PRIVACY POLICY

Last Updated: December 9, 2025

1. INTRODUCTION

Forward Ethos ("we," "us," or "our") respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our mobile application (the "App") and tell you about your privacy rights and how the law protects you.

Important Note Regarding Medical Data: This App is a self-help and educational tool. It is not a healthcare provider or a "covered entity" under the Health Insurance Portability and Accountability Act (HIPAA). The information you input into this App is not considered Protected Health Information (PHI) under HIPAA.

2. THE DATA WE COLLECT

We collect, use, store, and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data: Includes first name, last name, username or similar identifier, title, and date of birth.

  • Contact Data: Includes email address and telephone number.

  • Financial Data: Includes details about payments to and from you (e.g., transaction receipts). Note: We do not store or collect your payment card details (such as credit/debit card numbers). That information is provided directly to our third-party payment processors (Apple App Store or Google Play Store), whose use of your personal information is governed by their Privacy Policy.

  • Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this App.

  • Profile Data: Includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.

  • Usage Data: Includes information about how you use our App, products, and services (e.g., course progress, time spent on pages).

  • User Content (Journal Data): Includes the text, images, and other content you input into the journal or exercise features of the App. Note: As stated in our Terms of Service, Journal Data is stored locally on your device and is not accessible by Forward Ethos unless you explicitly choose to back it up or share it.

3. MOBILE APP SPECIFIC PERMISSIONS

To provide specific features, our App may request access to the following permissions on your mobile device. You can manage these permissions in your device settings at any time.

  • Camera: Used to allow you to take photos for your profile or journal entries.

  • Photo Library: Used to allow you to upload existing photos to your profile or journal entries.

  • Microphone: Used if you choose to use voice-to-text features for journaling or record audio notes (if available).

  • Push Notifications: Used to send you reminders, course updates, and daily affirmations.

4. HOW WE USE YOUR PERSONAL DATA & LEGAL BASIS (GDPR)

We will only use your personal data when the law allows us to. Under GDPR, we rely on the following legal bases to process your data:

  • Performance of Contract: To register you as a new customer, process your subscription, and give you access to the App's features.

  • Legitimate Interest: To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

  • Legal Obligation: To notify you about changes to our terms or privacy policy, or to comply with accounting and tax requirements.

  • Consent: We generally do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

5. COOKIES & TRACKING TECHNOLOGIES

While our App does not use traditional browser cookies, we use mobile "identifiers" (like Android Advertising ID or Apple IDFA) and tracking technologies (SDKs) to recognize your device and collect information about your usage.

  • Why we use them: To authenticate users, remember user preferences, and analyze App performance.

  • Your Control: You can control how these technologies track you through your device settings (e.g., "Ask App Not to Track" on iOS or "Opt out of Ads Personalization" on Android).

6. DISCLOSURE OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

  • Service Providers: Companies that provide IT and system administration services (e.g., Google Firebase, AWS).

  • Analytics Providers: We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.

    • Tools used: Flurry, Firebase, Count.ly, AppsFlyer, Facebook App Events.

  • Professional Advisers: Lawyers, bankers, auditors, and insurers.

  • Legal Authorities: If required by law or in response to valid requests by public authorities (e.g., a court or a government agency).

We do NOT sell your personal data to third parties.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed.

  • Encryption: We use Secure Socket Layer (SSL) encryption for all data in transit. Account passwords are hashed and salted before storage.

  • Access Control: We limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.

8. DATA RETENTION & DELETION

How long will you use my personal data? We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

How to Delete Your Account: You may delete your account and all associated hosted data at any time directly within the App:

  1. Go to Settings.

  2. Select Account.

  3. Tap Delete Account.

Alternatively, you may email us at [email protected] with the subject line "Delete My Account." Please note that simply deleting the App from your device does not delete your account or cancel your subscription.

9. YOUR LEGAL RIGHTS (GDPR - FOR EUROPEAN USERS)

If you are located in the European Economic Area (EEA) or the UK, you have rights under data protection laws in relation to your personal data, including the right to:

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Object to processing of your personal data.

  • Request restriction of processing your personal data.

  • Request transfer of your personal data.

  • Right to withdraw consent.

To exercise any of these rights, please contact us at [email protected].

10. YOUR CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with specific rights regarding your personal information:

  1. Right to Know: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.

  2. Right to Delete: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.

  3. Right to Opt-Out of Sale/Sharing: We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising.

  4. Right to Limit Use of Sensitive Personal Information: You have the right to limit the use of your "sensitive personal information" (e.g., precise geolocation, health data) to that which is necessary to perform the services.

  5. Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

"Do Not Sell or Share My Personal Information" Forward Ethos does not sell your personal information. To exercise your rights to know, delete, or correct your data, please contact us at [email protected].

Do Not Track Signals Our App currently does not respond to "Do Not Track" (DNT) signals or similar mechanisms transmitted by web browsers.

Shine the Light Law California Civil Code Section 1798.83 permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

11. CHILDREN'S PRIVACY

Our App is not intended for children under 13 years of age (or 16 in certain jurisdictions like the EEA). We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe we have collected information from your child, please contact us immediately, and we will remove such data.

12. INTERNATIONAL TRANSFERS

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States. We ensure such transfers are carried out in compliance with applicable data protection laws, primarily by relying on Standard Contractual Clauses (SCCs) approved by the European Commission.

13. CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top. You are advised to review this Privacy Policy periodically for any changes.

14. CONTACT US

If you have any questions about this Privacy Policy, please contact us: