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Heal — Privacy Policy

Application: Heal (also known as “Healing Protocol”) Operator: Jason Kilic Last updated: July 15, 2026

At Heal, our mission is to support you through preparation for and recovery from knee replacement surgery, and we want you to know how we collect and use the data you provide to us along the way. This Privacy Policy describes how Jason Kilic, an individual doing business as “Healing Protocol” (“Heal,” “we,” “us,” “our”), collects, uses, and discloses information through the Heal mobile application and related services (collectively, the “Services”). We encourage you to read this Privacy Policy together with our Terms of Service.

BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE, AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING IN THE UNITED STATES AS DESCRIBED IN THIS PRIVACY POLICY.

The Services and all associated systems, including registration, are housed on servers in the United States. If you are located outside of the United States, please be aware that information we collect will be processed and stored in the United States, a jurisdiction whose data protection and privacy laws and principles, including your data subject rights, may not offer the same level of protection as those in the country or region where you reside. By using our Services and providing information to us, you consent to the transfer to and processing of that information in the United States.

Please read this Privacy Policy carefully. Your access to and use of the Services signifies that you have read, understand, and agree to all terms within this Privacy Policy. If you do not agree with any part of this Privacy Policy or our Terms, please do not access or use the Services or otherwise submit your Personal Data to us.


Information About Your Personal Data

This Privacy Policy relates to data about you, your devices, and your interaction with our Services.

“Personal Data” is information that can be used to identify you, directly or indirectly, alone or together with other information. This includes things such as your name, email address, device identifiers, and “Health and Recovery Data.”

“Health and Recovery Data” is information you provide about your surgery and health, including your surgery date and type, operative knee, prior surgery history, surgeon and hospital names, weight, height, diabetes status, dietary preferences, medical conditions, medications, allergies, daily check-in responses (such as pain level, range of motion, mood, and stress), recovery activity you track (such as hydration, meals, and exercise), and progress photos you choose to upload.

We may create de-identified or anonymized data from Personal Data by removing or obscuring the components that make the data identifiable to you. Our use of de-identified and anonymized data is not subject to this Privacy Policy.


What We Collect and How We Use It

1. When you register for an account

When you create a Heal account we collect your email address and a password (managed through our authentication provider), and, if you provide it, your first name. We use this information to create and secure your account, provide the Services, and communicate with you about the Services.

2. When you set up your recovery profile

We collect the Health and Recovery Data you enter during onboarding and in your profile — including your surgery date — to build your recovery timeline, determine your recovery stage, and show you the daily plans, exercises, and educational content that match where you are in recovery.

3. When you check in, track, or upload photos

We collect the check-in responses, tracker entries, and progress photos you submit so you can monitor your recovery over time and so the Services can present your history back to you. Photos you upload are stored with our cloud hosting provider in the United States.

4. When you set medication reminders

We collect the medication names and reminder times you enter to schedule reminder notifications. Reminder notifications are delivered locally by your device and may display the medication names you entered; anyone able to view your device’s lock screen may see them. You can adjust notification previews in your device settings.

5. When you use the Ask chat and other AI features

The Ask chat is powered by a third-party AI service. Before your first message is sent, the app shows you a disclosure describing this data sharing and asks for your permission; nothing is sent to the AI service until you agree.

When you use the Ask chat, the following data is sent to Amazon Web Services, Inc. (“AWS”) and processed through its Amazon Bedrock service using Anthropic’s Claude model in order to generate responses: (a) the messages you type and any photos you attach; (b) relevant context from your recovery profile, such as your surgery type and date, operative knee, recovery stage, age, and the conditions, medications, and allergies you entered; and (c) relevant recent check-in responses and tracked activity. This data is used solely to generate responses and provide safety features (such as detecting emergencies), and is not used to train third-party AI models or for advertising. AWS processes this data on our behalf under data-processing terms that provide protections equivalent to this Privacy Policy.

We may retain chat history to provide the feature, maintain continuity across sessions, and support safety features. As described in our Terms, AI responses are informational only and are not medical advice.

6. When you contact support

If you use the in-app support chat or email us, we collect the information you share so we can respond to and resolve your request. In-app support conversations are processed by our customer-support platform provider.

7. When you purchase a subscription

Subscriptions are purchased through, and billed by, the Apple App Store. We do not receive or store your full payment card details. We receive transaction and subscription-status information (such as whether your subscription is active) through Apple and our subscription-management provider so we can unlock paid features for your account.

8. Device, usage, and diagnostic data

When you use the Services we automatically collect certain device and usage data, including device model, operating system version, app version, device and app identifiers, IP address, push notification tokens, usage events (such as screens viewed and features used), and crash and performance logs. We use this data to operate, secure, debug, and improve the Services and to understand how features are used. This data is collected in part through analytics and crash-reporting tools provided by our service providers.

9. Communications

We may use your email address and push notifications to send you Service-related messages — such as reminders you have set, updates to your recovery plan, and notices about changes to our Terms or this Privacy Policy. With your consent where required, we may also send promotional messages; you can opt out of promotional email at any time using the unsubscribe link in any such email, and you can control push notifications in your device settings. We may send strictly necessary communications, such as security or legal notices, even if you have opted out of promotional messages.

10. Legal requirements, safety, and enforcement

We may use Personal Data to comply with laws, regulations, court orders, or other legal obligations; to assist in an investigation; to protect and defend our rights and property or the rights or safety of third parties; to enforce our Terms or this Privacy Policy; and for fraud- and crime-prevention purposes.


How We Disclose Personal Data

We do not sell your Personal Data, and we do not use or disclose your Personal Data for third-party advertising. We disclose Personal Data only in the following ways:

1. To service providers. We share Personal Data with vendors who process it on our behalf to provide the Services, including cloud hosting and storage, authentication, analytics and crash reporting, AI processing for the Ask chat (Amazon Web Services / Amazon Bedrock, as described above), subscription management, push notification delivery, and customer support. These providers are permitted to use your Personal Data only to provide services to us, and are required to provide protections for your Personal Data that are the same as or equivalent to those in this Privacy Policy.

2. To Apple. Subscription purchases are processed by the Apple App Store under Apple’s own terms and privacy policy.

3. For legal compliance, law enforcement, and public safety. We may disclose Personal Data to law enforcement, government or regulatory bodies, or other authorized third parties in order to comply with laws, regulations, court orders, or other legal obligations; to assist in an investigation; to protect and defend our rights and property or the rights or safety of third parties; to enforce our Terms or this Privacy Policy; or for crime-prevention purposes.

4. In the event of an actual or contemplated sale. We may disclose Personal Data to prospective or actual purchasers, investors, or successor entities in connection with a financing, sale, reorganization, or other transaction involving all or part of our business or assets, including for due diligence purposes, subject to assurances of appropriate data handling practices and safeguards.


Your Choices and Controls

Access and correction. You can view and update your profile information, including your Health and Recovery Data, at any time in the app (Profile & Support).

Account deletion. You can delete your account at any time in the app (Profile & Support → Delete account) or by emailing us at help@pulsivehealth.com. Deleting your account is permanent and removes your data from the Services, subject to the retention described below.

Email. You can opt out of promotional email using the unsubscribe link in any promotional message. You will still receive strictly necessary Service communications.

Push notifications. You can enable or disable push notifications, and control whether previews appear on your lock screen, in your device settings. Reminders you created can also be removed within the app.

If you choose not to provide data. You may choose not to provide certain Personal Data, but some features — such as your recovery timeline, personalized daily plans, or medication reminders — may be unavailable or may not function properly without it.


Data Retention

We retain your Personal Data for as long as you maintain an account or as otherwise necessary to provide you the Services. We also retain Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Where we no longer need to process your Personal Data for the purposes set out in this Privacy Policy, we will delete it from our systems.


Security

We implement technical and organizational safeguards designed to protect against unauthorized or unlawful processing of Personal Data and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data. Please be advised, however, that no system can fully eliminate security risks associated with the storage and transmission of Personal Data.


Third-Party Services

The Services may contain links to or interfaces with services operated by third parties, such as the Apple App Store and our customer-support chat. This Privacy Policy does not apply to third-party services, and any data you provide to them is governed by their own privacy policies, which we encourage you to review.


Children

The Services are intended for adults. We do not knowingly collect Personal Data from individuals under 18. If you become aware that an individual under 18 has provided us with Personal Data, please contact us at help@pulsivehealth.com, and we will take steps to remove the data and cancel that individual’s account.


Transfers of Your Personal Data to Other Countries

The Personal Data we process, and all associated Services and systems, are housed on servers in the United States. If you are located outside the United States, Personal Data we collect will be processed and stored in the United States, where data protection laws may offer a lower level of protection than in your country or region. By using our Services and submitting your Personal Data, you agree to the transfer, storage, and processing of your Personal Data in the United States. Where transfers from the European Economic Area or the United Kingdom require additional safeguards, we rely on your consent or other lawful transfer mechanisms permitted by applicable law.


Residents of the European Economic Area and the United Kingdom

For the purposes of applicable data protection laws, Jason Kilic, doing business as Healing Protocol, is the controller of the Personal Data you provide to us.

Legal bases for processing. We process your Personal Data on the following legal bases:

  • Performance of a contract (Art. 6(1)(b) GDPR): to register and secure your account, provide the Services you request — including your recovery timeline, daily plans, reminders, and chat — and respond to your support requests.
  • Consent (Art. 6(1)(a) and, for health data, Art. 9(2)(a) GDPR): for our processing of the Health and Recovery Data you choose to provide, and for promotional communications where consent is required. You may withdraw consent at any time with future effect, without affecting the lawfulness of processing carried out before withdrawal.
  • Legitimate interests (Art. 6(1)(f) GDPR): to secure, analyze, and improve the Services; to communicate with you about the Services; to enforce our Terms; and to prevent fraud and misuse — except where overridden by your interests or fundamental rights.
  • Legal obligation (Art. 6(1)(c) GDPR): to comply with laws, regulations, court orders, or other legal obligations.

Your rights. Subject to applicable law, you have the right of access to your Personal Data (Art. 15), the right to correction (Art. 16), the right to erasure (Art. 17), the right to restriction of processing (Art. 18), the right to data portability (Art. 20), and the right to object to processing, including for direct marketing (Art. 21). To exercise these rights, contact us at help@pulsivehealth.com. We will respond to reasonable requests within the time limits prescribed by law.

Health data. Some Health and Recovery Data may be considered health data under the GDPR. We process it, with your consent, to provide the Services and to present information you can incorporate into your own view of your recovery; it is not professional medical advice and is not intended for diagnostic purposes.

Complaints. We encourage you to contact us directly so we can address your concerns. You also have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State or UK region where you reside, work, or where an alleged infringement occurred.


Residents of the United States

We do not sell Personal Data as defined by Nevada law.

Residents of California

If you are a California resident, you have certain rights to the Personal Data we have collected about you, subject to exemptions under applicable law:

  • Right to know and access: you may request confirmation of whether we process your Personal Data and access to the Personal Data we have collected about you, including the categories collected, used, and disclosed.
  • Right to deletion: you may request that we delete your Personal Data, as permitted by law. You can also delete your account directly in the app.
  • Right to correct: you may request that we correct inaccurate Personal Data, and you can update most information directly in the app.
  • No sale or sharing: we do not sell your Personal Data, and we do not share it for cross-context behavioral advertising. We have no actual knowledge of selling or sharing the Personal Data of anyone, including minors under 16.
  • Right to non-discrimination: we will not discriminate against you, in price or service, for exercising any of these rights.

To exercise these rights, contact us at help@pulsivehealth.com. To protect your data, we will verify your identity before fulfilling a request — for example, by requiring that the request come from the email address associated with your account — and will let you know if we cannot fulfill a request and why.

Under California Civil Code Section 1798.83, California residents may request a list of any Personal Data we disclosed to third parties for those third parties’ direct marketing purposes in the preceding calendar year. We do not disclose Personal Data to third parties for their own direct marketing purposes.


Changes to This Privacy Policy

We may update this Privacy Policy from time to time in accordance with applicable data protection laws. If we make material changes, we will notify you through the Services and/or by email before the change becomes effective. The “Last updated” date at the top of this document reflects the most recent revision. Your continued use of the Services after an update signifies your acceptance of the revised Privacy Policy.


How to Contact Us

If you have any questions, comments, or concerns about how we handle your Personal Data, contact us:

Email: help@pulsivehealth.com Mail: Pulsive Health, 345 West Portal Ave, Ste 210, San Francisco, CA 94127

From surgery date to full stride.

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