Privacy Policy

Last updated: [EFFECTIVE DATE]

DRAFT. NOT YET REVIEWED BY COUNSEL. DO NOT PUBLISH UNTIL A LICENSED ATTORNEY HAS REVIEWED IT. Bracketed items like [THIS] are placeholders. See NOTES.md.

This Privacy Policy explains how [COMPANY LEGAL NAME], LLC ("Upbee," "we," "us," or "our") collects, uses, shares and protects personal information when you use the Upbee assistant, text with Upbee through iMessage, SMS, MMS, RCS or other channels, visit our websites (including upbee.ai), or otherwise interact with us (together, the "Service"). It also explains the choices and rights you have.

This Privacy Policy is part of our Terms of Service at [upbee.ai/terms]. Capitalized terms not defined here have the meanings given in the Terms.

The short version

• We collect what you send Upbee (messages, photos, voice notes), what Upbee learns about you (your Memory), what you connect (like your calendar), and basic account, billing and device information.
• We use it to run your assistant: to answer you, remember things, remind you, and take the actions you approve.
• We don't sell your personal information or share it for targeted advertising. We don't use it for ads.
• We don't use your conversations to train AI models, and we require our AI providers not to train on them either.
• Your mobile number and text-message consent are never shared with anyone for their marketing.
• You're in control. Text "what do you know about me," "forget that," "forget everything," or "delete everything." Text STOP to stop messages.
• Upbee is for adults 18+ in the U.S.

1. Scope

This Privacy Policy applies to personal information we process as the operator of the Service. It does not apply to third-party services you connect to Upbee or reach through links from Upbee (such as your calendar provider, a restaurant's booking site, or a merchant), which have their own privacy policies.

The Service is offered only to adults in the United States. This Privacy Policy is written for U.S. residents (see Section 18).

2. Information we collect

2.1 Information you give us

• Sign-up and account information: your mobile phone number; your name or nickname (if you share it); date of birth (to confirm you're 18+); time zone; wake-up time; the things you'd like Upbee to help with; persona and messaging preferences (for example, "quieter"); and, if you buy a Paid Plan, your email address.
• Your messages and content: everything you text Upbee, including the text of your messages, photos, screenshots, PDFs and other files, voice notes, contact cards (vCards) you share, and your replies (such as YES to approve an action). Screenshots and files you send can contain information about other people (see Section 12).
• Payment information: if you buy a Paid Plan, our payment processor collects your payment card or wallet details and billing information. We don't receive or store your full card number; we receive limited information such as card type, last four digits, expiration date, billing ZIP code and transaction details.
• Student verification: if you choose student pricing, information needed to verify eligibility (for example, a school email address or a confirmation from a verification service).
• Support and feedback: information you provide when you contact us, take a survey or send feedback.
• Family Plan information: if you organize or join a Family Plan, the names and phone numbers of the adults you invite, and information you add to the shared household layer, which can include information about your children (see Section 11).

2.2 Information Upbee creates or learns about you (your "Memory")

To act like an assistant that knows you, Upbee builds and keeps a private profile from your conversations and connected services. This can include:

• People you mention and details about them (relationship, contact information, birthdays, preferences);
• Preferences (food, places, budgets, brands, times);
• Routines (wake time, busy days, when you usually reply);
• Goals, projects, plans, tasks, reminders, commitments and open loops ("did your landlord ever reply?");
• Life events you share (a new job, a move);
• Your communication style (message length, casing, emoji use, tone); and
• Summaries of past conversations.

Some of this is inferred: Upbee may draw conclusions from what you say (for example, that you go to the gym on Tuesdays). Upbee's inferences can be wrong, and you can correct or delete them at any time (Section 8).

2.3 Information from services you connect

If you choose to connect a service, we receive information from it according to the permissions you grant:

• Calendars (for example, Google Calendar, iCloud Calendar or Outlook): event titles, times, locations, attendees, descriptions and free/busy status, and the ability to add or change events you approve. For iCloud Calendar, you give us an app-specific password, which we store encrypted and use only to connect to your calendar.
• Email (where offered, for example Gmail or Outlook): the ability to send emails you approve from your account, and any limited email information described when you connect.
• Task and notes apps (for example, Todoist or Notion): the tasks, pages or items you choose to sync.
• Device automations you set up (for example, an Apple Shortcuts automation): signals such as "alarm stopped," "arrived at gym" or "charger plugged in," along with a token that identifies your account. These signals tell us an event happened; they don't give us continuous access to your device or location.

You can disconnect any service at any time (Section 8).

2.4 Information collected automatically

• Messaging metadata: the channel you use (iMessage, SMS, RCS), the Upbee number assigned to you, message timestamps, delivery and read status, and reactions (such as tapbacks). We may also ask our messaging providers whether a number can receive iMessage, so we can choose the right channel.
• Website and device information: when you visit our websites or open links we send, we collect your IP address, browser and device type, operating system, referring page, pages viewed, links clicked, and approximate location derived from your IP address. We use cookies and similar technologies for this (Section 13).
• Usage information: which features you use, how often, errors and performance data, and the cost and model used to answer you, which we use for reliability, fair use and billing.
• Approximate location: we infer your time zone and general area from your phone number's area code, IP address, or what you tell us. We don't collect precise GPS location from your device. If you share a location (for example, "find sushi near 5th and Main" or a shared address), we use it to fulfill your request.

2.5 Consent and compliance records

We keep records of your consent to receive messages (including the date, time, phone number, IP address, browser information, and the exact wording you agreed to), your opt-outs (such as STOP), your agreement to automatic renewal terms, and your age confirmation, so that we can honor your choices and show that we followed the law.

2.6 Information from other sources

• Referral and campaign information: if you came to Upbee through a creator, affiliate, referral link or ad campaign, we receive a code that tells us which one.
• Service providers: our payment processor (for example, payment status and fraud signals), messaging providers (for example, delivery status), and verification providers.
• Other users: a user may give us information about you, for example when they ask Upbee to text you, invite you to a Family Plan, add Upbee to a group chat you're in, or mention you in conversation (Section 12).

3. How we use information

We use personal information to:

1. Provide the Service: understand and reply to your messages; read photos, screenshots, files and voice notes you send; set and deliver reminders and scheduled messages; send your morning brief and other proactive messages; manage your calendar, lists and tasks; prepare drafts; and carry out the messages, emails, bookings, purchases and calls you approve.
2. Personalize Upbee for you: build and maintain your Memory so Upbee can recall details, follow up on things you mentioned, time its messages for when you're likely to read them, and write in a style that suits you.
3. Run your account and billing: create your account, verify your age and eligibility, process payments, manage trials, renewals and cancellations, send receipts and required notices (such as trial-ending and renewal reminders), and prevent trial abuse.
4. Communicate with you: respond to support requests and send service and account messages. If you agree, we may also send you messages about offers or new features; you can opt out at any time.
5. Keep people safe: detect and respond to messages that suggest a risk of self-harm (for example, by sharing crisis resources such as 988), prevent the generation of harmful content, honor recipients' opt-outs, and enforce our Terms.
6. Protect the Service: secure accounts, prevent fraud, spam and abuse, protect our messaging lines and systems, and debug problems.
7. Measure and improve the Service: understand how features are used, measure reliability (for example, whether reminders fire on time), fix errors, and develop new features, mostly using aggregated or de-identified information. We do not use your content to train AI models (Section 4).
8. Comply with law: meet our legal, tax, accounting and regulatory obligations, respond to lawful requests, and establish or defend legal claims.
9. With your consent: for any other purpose we describe to you when we ask for your consent.

We don't use your personal information to show you ads, and we don't sell it. We don't use your information to make decisions that produce legal or similarly significant effects about you (such as decisions about credit, housing, employment or insurance).

4. AI, your content and model training

4.1 How AI is used. Upbee's replies, summaries, Memory and actions are produced by AI models. To answer you, we send the relevant parts of your messages, files, Memory and connected-service information to our AI model providers, which process them and return a response. We currently use models from Anthropic (Claude), which may be accessed directly or through cloud platforms such as Amazon Web Services or Google Cloud. We use a speech-to-text provider (currently OpenAI) to transcribe voice notes. We may change or add AI providers; when we do, we'll update this Policy.

4.2 No training on your content.

• We don't use your messages, files, voice notes, Memory or connected-service data to train or fine-tune AI models, whether ours or anyone else's.
• We use AI providers under commercial terms that prohibit them from using our customers' content to train their models.
• Our AI providers may keep inputs and outputs for a limited period (generally up to about 30 days) to provide their services and to detect and prevent abuse, and may keep content flagged for violating their usage policies longer, as their terms allow. Some background processing that we run in batches (for example, nightly updates to your Memory) may be kept by the provider for a similar limited period. [Where available to us, we use zero-data-retention or reduced-retention options.]

4.3 Improving Upbee without training on you. We improve Upbee by changing its instructions and design, by testing it against conversations we write ourselves, and by looking at aggregated or de-identified metrics (for example, how often a reminder is delivered on time or how often people undo an action). We don't build test sets from your conversations without your permission.

4.4 When people at Upbee may see your conversations. Your conversations are handled by automated systems. Authorized personnel may access the content of your conversations only when reasonably necessary to:

• help you, when you contact support and ask us to look at a specific conversation or issue;
• investigate and prevent fraud, abuse, security incidents or violations of our Terms, including reports from people who received messages sent through Upbee;
• respond to safety risks;
• comply with law; or
• improve the Service, only if you have opted in (for example, as a beta tester who agreed to let us review conversations).

Access is limited, logged, and subject to confidentiality obligations.

4.5 Safety systems. Every message is automatically checked by safety systems, including a classifier that looks for signs of crisis or self-harm. When one is detected, Upbee may reply with crisis resources. We log that a safety event occurred and its category, but not the text of your message, so we can operate our safety protocol and meet reporting obligations (which use aggregate counts, not personal information).

4.6 Automated personalization. Upbee automatically builds your Memory and uses it to decide what to remember, what to remind you about and when to message you. You can see, correct and delete your Memory at any time (Section 8), turn proactive messages down or off, and ask Upbee why it suggested something.

5. How we share information

We don't sell your personal information, and we don't share it for cross-context behavioral (targeted) advertising. We share personal information only as described below.

5.1 Service providers

We share information with companies that process it on our behalf, under contracts that limit their use to providing services to us and require them to protect it. Current categories and examples include:

We may update these providers from time to time. [A current list is available at upbee.ai/subprocessors.]

5.2 At your direction

When you ask Upbee to do something that involves someone else, we share information as needed to do it. For example:

• Messages you approve: when Upbee sends a text for you, the recipient sees the message and your name as the sender ("Maya's assistant").
• Emails you approve: sent through your connected email account to the recipients you approve.
• Connected services: when you ask Upbee to add an event, we send that event to your calendar provider.
• Bookings and purchases (rolling out): we share the details needed to complete the booking or purchase you approved (such as your name, party size, time or order details) with the merchant, booking platform or payment provider.
• AI calls (rolling out): the business Upbee calls hears the information needed for your request.
• Group chats: what Upbee says in a group is seen by everyone in that group. Upbee does not use your private Memory in group chats.
• Family Plans: information you add to the shared household layer is visible to the adults on your Family Plan. Your personal conversations and personal Memory are not visible to the organizer or other members.

5.3 Referral partners

If you signed up through a creator, affiliate or referral link, we tell that partner that a referral converted and the related reward amount. We don't give referral partners your phone number, your messages or your Memory.

5.4 Legal, safety and protection

We may disclose information if we believe in good faith that it's reasonably necessary to (a) comply with a law, regulation, subpoena, court order or other legal process; (b) protect the safety of any person, including in an emergency involving risk of death or serious injury; (c) detect, prevent or address fraud, security or technical issues; (d) report apparent child sexual exploitation to the National Center for Missing & Exploited Children; or (e) protect the rights, property or safety of Upbee, our users, or the public. Where legally permitted and practical, we'll notify you of legal requests for your information.

5.5 Business transfers

If we're involved in a merger, acquisition, financing, reorganization, bankruptcy or sale of assets, your information may be transferred as part of that transaction. We'll require the recipient to honor this Privacy Policy for the information it receives, and we'll notify you of any material change in how your information is handled.

5.6 Aggregated and de-identified information

We may share information that has been aggregated or de-identified so that it can't reasonably be linked to you (for example, "Upbee users set 2 million reminders this year"). We maintain de-identified information in de-identified form and don't attempt to re-identify it, except as permitted by law.

5.7 Mobile information and text messaging (carrier statement)

We do not sell, rent, or share your mobile phone number, your text messaging opt-in data, or your consent to receive text messages with any third parties or affiliates for their marketing or promotional purposes. All of the categories of sharing described in this Privacy Policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, except with the messaging providers, aggregators and carriers that deliver our messages to you, solely to provide the messaging service, or as required by law.

6. Messaging, consent and opt-outs

• How we text you: we send you messages using automated technology, including replies, reminders and scheduled messages you request, proactive messages (such as a morning brief), and account and billing messages. Message frequency varies. Message and data rates may apply. See Section 10 of our Terms for our full Messaging Terms.
• To stop all messages, text STOP (or QUIT, END, REVOKE, OPT OUT, UNSUBSCRIBE). We'll confirm once and then stop. Text START to resume. Text HELP for help.
• Marketing messages: we'll send you messages about offers or new features only if you agree, and you can opt out of those separately (for example, by texting "no promos") without stopping your assistant.
• People who receive messages from Upbee for a user can text STOP to stop all messages from Upbee numbers. We keep a record of that opt-out so that no Upbee user can message that number from an Upbee number again.

7. Google user data

If you connect a Google account (for example, Google Calendar or Gmail), the following applies to information we receive from Google APIs ("Google user data"):

• Upbee's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
• We access only the Google user data needed for the features you turn on (for example, reading your events to plan your day, and adding events you approve), and we use it only to provide and improve those user-facing features.
• We transfer Google user data to others only as necessary to provide or improve those features (for example, to our AI model providers to process your request, under terms that prohibit training), for security purposes, to comply with law, or as part of a merger or acquisition with notice to you.
• We don't use Google user data for advertising, we don't sell it, and we don't use it to determine creditworthiness or for lending.
• We don't use Google user data, or any data derived or aggregated from it, to develop, improve or train generalized or non-personalized AI or machine-learning models.
• Humans don't read your Google user data unless you give us permission for specific messages or events, it's necessary for security purposes (such as investigating abuse), it's necessary to comply with law, or the data has been aggregated and anonymized for internal operations.

You can revoke Upbee's access at any time from your Upbee account page, by texting Upbee, or in your Google Account's security settings. When you disconnect, we stop accessing your Google account and delete the Google user data we cached from it within [30] days, except for items you've asked Upbee to remember separately.

8. Your choices and controls

By text (anytime):

Connected services: disconnect any service from your account page, by texting Upbee (for example, "disconnect my calendar"), or in that service's own settings.

Cookies: see Section 13.

Privacy rights requests: see Section 15.

9. How long we keep information

We keep personal information only as long as needed for the purposes described in this Policy, unless a longer period is required or permitted by law. Our general retention periods:

When you delete: when you text "forget that," we delete that item from your active Memory right away. When you text "delete everything" and confirm, we delete your account and personal information from our active systems within [30] days, and from backups within a further [35] days as backups roll off. We may keep limited information after deletion where needed to comply with law, honor your opt-out, prevent fraud and trial abuse (for example, a one-way hashed version of your phone number), resolve disputes, or enforce our agreements. AI providers' limited retention is described in Section 4.2.

10. How we protect information

We use administrative, technical and physical safeguards designed to protect personal information, including:

• encryption of data in transit and at rest, with additional application-level encryption for phone numbers and for credentials and tokens for connected services;
• strict access controls, so each user's data is isolated and staff access is limited and logged;
• one-time, short-lived sign-in links that are stored only in hashed form;
• removal of message content from error logs;
• confirmation steps before any message, email, booking or purchase leaves Upbee; and
• protections against prompt injection, so that instructions hidden in photos, emails, calendar invites or web pages are treated as information, never as commands.

No system is perfectly secure. Messages you send over SMS or MMS travel through carrier networks, and iMessage and other channels are operated by third parties, so we can't guarantee the security of information while it's in transit on those networks. If we learn of a security incident that affects your personal information, we'll notify you and regulators as required by law.

11. Sensitive information, photos and biometrics

11.1 Sensitive topics. You decide what to share. If you tell Upbee about sensitive matters, such as your physical or mental health, medications, sexual life or orientation, religious beliefs, immigration status, finances or precise location, Upbee may store that information to help you with your request. Upbee is designed to treat such information as high sensitivity: it doesn't bring it up unprompted, doesn't use it in group chats or proactive messages without a reason related to your request, and doesn't use it to infer characteristics about you. We use sensitive information only to provide the Service you request and for the other limited purposes the law allows, never for advertising or profiling. You can delete it at any time.

11.2 Photos and screenshots. We use photos, screenshots and files you send to do what you ask (for example, turning a flyer into a calendar event). We don't use photos to identify people, and we don't create or store facial geometry, voiceprints or other biometric identifiers. Please don't send photos of other people's private documents, intimate images, or images of children unless it's necessary for your request and you have the right to share them.

11.3 Voice notes. Voice notes are transcribed into text so Upbee can understand them. We don't use your voice to identify you.

11.4 Children's information on Family Plans. Parents on a Family Plan may add information about their children (for example, school events, activities, sizes, doctors or allergies) to the shared household layer. We use it only to provide the Family Plan to the adults on it, treat children's health details as high sensitivity, never use it for advertising, and delete it when the parent deletes it or the household is closed. Children may not text Upbee or use the Service.

12. Information about other people

Using Upbee often involves information about other people: friends you mention, contacts you ask Upbee to text, people in screenshots you send, people in group chats, and attendees on your calendar events. You're responsible for having the right to share that information, and you should share only what's needed for your request.

We use information about other people only to provide the Service to the user who shared it. We don't build profiles of non-users for any other purpose, and we never sell or use it for marketing.

If you're not an Upbee user and believe a user has shared your information with Upbee, or you've received messages from an Upbee number, you can:

• text STOP to the Upbee number to stop all messages from Upbee numbers; and
• email privacy@upbee.ai to ask what information we hold about you or to request deletion. We'll respond as required by law. In some cases, we may not be able to identify information about you within another user's private content without additional details.

13. Cookies, analytics, Do Not Track and Global Privacy Control

13.1 Cookies and similar technologies. Our websites use cookies, local storage and similar technologies to keep you signed in, secure our sign-up and checkout pages, remember your preferences, and understand how people use our site (for example, which pages lead to sign-ups). We use first-party product analytics (currently PostHog). [We do not use third-party advertising cookies or pixels.] You can control cookies through your browser settings; blocking some cookies may affect how the site works.

13.2 Do Not Track. There is no common industry standard for "Do Not Track" browser signals, so our websites don't currently respond to them.

13.3 Global Privacy Control. We honor Global Privacy Control (GPC) and other legally recognized opt-out preference signals as a request to opt out of the sale and sharing of personal information and targeted advertising for that browser or device (and for your account, if you're signed in). Because we don't sell or share personal information for targeted advertising, this mainly confirms that choice.

14. Data location

We're based in the United States, and we process and store information in the United States. Some of our service providers may process information in other countries, under contracts that require appropriate protections.

15. Your U.S. state privacy rights

Depending on where you live, you may have some or all of the rights below under state privacy laws, including those of California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia. We extend these rights to all users in the United States, whether or not your state's law applies to us, subject to the limits the law allows.

15.1 Your rights.

• Access / Know: confirm whether we process your personal information, and obtain the categories and specific pieces of personal information we hold, the sources, the purposes, and the categories of third parties we disclose it to.
• Portability: receive a copy of your personal information in a portable, readily usable format.
• Correction: correct inaccurate personal information.
• Deletion: delete personal information we collected from or about you, subject to legal exceptions.
• Opt out of sale, sharing, targeted advertising and certain profiling: we don't sell your personal information, share it for targeted advertising, or use it for profiling that produces legal or similarly significant effects, so there is nothing to opt out of today. If that ever changes, we'll update this Policy first and give you a way to opt out.
• Sensitive information: we use sensitive personal information only to provide the Service you request and for other purposes permitted by law, and we don't use it to infer characteristics about you. Where a state requires consent to process sensitive data, we rely on your choice to share it with Upbee for your request, and you can withdraw it at any time by deleting the information.
• List of third parties: where state law provides it (for example, in Oregon and Minnesota), request a list of the specific third parties to which we've disclosed personal information.
• Appeal: if we deny your request, appeal our decision (Section 15.4).
• Non-discrimination: we won't discriminate against you for exercising your rights, for example by denying you the Service or charging a different price, except as permitted by law.

15.2 How to make a request. You can:

• text Upbee "privacy request" from the phone number on your account; or
• email privacy@upbee.ai with your request and the phone number associated with your account.

For deletion, you can also simply text "delete everything."

15.3 Verification and authorized agents. To protect your information, we'll verify your request, generally by confirming it through the phone number on your account (for example, by sending you a message or a secure link) and, if needed, the email address on your account. We'll ask for more information only if necessary. You may use an authorized agent to make a request for you; we'll require written proof of the agent's authority (or a valid power of attorney) and may ask you to verify your identity directly. We'll respond within 45 days, and if we need more time (up to an additional 45 days, as the law allows), we'll tell you why.

15.4 Appeals. If we deny your request in whole or in part, you can appeal by replying to our decision or emailing privacy@upbee.ai with "Appeal" in the subject line within a reasonable time. We'll respond in writing within the period the law requires (generally 45 to 60 days), explaining what we decided and why. If we deny your appeal, you may contact your state Attorney General.

16. California disclosures

This section supplements this Policy for California residents and serves as our Notice at Collection under the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA").

16.1 Personal information we collect, and how we use and disclose it. In the past 12 months we have collected the following categories of personal information. We collect it from the sources described in Section 2 (you, your devices, services you connect, our service providers, referral partners and other users), for the business and commercial purposes in Section 3, and we disclose it for business purposes to the categories of recipients described in Section 5. Retention periods are in Section 9.

16.2 Sale and sharing. We do not sell personal information or share it for cross-context behavioral advertising, and we have not done so in the past 12 months. We have no actual knowledge of selling or sharing the personal information of consumers under 16.

16.3 Sensitive personal information. We use and disclose sensitive personal information only for the purposes permitted under the CCPA regulations (Cal. Code Regs. tit. 11, § 7027(m)), such as performing the services you request, security and integrity, and short-term transient uses. We do not use it to infer characteristics about you. Therefore, we don't offer a separate "right to limit."

16.4 Your California rights. California residents have the rights described in Section 15 (to know, delete, correct, opt out of sale and sharing, limit the use of sensitive personal information, and be free from discrimination and retaliation). To exercise them, see Section 15.2. As an online-only service with which you have a direct relationship, we accept requests by text and by email.

16.5 Notice of financial incentive. From time to time we offer promotions such as free trials, referral rewards ("give a month, get a month"), founding-member pricing, student pricing and win-back offers. Some of these involve collecting or using personal information, such as your phone number, email or referral code, to deliver the offer, prevent abuse and track eligibility. Participation is voluntary; you opt in by accepting the offer, and you can withdraw at any time by contacting us or not redeeming it. We estimate the value of your personal information in connection with these programs as roughly equal to the value of the benefit offered, based on our reasonable estimate of the expenses related to providing the offer. [⚖️ COUNSEL TO CONFIRM WHETHER THIS NOTICE IS NEEDED.]

16.6 Shine the Light. We don't disclose personal information to third parties for their own direct marketing purposes, as defined in California Civil Code § 1798.83.

16.7 Deidentified information. Where we use deidentified information, we maintain it in deidentified form and don't attempt to re-identify it, except to test our deidentification processes as permitted by law.

17. Consumer health data (Washington, Nevada and Connecticut)

Some state laws, including Washington's My Health My Data Act, give special protection to "consumer health data." Upbee is not a health service, but if you choose to tell Upbee about your health (for example, "remind me to take my allergy meds," "I have a dentist appointment," or "I've been stressed lately"), that information may be consumer health data.

• What we collect: health-related information you choose to share in conversation or in your calendar, such as appointments, medications, conditions, symptoms, mood or wellness goals, and inferences Upbee draws from it.
• Sources: you, and services you connect.
• How we use it: only to provide the Service you request (for example, a reminder) and for safety (such as crisis detection), not for advertising, and never sold.
• Who we share it with: our service providers (such as AI model providers and hosting), only to provide the Service, and anyone you direct (for example, if you ask Upbee to text someone about an appointment).
• Your rights: you can access, delete and withdraw consent for your consumer health data using the controls in Section 8 or by emailing privacy@upbee.ai. You can appeal a denial as described in Section 15.4.

Our Consumer Health Data Privacy Policy is available at [upbee.ai/health-data-privacy]. [⚖️ WASHINGTON REQUIRES A SEPARATE, STANDALONE POLICY WITH ITS OWN HOMEPAGE LINK. SEE NOTES.]

18. Other jurisdictions

Nevada: we don't sell covered information as defined in Nevada law. You may still send a request to privacy@upbee.ai.

Outside the United States: the Service is intended only for people in the United States and isn't directed to people in the European Economic Area, the United Kingdom or other countries. If you use Upbee while temporarily traveling outside the U.S., your information will be processed in the United States under this Policy.

19. Children's privacy

The Service is for adults 18 and older. We ask for your date of birth at sign-up and don't knowingly collect personal information from anyone under 18, including children under 13. If we learn that someone under 18 is using Upbee, we'll close the account and delete their personal information, except for what we must keep to comply with law. If you believe a minor is using Upbee, contact privacy@upbee.ai. Parents may enter limited information about their children on a Family Plan, as described in Section 11.4; children themselves may not use the Service.

20. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We'll post the updated Policy with a new "Last updated" date. If we make a material change, we'll notify you in advance by text or email. If a change would let us use personal information we've already collected in a materially different way (for example, to train AI models or for advertising), we'll ask for your consent first.

21. Contact us

• Email: privacy@upbee.ai
• Text: "privacy request" to Upbee from your account's phone number
• Mail: [COMPANY LEGAL NAME], LLC, Attn: Privacy, [ADDRESS]
• Support: support@upbee.ai