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PRIVACY POLICY

Last updated: October 9, 2026

This Privacy Policy explains how personal data is processed in connection with Lymphik, including its quiz funnel, website, application, member platform, Lymphatic Walking program, tracking features, AI Coaches, Challenges, Library content, subscriptions, customer support, and related online services.

This Privacy Policy governs personal-data processing only. Commercial rights relating to purchases, subscriptions, cancellation, refunds, or Money-Back Guarantees are governed by the applicable checkout terms, Terms of Service, Subscription Terms, Money-Back Policy, and mandatory law.

1. Data Controller and Contact Information

1.1 Applicable Controller

PMC Baltic FZ-LLC, Licence No. 45001684, is the default data controller for personal data processed in connection with the Services, unless a different controller is identified for a specific processing activity or regional notice.

Registered address: SFFO0507 Compass Building, Al Shohada Road, Al Hamra Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates

Privacy / support email: hello@lymphik.com

1.2 Contracting Party, Seller, Merchant of Record and Payment Roles

The data controller may differ from the Seller, contracting party, Merchant of Record, billing entity, payment processor, gateway, acquiring partner, or payment administrator for a particular transaction.

A Seller, Merchant of Record, or payment provider may process transaction data needed to accept payment, issue transaction records, administer subscriptions, process refunds or reversals, prevent fraud, and respond to payment disputes. Handling a payment does not by itself make that entity the controller of all Lymphik data.

2. Categories of Personal Data

2.1 Data You Provide

Depending on how you use the Services, you may provide:

name, email address, account and contact information;

quiz or assessment answers, including age or age band, gender, goals, body-state information, weight-related information, body-shape or target-zone information, activity preferences, lifestyle and habit information, and other personalization inputs;

weight, nutrition, calorie, water, movement, activity, workout, habit, challenge, sleep, mindfulness, or progress information that you choose to log in the app;

questions or messages submitted to AI Coaches, together with the goals and tracked information used to personalize the response;

customer-support communications, complaints, cancellation, refund, or dispute requests and supporting information; and

information used to verify a privacy-rights request where applicable.

2.2 Automatically Collected Data

When you use the Services, technical and usage information may be collected, including:

IP address;

browser type and operating system;

device type or model;

language and time zone;

referring URLs, campaigns, or marketing links where used;

pages, screens, quiz steps, sessions, interactions, workout or feature events, and usage metadata; and

technical logs and security events.

2.3 Payment and Transaction Data

Payments may be processed through third-party payment providers. Lymphik does not generally receive or store complete payment-card details where those details are handled directly by the payment provider.

We may receive limited payment and transaction metadata such as a customer or transaction identifier, secure payment token, limited payment-method information where provided by the payment provider, amount, currency, timestamp, payment status, subscription status, refund or reversal status, and dispute or chargeback information where relevant.

2.4 AI Coach and Personalization Data

When you use AI Coaches, the question or message you submit and relevant personalization context may be processed to generate a response.

Relevant context may include your stated goals and selected information already tracked in the Service, such as nutrition, movement, weight-management, habits, motivation, or emotional-wellness information where the feature uses that context.

This Privacy Policy does not state that user content is used to train AI models.

3. Health-Related and Sensitive Information

Because Lymphik is a wellness and weight-management service, information you provide may include weight, body measurements or BMI-related inputs, eating and nutrition information, activity levels, sleep, stress, emotional well-being, puffiness or swelling-related symptoms, or other information that may be considered health-related or sensitive personal data under applicable law.

Where such information qualifies as sensitive or special-category personal data, we process it only for the relevant Service features and rely on explicit consent or another legally valid basis where required.

Providing sensitive information is voluntary. Where processing is based on consent, you may withdraw that consent at any time without affecting processing that was lawful before withdrawal.

Sensitive health-related or wellness content is not used for advertising merely because it is present in your quiz answers, app logs, or AI Coach conversations.

4. Purposes and Legal Bases

We process personal data only for purposes supported by an appropriate legal basis under applicable law. Depending on the processing activity and jurisdiction, we may process data to:

provide and administer the quiz, accounts, subscriptions, workouts, tracking features, AI Coaches, Challenges, Library content, and customer support under a contract;

personalize programs, activities, recommendations, progress information, and AI Coach responses as necessary to provide the Services;

process payments, administer subscriptions, deliver purchases, handle refunds or reversals, maintain accounting records, and comply with legal obligations;

protect accounts, prevent fraud and abuse, manage risk, and maintain Service security based on legitimate interests or legal obligations where applicable;

analyze and improve the Services using consent where required or another lawful basis where permitted;

send transactional and service communications necessary for the Services or legal compliance;

send marketing communications where permitted by law, using consent where required;

measure advertising, campaign attribution, and conversion performance where actually used and permitted, subject to applicable consent or opt-out requirements; and

establish, exercise, or defend legal claims and resolve refunds, complaints, disputes, chargebacks, and alleged unauthorized transactions.

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not retroactively invalidate processing that was lawful before withdrawal.

5. Cookies, Tracking and Privacy Controls

The Services may use cookies, local storage, session storage, pixels, and similar technologies for strictly necessary functionality, functional features, performance or analytics, and targeting or advertising purposes where those technologies are actually implemented.

Where consent is required, non-essential technologies are used subject to the consent mechanism made available through the Services.

Further information is provided in the Cookie Policy.

6. Payments, Subscriptions, Refunds and Disputes

Transaction data may be processed to administer purchases and subscriptions, confirm access, handle failed payments, process refunds or reversals, prevent fraud, maintain accounting records, investigate allegedly unauthorized transactions, respond to payment-provider or card-network disputes, and manage chargebacks.

Where reasonably necessary, we may retain and use order records, checkout or acceptance records, transaction terms, delivery or access logs, cancellation records, usage status, support and refund communications, payment-provider records, fraud indicators, and chargeback history to resolve disputes, establish amounts owed, enforce applicable policies, and establish, exercise, or defend legal claims.

This Privacy Policy does not determine whether a refund or Money-Back Guarantee claim is eligible.

7. Recipients and Service Providers

We may disclose personal data to service providers and other recipients only as reasonably necessary for the purposes described in this Policy. Relevant categories may include:

payment, billing, acquiring, bank, and card-network providers;

website, application, hosting, database, authentication, and security providers;

AI model and communication providers used to operate AI Coaches;

email and CRM providers, including ActiveCampaign, where used for account, service, or marketing communications;

analytics, performance-monitoring, advertising, and attribution providers where actually used and enabled;

professional advisers, insurers, accountants, and legal service providers; and

public authorities, regulators, courts, or law-enforcement bodies where required or permitted by law.

Depending on the activity, a third party may act as our processor or service provider, or may independently determine purposes and means of processing under its own privacy notice.

We may also disclose or transfer personal data in connection with a merger, acquisition, financing, reorganization, sale of assets, insolvency, dissolution, or transition of the Services to another operator, subject to applicable safeguards.

8. International Transfers

PMC Baltic FZ-LLC is established in the United Arab Emirates. Some service providers may process personal data in other countries.

Where personal data is transferred outside a jurisdiction that restricts international transfers, we use legally recognized safeguards as applicable, which may include adequacy mechanisms, Standard Contractual Clauses, or other lawful transfer tools.

This Policy does not claim participation in a specific data-transfer framework unless that participation has been separately confirmed.

9. Retention and Deletion

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, subject to legal, accounting, tax, fraud-prevention, security, dispute, chargeback, refund, regulatory, and limitation-period requirements.

Account, quiz, personalization, tracking, progress, AI Coach, support, and technical data may be retained for periods appropriate to the relevant purpose and operational need.

Purchase and transaction records may be retained for the period required by applicable accounting, tax, financial, dispute, refund, chargeback, fraud-prevention, or legal-claim requirements.

Retention may be extended where reasonably necessary or legally required for an open or anticipated dispute, refund, chargeback, fraud investigation, accounting or tax requirement, regulatory matter, security investigation, or legal claim.

A valid deletion request is handled subject to applicable law and lawful retention exceptions. Closing or deleting an account does not necessarily require immediate deletion of every transaction, accounting, consent, fraud, security, support, dispute, refund, chargeback, or legal-claim record that we are permitted or required to retain.

When personal data is no longer required, it will be deleted or de-identified in accordance with the applicable retention framework.

10. Privacy Rights and Choices

Depending on applicable law and your location, you may have rights concerning your personal data, including rights to:

request access to personal data;

request correction of inaccurate or incomplete data;

request deletion, subject to lawful exceptions;

request restriction of certain processing;

object to certain processing;

withdraw consent where processing is based on consent, without affecting prior lawful processing;

receive certain personal data in a structured, commonly used, machine-readable format where portability applies;

opt out of certain targeted advertising, statutory sale or sharing, or similar processing where applicable law provides such rights; and

lodge a complaint with a competent supervisory authority.

We may need to verify your identity or authority before acting on a privacy-rights request.

Privacy-rights requests may be submitted to hello@lymphik.com.

10.1 Marketing Choices

Where marketing communications are sent, you may use the unsubscribe mechanism provided in the message or contact us to exercise an applicable marketing choice.

Opting out of promotional marketing does not stop necessary transactional, account, billing, subscription, security, support, policy, or legal communications.

11. Automated Personalization

Lymphik may use automated processing to personalize quiz results, workout or wellness recommendations, Challenges, progress information, and AI Coach responses based on information you provide and how you use the Service.

This personalization is intended to improve relevance and is not intended to produce legal effects concerning you or similarly significantly affect you.

Automated outputs may be inaccurate and should not be treated as a medical diagnosis or professional healthcare assessment.

12. Security

We use reasonable administrative, technical, and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

No method of transmission or storage can be guaranteed to be completely secure.

Security and incident-related records may be retained where reasonably necessary to investigate, prevent, document, or respond to security incidents and to meet legal obligations.

13. Third-Party Services

Payment providers, hosting providers, AI providers, email services, analytics or advertising services, and other third parties may independently process some information under their own privacy notices.

This Privacy Policy describes processing controlled by or carried out on behalf of the controller identified above in connection with Lymphik. A request concerning data controlled solely by a third party may need to be directed to that third party.

14. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in the Services, technology, vendors, payment infrastructure, business practices, group operations, or legal requirements.

Where applicable law requires additional notice or consent for a material privacy change, we will provide that notice or obtain the required consent.

The "Last updated" date at the top of this Policy indicates the date of the most recent revision.

15. Contact Information

Email: hello@lymphik.com

Operator / default contracting entity: PMC Baltic FZ-LLC

Licence No.: 45001684

Registered address:

SFFO0507 Compass Building

Al Shohada Road

Al Hamra Industrial Zone-FZ

Ras Al Khaimah

United Arab Emirates

16. Related Policies and Document Hierarchy

This Privacy Policy should be read together with the applicable commercial and service policies. It governs personal-data processing and does not create or expand any commercial entitlement to a refund, cancellation, reimbursement, subscription benefit, or Money-Back Guarantee.

Cookie Policy

Terms of Service

Subscription Terms

Money-Back Policy