Privacy Policy

1) Information We Collect

A. Information you provide directly

• Contact details (e.g., name, email address, phone number, mailing address)
• Information submitted through forms (e.g., waitlist, inquiries, intake/onboarding details you choose to provide)
• Communications (e.g., emails, messages, support requests, feedback)
• Payment-related information for purchases (if applicable), which is processed by third-party payment processors; we typically do not store full payment card numbers

B. Information collected automatically

When you visit the website or use the Services, we (and our service providers) may automatically collect:

• Device and usage data (e.g., IP address, browser type, device identifiers, operating system, pages viewed, links clicked, time spent, referring URLs)
• Approximate location (generally derived from IP address)
• Log data and diagnostic information

C. Information from third parties

If you choose to connect third-party services (for example, device platforms or other integrations), we may receive information from those providers as permitted by your settings and their terms.

If you choose to connect a wearable device or third-party health platform through your Moira membership, we will receive biometric and health data from that device's manufacturer or platform provider. Depending on the device, this may include:

• Sleep stages and duration
• Heart rate and heart rate variability (HRV)
• Body temperature and temperature deviation
• Blood oxygen levels (SpO2)
• Activity and movement data
• Recovery and readiness scores
• Other health signals generated by the device

Additional device integrations may be added over time.

Each device manufacturer or platform maintains its own privacy practices governing data collected through their products. Connecting a wearable or third-party health platform to your Moira membership is always voluntary. You may disconnect any device at any time without affecting your membership status.

D. Information about others

If you provide information about another person (for example, a family member), you represent you have authority to do so.

2) How We Use Information

We use information to:

• Provide, operate, and improve the Services
• Respond to requests, inquiries, and support needs
• Manage waitlists, enrollments, and memberships (if applicable)
• Communicate service-related updates and information you request
• Maintain security, prevent fraud, and protect the integrity of the Services
• Analyze website traffic and usage trends to improve performance and user experience
• Comply with legal obligations and enforce our Terms & Conditions
• Generate your Moira Vitality Score and personalized vitality plan, including using wearable data signals to inform proactive outreach, health trend detection, and care team follow-up

3) Cookies, Analytics, and Similar Technologies

Squarespace and Moira Club use cookies and similar technologies (like pixels and local storage) to operate the site, remember preferences, and understand usage.

We also use Google Analytics to help us understand how visitors interact with our website (for example, which pages are visited most, how long people stay, and how they found the site). Google Analytics may collect information such as your IP address, device identifiers, and browsing activity on our site, and may set cookies to do so.

Your choices

• Browser controls: Most browsers allow you to manage cookies through your settings (including blocking or deleting cookies).
• Google Analytics opt-out: You can opt out of Google Analytics by installing Google's opt-out browser add-on (search “Google Analytics opt-out add-on”).
• Cookie banner/consent tools: If we enable a cookie banner or consent tool, you can manage cookie preferences through that tool (where available).

Disabling cookies may affect how certain features function.

4) How We Share Information

We may share information as follows:

A. Service providers

We share information with vendors that help us operate the Services (e.g., website hosting and website functionality via Squarespace, analytics via Google Analytics, email/communications tools, customer support platforms, and payment processors). These providers are permitted to use information only to perform services for us.

This includes wearable device manufacturers and health platform providers whose platforms transmit biometric data to Moira Club on your behalf when you choose to connect a device. It also includes Healthie, our clinical platform, which may receive wearable-sourced data as part of your member health record. As Moira Club's device ecosystem grows, additional wearable partners may be added. Current integrations are listed in Section 14 of this policy.

B. Business transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, information may be transferred as part of that transaction.

C. Legal and safety reasons

We may disclose information if we believe it is necessary to:

• Comply with law or legal process
• Protect the rights, property, or safety of Moira Club, our users, or others
• Detect, prevent, or address fraud, security, or technical issues

D. With your direction

We may share information when you instruct us to do so (for example, when you ask us to coordinate with a third party you choose).

E. Aggregated / de-identified data

We may share aggregated or de-identified information that cannot reasonably be used to identify you.

5) Artificial Intelligence (AI) Services

Some features of the Moira Club app use artificial intelligence to provide personalized health insights, appointment summaries, and wellness coaching. To deliver these features, we send certain personal information to third-party AI service providers.

What data is sent

Depending on the features you use, we may send the following to AI services:

• Audio recordings of medical appointments (only with your explicit consent, and only when you choose to use our appointment recording feature)
• Health metrics from connected wearable devices (e.g., heart rate, sleep, activity)
• Health goals, wellness preferences, and information you share during coaching sessions

Who receives your data

We share data with the following third-party providers to power our AI features:

• Google Cloud Platform: Used for speech-to-text transcription (Google Cloud Speech-to-Text V2) and AI processing (Vertex AI with Gemini and Claude). Privacy policy: policies.google.com/privacy
• Healthie: Used for electronic health records and care plan storage. We maintain a Business Associate Agreement (BAA) with Healthie covering all protected health information. Privacy policy: gethealthie.com/privacy

How your data is protected

Each provider listed above is contractually required to use your data only to perform services for Moira Club, protect your information with security standards equivalent to or greater than our own, and not sell or share your data with other third parties for their own purposes.

Your consent and choices

The appointment recording feature requires your explicit consent before each use. All other AI features may be declined by contacting us at info@moiraclub.com. To request deletion of your data, email info@moiraclub.com.

6) Health-Related Information and HIPAA

Moira Club may collect information you consider health-related if you choose to provide it. Moira Club is not a health insurer and may not be a “covered entity” or “business associate” under HIPAA for all Services. If any part of the Services is provided by or on behalf of a HIPAA-regulated entity, additional privacy notices or consents may apply to those specific services.

Wearable data received from connected devices is treated as consumer wellness data unless and until it is incorporated into a HIPAA-regulated care record. When wearable data is reviewed by a licensed member of your Moira Vitality Team as part of a clinical care plan, it may be subject to applicable health privacy protections. If required, a separate HIPAA authorization or Notice of Privacy Practices will be provided to you prior to that use.

7) Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect information. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

8) Data Retention

We retain personal information for as long as reasonably necessary to provide the Services, comply with legal obligations, resolve disputes, enforce agreements, and for legitimate business purposes. Retention periods vary depending on the type of data and purpose.

9) Your Choices and Rights

Depending on where you live, you may have rights to:

• Access, correct, or delete your personal information (subject to legal exceptions)
• Request a copy of your personal information
• Opt out of certain processing (such as marketing emails)
• Limit or object to certain processing where applicable law provides
• Disconnect a wearable device from your Moira account at any time, without affecting your membership status
• Request deletion of previously collected wearable data by contacting us at info@moiraclub.com

Marketing opt-out: You can unsubscribe from promotional emails using the link in the email. You may still receive operational messages.

SMS choices: Consent to receive text messages is optional. You may choose whether to receive service-related text messages, promotional text messages, or both, and you may opt out at any time.

To make a request, contact us at info@moiraclub.com.

10) SMS Messaging Terms

If you opt in, you may receive text messages from Moira Club about your membership inquiry, scheduling, and service-related updates. If you separately opt in to promotional text messages, you may also receive marketing messages from Moira Club. Consent is not required to submit an inquiry or receive services. You can opt out at any time by replying STOP or request more information by replying HELP. Message frequency varies. Message and data rates may apply.

If you need assistance or have questions about our SMS service, reply with “HELP” to any SMS message you receive, email info@moiraclub.com, or call 303-709-7068.

No mobile information will be shared with third parties or affiliates for marketing/promotional purposes. All categories in this Privacy Policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

11) Children's Privacy

The Services are not intended for children under 13 (and in some jurisdictions, under 16). We do not knowingly collect personal information from children. If you believe a child has provided personal information, contact us and we will take appropriate steps to delete it.

12) International Users

If you access the Services from outside the United States, your information may be transferred to and processed in the United States or other jurisdictions where our service providers operate. Those jurisdictions may have different data protection laws than your location.

13) Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The “Last Updated” date indicates when changes were made. If we make material changes, we will provide notice as required by law. Your continued use of the Services after changes become effective means you accept the updated policy.

14) Wearable Device Data

If you participate in Moira Club's wearable integration program, the following additional terms apply.

What we collect

When you connect a wearable device or health platform to your Moira membership, we receive biometric and wellness data generated by that device or platform. The specific data we receive depends on the device and the permissions you grant, but may include sleep metrics, heart rate, HRV, body temperature deviation, SpO2, daily activity, and device-generated wellness and recovery scores. Current supported integrations include Oura Ring and Apple HealthKit. Additional integrations may be added over time and will be reflected in updates to this policy.

How we use it

Wearable data is used by your Moira Vitality Team and our AI-assisted platform to monitor meaningful trends over time, contribute to your Moira Vitality Score, and prompt proactive outreach when notable changes are detected. This data is never used for advertising purposes and is never sold to third parties.

Alert signals

Moira Club uses wearable data to generate health signals that may prompt different levels of follow-up from your care team. These signals are based on meaningful changes from your personal baseline and are designed to support proactive, personalized care.

Your control

Connecting any wearable device is always optional. You may disconnect a device at any time by contacting your care team or adjusting settings in the Moira app. Disconnecting stops the flow of new data to Moira Club but does not automatically delete data already received. To request deletion of previously collected wearable data, contact us at info@moiraclub.com.

Third-party device practices

Each wearable manufacturer and health platform independently collects and processes data through its own app and services. Moira Club is not responsible for their data practices. We encourage you to review the privacy policy of any device or platform you connect to your Moira membership.

Retention

Wearable data is retained as part of your member health record for the duration of your active membership and for a reasonable period thereafter, consistent with Section 7 of this policy.

15) Contact Us

Moira Club Partners, Inc.

Email: info@moiraclub.com

Phone: 303-709-7068