Privacy Policy

1.Scope of This Policy

This Privacy Policy explains how WellSaid AI, LLC (“WellSaid AI,” “Company,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information in connection with our website (www.wellsaid.ai), our online cognitive assessment platform, our AI companion (“Coach Cara”), and related applications and services (collectively, the “Services”). Please read this Policy carefully. By accessing or using the Services, you acknowledge that you have read and understood this Policy.

This Policy applies to personal information collected through the Services, including when you browse our website, purchase or complete a cognitive assessment, create an account, communicate with Coach Cara, or otherwise interact with us. This Policy does not apply to third-party websites, applications, or services that link to or from our Services but that maintain their own privacy policies.

2.Information We Collect

2.1 Information You Provide to Us

We collect information you provide directly, including:

• Contact and identity information: name, postal address, email address, phone number, and username/password.
• Account and purchase information: billing information, order history, and communications with our support team. Payment card numbers are collected and processed directly by our payment processor, as described in Section 4.
• Assessment and health-related information: responses to cognitive assessment questions and exercises, self-reported health history, family health history, lifestyle information such as diet, exercise, sleep, and social engagement, and other information you choose to share as part of the assessment or with Coach Cara.
• Communications: information you provide when you contact us, respond to surveys, or participate in promotions.

2.2 Information from Healthcare Professionals and Specialist Review

Assessments completed through the Services are reviewed by a healthcare professional. This review may generate notes, scoring, and recommendations that become part of your account record. This information is not protected health information under HIPAA because WellSaid AI is not a HIPAA-covered entity or business associate, but we treat it as sensitive information and apply the safeguards described in Section 7.

2.3 Information We Receive from Other Sources

We may receive information about you from service providers, such as identity-verification or fraud-prevention vendors, partners identified on our Partnerships page, and publicly available sources, which we may combine with information collected through the Services.

2.4 Information Collected Automatically

When you use the Services, we and our service providers automatically collect certain information about your device and usage, including IP address, device identifiers, operating system, browser type and language, referring and exit pages, pages viewed, links clicked, time spent on pages, and approximate location derived from your IP address.

2.5 Cookies and Similar Technologies

See Section 5 below.

3.How We Use Personal Information

We use personal information for the following purposes:

• To create and administer your account and deliver the cognitive assessment and Coach Cara services you request.
• To facilitate specialist review of assessment responses and to prepare and deliver your personalized report and recommendations.
• To process payments, prevent fraud, and fulfill orders.
• To operate, maintain, secure, and improve the Services, including troubleshooting and quality assurance.
• To communicate with you, including confirmations, receipts, appointment or assessment reminders, technical notices, security alerts, and customer support.
• To send marketing communications about our products, services, and partner offerings, where you have not opted out and where permitted by law.
• To personalize your experience, including recommendations delivered through Coach Cara.
• To conduct research and analytics to improve the accuracy, safety, and effectiveness of our assessment and coaching tools, using de-identified or aggregated data where feasible.
• To comply with applicable law, respond to legal process, and enforce our Terms of Use and other agreements.
• To detect, investigate, and prevent fraudulent, unauthorized, or illegal activity, and to protect the rights, property, and safety of WellSaid AI, our users, and others.

4.How We Share Personal Information

We do not sell personal information, and we do not share personal information with third parties for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act, as amended (“CCPA”), and similar state laws. We may share personal information as follows:

• Healthcare professionals engaged by us: to review assessment responses and prepare your report and recommendations.
• Service providers: vendors that perform services on our behalf, such as cloud hosting, payment processing, customer support, email and text-message delivery, analytics, and identity verification. These providers are contractually restricted from using personal information for any purpose other than providing services to us.
• With your consent: for example, if you ask us to share your report with a family member or your own physician.
• Business transactions: in connection with a merger, financing, acquisition, reorganization, bankruptcy, or sale of some or all of our assets, subject to standard confidentiality arrangements.
• Legal, safety, and protection purposes: to comply with law or legal process, protect the rights, property, or safety of WellSaid AI or others, enforce our agreements, or respond to an emergency.
• Aggregated or de-identified information: we may share information that has been aggregated or de-identified such that it can no longer reasonably be used to identify you.

We do not share consumer health data with third parties for advertising purposes, and we do not permit geofencing around healthcare facilities in a manner that would identify or track consumers seeking health care services, consistent with applicable state law.

5.Cookies, Analytics, and Similar Technologies

We and our service providers use cookies, web beacons, and similar technologies to operate the Services, remember your preferences, support account features, including keeping you logged in, measure performance, and understand how the Services are used.

5.1 Types of Cookies

• Essential cookies: required for core functionality, such as account authentication and security.
• Analytics cookies: help us understand usage patterns and improve the Services.
• Preference cookies: remember settings and choices you have made.

5.2 Your Choices

Most browsers allow you to block or delete cookies through your browser settings. Because we do not use cookies for cross-context behavioral advertising, there is no advertising opt-out to manage; blocking essential cookies, however, may prevent you from logging in or using certain features of the Services.

6.Data Retention

We retain personal information for as long as reasonably necessary to provide the Services, fulfill the purposes described in this Policy, comply with our legal obligations, resolve disputes, and enforce our agreements. Assessment responses, specialist review notes, and related health-related information are generally retained for the duration of your account relationship with us and for a reasonable period thereafter to support continuity of care, respond to inquiries, and meet record-keeping and legal obligations, unless a longer or shorter period is required or permitted by law or you validly exercise a deletion right described in Sections 8 or 9. When personal information is no longer needed, we delete, de-identify, or securely dispose of it.

7.Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, and destruction, including encryption of data in transit, access controls limiting internal access to personal information on a need-to-know basis, and regular review of our security practices. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a security incident affecting your personal information, we will notify you and take other steps as required by applicable law.

8.Your Privacy Rights (California and Other States)

Depending on where you live, you may have rights under state privacy laws such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”), and similar laws in states including Colorado, Connecticut, Virginia, Utah, Oregon, Texas, and others. Subject to certain exceptions, these rights may include:

• Right to know or access: the categories and specific pieces of personal information we have collected about you, and the categories of sources, purposes, and third parties with whom we share it.
• Right to delete: request deletion of personal information we have collected from you, subject to certain exceptions.
• Right to correct: request correction of inaccurate personal information.
• Right to data portability: receive a copy of your personal information in a portable format.
• Right to opt out of sale, sharing, and targeted advertising: we do not sell personal information or share it for cross-context behavioral advertising, so no action is needed to opt out of these practices.
• Right to limit use of sensitive personal information: we use sensitive personal information, including health-related information, only to provide the Services you request and for the limited purposes described in Section 3, consistent with applicable law.
• Right to non-discrimination: we will not discriminate against you for exercising your privacy rights.

8.1 How to Exercise Your Rights

You may submit a request by emailing us at support@wellsaid.ai or by writing to the address in Section 16. We will verify your identity before responding, which may require you to provide additional information. You may designate an authorized agent to submit a request on your behalf, subject to verification. We will respond within the time required by applicable law, generally 45 days, with a possible extension.

8.2 Nevada Residents

Nevada residents may submit a request directing us not to sell certain covered information, as defined under Nevada law, by contacting us using the information in Section 16. As noted above, we do not currently sell personal information.

9.Consumer Health Data (Washington, Nevada, Connecticut, and Others)

Several states have enacted laws specifically protecting “consumer health data” collected outside the scope of HIPAA, including the Washington My Health My Data Act, Nevada's consumer health data law, and Connecticut's consumer health data provisions. Because the Services relate to cognitive and brain health assessment, certain information we collect—such as assessment responses, self-reported health and family health history, and inferences about your cognitive or physical health—may constitute “consumer health data” under these laws.

9.1 Consent

We collect consumer health data with your consent, or as necessary to provide a product or service you have requested. Where required by law, we obtain your affirmative, opt-in consent before collecting or sharing consumer health data, and separate consent before selling any consumer health data. We do not sell consumer health data.

9.2 Your Rights

Subject to applicable law, you may have the right to:

• Confirm whether we are collecting, sharing, or selling your consumer health data.
• Access your consumer health data.
• Withdraw consent to our collection or sharing of your consumer health data.
• Request deletion of your consumer health data, which we will honor by deleting the data from our records and directing service providers and affiliates who received it from us to do the same, subject to limited legal exceptions.

To exercise these rights, contact us at support@wellsaid.ai. We will respond within 45 days, or as otherwise required by applicable law.

9.3 Washington My Health My Data Act—Stand-Alone Policy

As noted in Section 1, Washington consumers should refer to our separate, stand-alone Consumer Health Data Privacy Policy, which governs our collection, use, and sharing of consumer health data for Washington consumers and controls in the event of any conflict with this general Policy.

9.4 Geofencing

We do not use geofencing technology to establish a virtual boundary around a health care facility for the purpose of identifying, tracking, collecting data from, or sending notifications to consumers regarding their consumer health data or health care services.

10.Text Messaging

If you provide a mobile phone number, we may send service-related text messages, such as identity or account verification, appointment or assessment reminders, customer-support communications, status updates, and security notifications. We will send promotional or marketing text messages only with the consent required by applicable law; such consent is never a condition of purchasing or using our Services.

Message frequency varies. Message and data rates may apply. Reply STOP to opt out of recurring messages at any time; you may receive a one-time confirmation. Reply HELP for assistance, or contact us at support@wellsaid.ai. Opting out of promotional texts does not affect essential, non-marketing messages, such as security alerts or responses to messages you send us.

11.Children's Privacy

The Services are intended for adults and are not directed to children under 13, and we do not knowingly collect personal information from children under 13. The Services are also not designed for use by individuals under 18 without the involvement of a parent, guardian, or caregiver. If we learn that we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information. If you believe a child has provided us with personal information, please contact us at support@wellsaid.ai.

12.Artificial Intelligence and Automated Processing

Coach Cara uses artificial intelligence to provide personalized suggestions related to memory exercises, movement, nutrition, and social connection based on information you provide and your interactions with the Services. Assessment scoring may involve automated tools, but every assessment is reviewed by a healthcare professional before your results are prepared—we do not rely solely on automated processing to generate your final report or clinical recommendations.

Your interactions with Coach Cara and other AI-assisted features may be processed by third-party AI service providers acting as our service providers, subject to contractual confidentiality and security obligations, and may be used in de-identified or aggregated form to improve the accuracy and safety of our tools.

13.Third-Party Links and Services

The Services may contain links to third-party websites or services, including partner organizations described on our Partnerships page. We are not responsible for the privacy practices of third parties, and we encourage you to review their privacy policies before providing personal information to them.

14.International Users

The Services are directed to individuals in the United States. If you access the Services from outside the United States, your information will be transferred to, stored, and processed in the United States, where privacy laws may differ from those in your country of residence.

15.Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the “Last Updated” date above and, where required by law, provide additional notice, such as an email notification or a prominent notice on the Services. For material changes affecting consumer health data, we will obtain your consent as required. We encourage you to review this Policy periodically.

16.Contact Us

If you have questions, concerns, or requests regarding this Policy or our privacy practices, please contact us: