Privacy Policy

This Privacy Notice for Fortitude AI, Inc. (doing business as Fortitude) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") information when you use our services ("Services"), including when you:

• Visit our website at https://www.buildfortitude.ai, or any website of ours that links to this Privacy Notice
• Download and use our mobile application (Fortitude), or any other application of ours that links to this Privacy Notice
• Engage with us in other related ways, including any sales, marketing, or events

Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your Personal Data is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@buildfortitude.ai.

Information We Collect

We collect personal data relating to you ("Personal Data") that you voluntarily provide to us when you create an account, express an interest in learning about our Services, when you use our Services, or when you otherwise contact us.

You provide us with Personal Data as follows:

• Account Information: When you create an account with us, we collect information about your account including your name and contact information (e.g. your email address). We may provide you with the option to register with a social media account (e.g. Google or Apple) and, if you choose to register in this way, collect similar information from them.
• Demographic Data: We collect data such as your age, gender, race and ethnicity, and marital status.
• Conversation Data: We collect Personal Data that you provide as an input to our Services. This may include Personal Data and other sensitive information about your mental health.
• Payment Data: We may collect data necessary to process your payment if you choose to make purchases. All such payment data is handled and stored by Apple. We do not control and are not responsible for Apple's privacy practices and suggest that you review their privacy policy before sharing payment information.
• Feedback on Your Use of Services: We appreciate your feedback about our Services, and store feedback that you provide, for example, if you thumbs up / thumbs down a message.
• Communication Information: If you communicate with us, for example to ask a question, we collect your name, contact information, and the content of any messages you send.

When you use our Services, we also receive certain technical data ("Technical Information") as follows:

• Device and Connection Information: Consistent with your device or browser permissions, your device or browser automatically sends us information about when and how you install, access, or use our Services. This includes information such as your device type, operating system information, browser information, mobile network, connection information, mobile operator or internet service provider (ISP), time zone setting, IP address (including information about the location of the device derived from your IP address), identifiers (including device or advertising identifiers, probabilistic identifiers, and other unique personal or online identifiers).
• Usage Information: We collect information about your use of the Services, such as the start and stop times of your sessions and pages you view.
• Log and Troubleshooting Information: We collect information about how our Services are performing when you use them. This information includes log files. If you or your device experiences an error, we may collect information about the error, the time the error occurred, the feature being used, the state of the application when the error occurred, and any communications or content provided at the time the error occurred.

How We Use Personal Data

We may use and disclose Personal Data for the following purposes:

• To provide, analyze, and maintain our Services, for example, to provide therapy sessions.
• To improve or develop our services, for example, by conducting research about how you interact with our Services or improving our artificial intelligence models.
• To communicate with you, for example, by responding to your inquiries or sharing information about new features.
• To prevent fraud, illegal activity, or misuses of our Services, and to protect the security of our systems and Services.
• To comply with legal obligations and to protect the rights, privacy, safety, or property of our users, Fortitude, or third parties.

Disclosure of Personal Data

We may disclose your Personal Data in the following circumstances:

• Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may disclose Personal Data to vendors and service providers, including providers of cloud computing services, communication and collaboration tools, performance monitoring tools, customer service vendors, and other information technology providers. We do not control such third-party service providers, but we carefully evaluate the information privacy and security practices of those providers prior to engaging them and select only those providers that we reasonably determine are able to adequately protect Personal Data.
• Business Transfers: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively, a "Transaction"), your Personal Data may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
• Government Authorities or Other Third Parties: We may disclose your Personal data with authorities or trusted third parties when legally required, to enforce our rights, prevent fraud or other violations, ensure safety, or avoid liability.

Retention of Personal Data

We will only keep your Personal Data for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymize such information as permitted or required under applicable laws. We may also aggregate or de-identify Personal Data so that it no longer identifies you, and use this information for the purposes described in this Privacy Policy.

Data Security

We implement commercially reasonable information security measures designed to maintain the security and integrity of the information that we collect and maintain. Examples of such measures may include data encryption, usage of multi-factor authentication by employees, and role-based access control for employees. Despite the security measures we implement, there are inherent risks in transmission of information over the Internet and therefore we cannot guarantee that unauthorized access to or use of information will never occur.

Children Under 13

Our Services are not intended for use by children under the age of 13. We do not knowingly collect Personal Data from children under the age of 13. If you become aware that we have collected Personal Data from a child under the age 13, please contact us at support@buildfortitude.ai so that we may seek to delete such Personal Data.

Direct Marketing

If you opt to receive direct marketing communications from us, we may use your name and contact information to send such communications to you. Direct marketing communications may include, without limitation, updates about our products and services and other promotional material that may be of interest to you. When we send direct marketing communications to you via email, we will include an unsubscribe link in the email which allows you to opt out of receiving further direct marketing emails from us. You may also choose to receive direct marketing communications through push notifications within our application. You may, at any time, discontinue these notifications by changing the application settings to disable such notifications.

Tracking Tools

We use certain tools and programs to track Service usage ("Tracking Tools") in accordance with applicable laws. We use Tracking Tools to understand, among other things, how you use our Services, including how often you use them. The use of Tracking Tools involves collection of information about your activity and the device you use to access our Services. The information we obtain from the use of Tracking Tools enables us to improve our Services and make them more user-friendly and convenient. You may disable Tracking Tools by modifying your browser settings, but if you do so, some features on our Services may not function as intended.

Your Rights and Choices

Depending on where you live, you may have the following rights regarding your Personal Data:

• Right to be informed: Your right to know what Personal Data we process and why.
• Right to access: Your right to request a copy of the Personal Data we have about you.
• Right to rectify: Your right to correct the Personal Data we have about you if it's inaccurate.
• Right to data portability: Your right to retrieve your Personal Data from us to easily transfer it to another location.
• Right to erase: Your right to have your Personal Data deleted, except if we have compelling reasons to keep it (like following the law).
• Right to restrict or object: Your right to limit or stop how we use your Personal Data. If processing is restricted, we can still store the information but can't use it further.
• Right to complain: Your right to complain to us or your country's data privacy authority if you don't agree with how we handle your data or address your concerns. If you have a concern about how we handle your Personal Data or a request, we encourage you to first contact us.
• Rights related to automated decision-making, including profiling: Your right not to be affected by automatic decisions made without any human involvement, especially if those decisions have significant or legal effects on you. For example, this includes situations like automatic denial of an online credit application or hiring decisions made entirely by computers.

You can exercise some of these rights through our Services. For example, you can delete your account and the associated data, or disable notifications. You or an authorized agent may submit a request by contacting us. We may verify your request by requesting information sufficient to verify your identity. You may also have the right to appeal requests that we deny by contacting us.

Privacy Policy Changes

We may update this Privacy Policy from time to time. When we do, we will publish an updated version and effective date on this page. If we make material changes, we may notify you via email or another prominent method. We encourage you to review this document frequently to be informed. If you keep using Services after a change to this Policy, your continued use means that you accept any such changes.

Contact Us

If you have questions or comments about this notice, you may contact us at:

Legal Basis for Processing

According to some data protection laws, processing Personal Data must always have a specific lawful basis, as defined by those laws. Below is the legal basis for all of the Personal Data we collect, use, and process.