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ExDNA

ExDNA Privacy Policy

Effective Date: July 27, 2026

Exelar LLC ("Exelar," "we," "us," or "our") operates the ExDNA mobile application and related services, collectively referred to as the "App."

This Privacy Policy explains what information we collect, how we use it, when we share it, how long we retain it, and the choices available to you.

By using ExDNA, you acknowledge the practices described in this Privacy Policy.

1. Information We Collect

We collect information that you provide directly, information generated through your use of the App, and limited technical information needed to operate and improve ExDNA.

Account and Contact Information

We may collect:

  • Name
  • Email address
  • Username
  • Nickname
  • Date of birth
  • Gender, if voluntarily provided
  • Language preferences
  • Account identifiers
  • Authentication-provider identifiers

We use this information to create and manage your account, authenticate you, personalize the App, communicate with you, and provide support.

Profile Information

You may choose to provide:

  • Profile photograph or avatar
  • Biography
  • Public username
  • Privacy settings
  • Profile visibility preferences
  • Achievement visibility preferences

Some profile information may be visible to other users depending on your settings and the features available in the version of the App you use.

ExDNA does not include a public social feed at launch.

Habit, Activity, and Wellbeing Information

Depending on the features you use, we may collect information such as:

  • Habits and activities
  • Goals
  • Schedules
  • Session history
  • Duration and completion records
  • Streaks
  • Milestones
  • Notes
  • Reflections
  • Moods
  • Urges, slips, or recovery-related entries
  • Progress information
  • Equipment and preferences

This information is used to provide the App's habit-building, tracking, reflection, recommendation, and progress features.

ExDNA is not a medical service and does not provide medical, psychiatric, psychological, emergency, legal, or other professional advice.

User Content

You may provide or upload content such as:

  • Text
  • Comments
  • Profile content
  • Photographs
  • Videos
  • Uploaded files
  • Reports
  • Support messages
  • Feedback

We use this information to provide the feature you requested, maintain safety, respond to reports, enforce our rules, and provide support.

AI Feature Information

When you choose to use an AI-powered feature, information you submit may be processed by Base44 AI to generate the requested response.

This may include:

  • Prompts
  • Habit details
  • Reflections
  • Goals
  • Notes
  • Related context you choose to provide

We use Base44 AI only to provide the feature you requested.

Before the first AI request, ExDNA may present a disclosure explaining that AI is being used and request your affirmative acceptance.

AI responses may be incomplete, inaccurate, or inappropriate and should not be relied upon as medical, mental-health, emergency, legal, or other professional advice.

You should not submit information to an AI feature that you do not want processed for the purpose of generating an AI response.

Purchase Information

If you make a purchase, we may collect or receive:

  • Purchase status
  • Product or entitlement purchased
  • Transaction identifier
  • Subscription or supporter status
  • Virtual or digital entitlement information
  • Purchase date
  • Refund or cancellation status

Payments made through the Apple App Store are processed by Apple. We generally do not receive your full payment-card information.

Apple's handling of payment information is governed by Apple's own privacy policy and terms.

Analytics and Usage Information

We may collect information about how you use ExDNA, including:

  • Screens viewed
  • Buttons or features used
  • Session activity
  • Onboarding progress
  • Feature adoption
  • Errors and failed actions
  • Experiment or feature assignment
  • Interaction timestamps
  • App version
  • Device and operating-system information
  • Diagnostic and performance information

We use this information to operate the App, detect problems, improve features, measure reliability, prevent abuse, and understand whether features are useful.

We do not use this information for third-party advertising.

Device and Technical Information

We or our service providers may automatically receive limited technical information such as:

  • Device type
  • Operating system
  • App version
  • IP address
  • Browser or web-view information
  • Authentication-session information
  • Crash logs
  • Performance data
  • Security and fraud-prevention signals

We use this information for security, authentication, diagnostics, reliability, and App functionality.

2. How We Use Information

We use personal information to:

  • Create, authenticate, and manage accounts
  • Provide habit, activity, tracking, reflection, and recommendation features
  • Personalize App settings and content
  • Provide AI-powered features when requested
  • Process purchases and maintain entitlements
  • Provide essential account and service communications
  • Respond to support and privacy requests
  • Enforce Community Guidelines and Terms of Use
  • Review reports and conduct moderation
  • Prevent fraud, abuse, harassment, and unauthorized access
  • Diagnose errors and improve performance
  • Conduct product analytics and limited feature experiments
  • Comply with legal obligations
  • Protect the rights, safety, and security of users, Exelar LLC, and others

We send only essential service-related emails, such as account, security, support, purchase, moderation, or important policy communications.

We do not use your email address for unrelated marketing or third-party advertising.

3. No Advertising or Sale of Personal Information

ExDNA does not display third-party advertisements at launch.

We do not sell or rent personal information.

We do not share personal information with third parties for their independent advertising or marketing purposes.

We do not use cross-app tracking for advertising.

4. How We Share Information

We may share information in the following limited circumstances.

Service Providers

We use service providers to help operate ExDNA, including providers of:

  • Cloud hosting and databases
  • Authentication
  • Email delivery
  • Analytics
  • Diagnostics
  • Payment processing
  • AI processing
  • Content storage
  • Security and fraud prevention

These providers may process information only as necessary to perform services for us and are expected to provide appropriate protections.

Base44

We use Base44 for cloud infrastructure, authentication, database services, backend functions, analytics, file storage, and AI-powered features.

Base44 may process information on our behalf as necessary to provide these services.

Authentication Providers

If you sign in through Google, Apple, or another authentication provider, that provider may send us information needed to authenticate your account, such as your name, email address, and provider-specific identifier.

Their use of your information is governed by their own policies.

Apple and Payment Providers

When you make an in-app purchase, Apple or another authorized payment platform may process the transaction and provide us with purchase and entitlement information.

Legal and Safety Purposes

We may disclose information where reasonably necessary to:

  • Comply with law, regulation, court order, or legal process
  • Respond to lawful government requests
  • Investigate fraud, abuse, security incidents, or violations
  • Protect users or the public from harm
  • Enforce our Terms of Use
  • Protect our legal rights

Business Transfers

If Exelar LLC is involved in a merger, acquisition, financing, restructuring, sale of assets, or similar transaction, information may be transferred as part of that transaction, subject to applicable law and continued privacy protections.

5. Public and Shared Information

Information you choose to make public may be visible to other users.

Depending on the available features and your settings, this may include:

  • Username
  • Nickname
  • Avatar
  • Biography
  • Achievements
  • Public habits or progress information
  • Public comments or other content, if such features are enabled

You should not include sensitive or private information in content you choose to make public.

6. Content Moderation and Safety

We may use automated filters and human review to detect and respond to content that may violate our Terms of Use or Community Guidelines.

Reports, moderation decisions, and enforcement records may be retained as necessary to:

  • Review safety complaints
  • Prevent repeat abuse
  • Document enforcement decisions
  • Protect users
  • Comply with legal obligations

Reporter identity is not intentionally disclosed to the reported user.

7. Data Retention

We retain personal information only for as long as reasonably necessary to:

  • Provide the App
  • Maintain your account
  • Fulfill purchases
  • Provide support
  • Protect security and prevent abuse
  • Comply with legal obligations
  • Resolve disputes
  • Enforce agreements

Retention periods may differ depending on the type of information and the reason it is held.

When you delete your account, we delete account-linked information from active systems, including applicable profile, habit, session, social, analytics, entitlement, consent, and content records.

Residual copies may remain temporarily in secure backups, system logs, or platform-managed infrastructure until they are overwritten through normal retention cycles.

We may retain limited information where required by law or reasonably necessary for fraud prevention, security, payment records, legal claims, or enforcement.

8. Account Deletion

You may initiate account deletion from within the App's Settings.

Account deletion is intended to remove your account and associated account-linked data, rather than merely deactivate the account.

Deleting your account does not automatically cancel an active Apple subscription. Subscription management and cancellation are handled through your Apple account settings.

If a platform-managed authentication record or storage item cannot be deleted directly by the App, contact us at support@exelarllc.com for assistance.

9. Your Privacy Choices and Rights

Depending on where you live, you may have the right to:

  • Access personal information we hold about you
  • Request correction of inaccurate information
  • Request deletion of your information
  • Obtain a copy of certain information
  • Withdraw consent where processing is based on consent
  • Object to or restrict certain processing
  • Opt out of research experiments
  • Manage profile visibility
  • Manage AI disclosure consent
  • Appeal certain moderation decisions
  • Lodge a complaint with a privacy regulator

You may manage certain preferences within the App or contact us at support@exelarllc.com.

Withdrawing consent may limit features that require the relevant information.

10. International Use and Data Transfers

ExDNA is available worldwide.

Your information may be processed in countries other than the country where you live, including the United States.

Where required, we use reasonable safeguards for international transfers and require service providers to protect information according to applicable law.

11. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect information, including access controls, authentication, authorization rules, encrypted transmission where supported, monitoring, and limited service-provider access.

No system can be guaranteed completely secure.

You are responsible for protecting your login credentials and notifying us if you suspect unauthorized access.

12. Children's Privacy

ExDNA is intended for users age 13 and older.

We do not knowingly collect personal information from children under 13.

If we learn that a child under 13 provided personal information, we will take reasonable steps to delete it.

Parents or guardians who believe a child under 13 has used ExDNA may contact us at support@exelarllc.com.

Users in some countries may need to be older than 13 or obtain parental consent under local law.

13. Essential Communications

We may send essential messages related to:

  • Account creation
  • Authentication
  • Security
  • Support requests
  • Purchases
  • Service interruptions
  • Significant feature or policy changes
  • Moderation or enforcement actions

We do not use your email address for unrelated marketing or third-party advertising.

14. Third-Party Links and Services

ExDNA may contain links to or integrations with third-party services.

Those services operate under their own privacy policies.

We are not responsible for their independent privacy practices.

You should review their terms and policies before using them.

15. Changes to This Privacy Policy

We may update this Privacy Policy when our practices, features, service providers, or legal obligations change.

We will post the updated policy in the App and update the Effective Date.

Where required, we may provide additional notice or request renewed consent.

16. Florida Law

This Privacy Policy is governed by applicable United States federal law and the laws of the State of Florida, without limiting any mandatory rights you may have under the laws of your country, state, or region.

17. Contact Us

For privacy questions, access requests, correction requests, deletion requests, or complaints, contact:

Exelar LLC

Jurisdiction: Florida, United States

© 2026 Exelar LLC. All rights reserved.