization and Model Iteration

4. Special Terms for the Blood Pressure Trends Feature

4.1 Nature of the Feature

4.2 Data We Process

4.3 Legal Basis and Consent

4.4 Withdrawal of Consent

5. Special Terms for Sleep PRO (Lab Version)

5.1 Nature of the Feature

5.2 Data We Process

5.3 Legal Basis and Consent

5.4 Data Use

5.5 Data Storage

5.6 Data Retention

5.7 Withdrawal of Consent

6. Automated Processing, Algorithmic Transparency, and Health Insights

7. How We Share and Disclose Data

7.1 Processing by External Third Parties

7.2 With Your Consent or at Your Direction

7.3 Legal Compliance and Law Enforcement

8. Data Storage and Transfers

9. Data Retention and Security

9.1 Data Retention

9.2 Data Security

10. Your Rights

10.1 Rights Under Applicable Law

10.2 How to Exercise Your Rights

11. Terms for Users in the EU/EEA and United Kingdom

11.1 Legal Bases for Processing

11.2 Key Processing Activities, Data Categories, and Legal Bases

11.3 Your Rights

12. Terms for California Users

12.1 Data Collection

12.2 Your Rights

13. Special Notice Regarding U.S. Consumer Health Data

13.1 Categories of Consumer Health Data

13.2 Sources of Data

13.3 Purposes of Processing

13.4 Sharing Consumer Health Data

13.5 Your Rights

14. Terms for Users in Japan

15. Our Policy Regarding Children

16. Cookies, SDKs, and Similar Technologies

16.1 Types of Cookies

16.2 SDK List

17. Updates to This Privacy Policy

18. Contact Us