EMPEDOC AI LLC ("we," "us," "our") operates the Phoebe mobile application ("Phoebe," "the App"). This Privacy Policy explains what data we collect, why we collect it, how we process it, and what rights you have regarding your information.

1. Data We Collect

1.1 Account Information

When you create an account, we collect your name, email address, age, and biological sex. This information is necessary to provide a personalized experience and to calibrate the prediction model.

1.2 Health Data (Apple HealthKit)

With your explicit permission, Phoebe reads the following data from Apple HealthKit:

• Sleep duration and quality
• Heart rate variability (HRV)
• Resting heart rate
• Step count and active energy

1.3 Diary Entries

Information you log manually or via voice check-in, including: headache occurrence, severity, duration, symptoms, triggers, pain location, medication taken, mood, and notes.

1.4 Location Data

With your permission, Phoebe accesses your approximate location to retrieve local atmospheric data (barometric pressure, temperature, humidity) via Apple WeatherKit. We do not track your movements or store a history of your locations. Location is used only at the moment of a weather data request.

1.5 Voice Data

When you use the Voice Check-in feature, audio is processed to extract symptom information. Audio recordings are processed in real-time and are not stored on our servers after transcription is complete.

1.6 Chat Conversations

Messages you send to the Phoebe AI assistant are transmitted to our server and to a third-party AI provider (Google Gemini API) to generate responses. Chat history is stored on our server to provide conversational context. You may delete your chat history at any time from within the App.

2. How We Use Your Data

Data	Purpose
Health biometrics (HealthKit)	Input to migraine risk prediction model. Combined with atmospheric data to produce your daily Blended Risk Score and 7-day forecast.
Diary entries	Personalize predictions, display your history, generate PDF medical reports, and improve prediction accuracy over time.
Location	Retrieve real-time barometric pressure, temperature, and humidity for your area via Apple WeatherKit.
Voice input	Convert spoken symptom descriptions into structured diary entries.
Chat messages	Generate AI-assisted responses about your logged health data.
Account info	Authenticate your account, personalize the experience, and enable data recovery.

We do not use your data for advertising. We do not sell your data to any third party. We do not use your data to build user profiles for marketing purposes.

3. Third-Party Services

Phoebe integrates with the following third-party services to provide its core functionality:

Service	Provider	Data Shared	Purpose
Prediction API	Hugging Face, Inc.	Anonymized biometric and weather features (no personally identifiable information)	ML-based migraine risk prediction
AI Chat	Google LLC (Gemini API)	Chat messages and relevant diary context	AI-powered health diary assistant. Google does not retain conversation data after processing.
WeatherKit	Apple Inc.	Approximate location coordinates	Retrieve local atmospheric conditions
HealthKit	Apple Inc.	Read-only access, on-device	Access biometric data with user permission
In-App Purchases	Apple Inc. (StoreKit)	Transaction data managed by Apple	Process subscription payments. We do not see or store your payment information.

Each third-party provider operates under its own privacy policy. We encourage you to review their respective policies.

4. Data Storage & Security

Your data is stored on private, secured servers operated by EMPEDOC AI LLC. We implement industry-standard security measures including:

• Encrypted data transmission (HTTPS/TLS) between the App and our servers
• Containerized server infrastructure (Docker) with restricted access controls
• Authentication-protected API endpoints
• Regular security reviews and updates

While we take reasonable precautions to protect your information, no method of electronic storage or transmission over the Internet is 100% secure. We cannot guarantee absolute security.

5. Data Retention & Deletion

We retain your personal data only for as long as your account is active and as needed to provide the services described in this policy.

6. Future Use of Anonymized Data

In the future, we may use anonymized and aggregated data to improve our machine learning models and prediction accuracy. If and when we implement this:

• All data will be stripped of personally identifiable information before any processing
• Anonymized data cannot be traced back to individual users
• We will update this Privacy Policy before any such use begins
• You will be notified of material changes and may opt out at that time

As of the effective date of this policy, we do not use individual user data to train or improve our ML models.

7. Your Rights

7.1 All Users

• Access: You may request a copy of the personal data we hold about you.
• Correction: You may update your personal information through the App at any time.
• Deletion: You may delete your account and all associated data at any time.
• Export: You may generate and export PDF reports containing your health diary data.

7.2 European Economic Area (EEA) Residents — GDPR

If you are located in the EEA, you have additional rights under the General Data Protection Regulation, including the right to data portability, the right to restrict processing, and the right to object to processing. Our legal basis for processing your health data is your explicit consent, which you may withdraw at any time by deleting your account or revoking HealthKit permissions in your device settings.

7.3 California Residents — CCPA

If you are a California resident, you have the right to know what personal information we collect, request deletion, and opt out of the sale of personal information. We do not sell personal information.

8. Children's Privacy

Phoebe is not intended for use by individuals under the age of 13 (or 16 in the European Economic Area). We do not knowingly collect personal information from children. If we learn that we have collected data from a child under the applicable age, we will delete it promptly. If you believe a child has provided us with personal data, please contact us at privacy@empedoc.com.

These Terms of Use ("Terms") govern your access to and use of the Phoebe mobile application provided by EMPEDOC AI LLC. By downloading, installing, or using Phoebe, you agree to be bound by these Terms.

1. Acceptance of Terms

By creating an account or using Phoebe, you confirm that you have read, understood, and agree to these Terms and our Privacy Policy. If you do not agree, you must not use the App.

2. Medical Disclaimer

The prediction model is based on statistical correlations and machine learning. While we strive for accuracy, predictions are probabilistic and not guaranteed. Individual results will vary. A low risk score does not mean an attack will not occur, and a high risk score does not mean an attack is certain.

3. Account & Eligibility

To use Phoebe, you must:

• Be at least 13 years of age (or 16 in the EEA)
• Provide accurate and complete registration information
• Maintain the security of your account credentials
• Notify us immediately of any unauthorized use of your account

You are responsible for all activity that occurs under your account.

4. Subscriptions & Payments

Phoebe offers both free and premium subscription tiers. Premium subscriptions are processed through Apple's In-App Purchase system and are subject to Apple's terms and conditions.

• Subscription prices are displayed in the App and may vary by region.
• Subscriptions automatically renew unless cancelled at least 24 hours before the end of the current billing period.
• You may manage or cancel your subscription through your Apple ID settings.
• Refunds are handled by Apple in accordance with their refund policies.
• We reserve the right to modify subscription pricing with reasonable advance notice.

5. Acceptable Use

You agree not to:

• Use Phoebe for any unlawful purpose or in violation of any applicable laws
• Attempt to reverse engineer, decompile, or disassemble the App or its underlying algorithms
• Interfere with or disrupt the App's servers, networks, or infrastructure
• Create multiple accounts for fraudulent purposes
• Use the App to generate, store, or transmit content that is harmful, abusive, or violates the rights of others
• Misrepresent Phoebe's outputs as professional medical advice to others

6. Intellectual Property

All content, features, functionality, design, machine learning models, algorithms, and source code of Phoebe are owned by EMPEDOC AI LLC and are protected by United States and international intellectual property laws. The Phoebe name, logo, and all related marks are trademarks of EMPEDOC AI LLC.

Your health data remains yours. We claim no ownership over the personal data you provide or generate through use of the App.

7. Limitation of Liability

To the maximum extent permitted by applicable law:

• Phoebe is provided on an "AS IS" and "AS AVAILABLE" basis without warranties of any kind, whether express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, and non-infringement.
• EMPEDOC AI LLC shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of data, health outcomes, or damages arising from reliance on the App's predictions or AI-generated responses.
• In no event shall our total liability exceed the amount you have paid us in the twelve (12) months preceding the claim.

8. Changes & Termination

We reserve the right to modify these Terms at any time. Material changes will be communicated through the App or via email. Continued use of Phoebe after such notification constitutes acceptance of the updated Terms.

We may suspend or terminate your access to the App at any time for violation of these Terms, with or without notice. Upon termination, your right to use the App ceases immediately. You may request deletion of your data at any time, regardless of account status.

9. Governing Law & Contact

These Terms shall be governed by and construed in accordance with the laws of the United States of America. Any disputes arising under these Terms shall be resolved in the courts of competent jurisdiction.