AlgaeCal Community Privacy Policy

The AlgaeCal Community Privacy PolicyLast Updated: December 18, 2025

This privacy policy (“Privacy Policy”) explains how The AlgaeCal Community, which is owned and operated by AlgaeCal Inc., a corporation organized under the laws of the Province of British Columbia, Canada (“we,” “us,” and/or “our”) collects, uses, and discloses information from individuals (“you” and/or “your”) who access and use our online community or mobile or other downloadable applications (collectively, the “Community”). 

Your use of the Community is also subject to (a) the default Community Terms of Service made available by CircleCo, Inc. (“Circle”) for this Community and (b) the Additional Community Terms for The AlgaeCal Community attached to those terms as Exhibit A (together, the “Community Terms”).

This Privacy Policy applies only to the Community. It does not apply to any other AlgaeCal websites, products, or services, which are governed by their own privacy policies.

We reserve the right, at our discretion, to change, modify, add, or remove portions of this Privacy Policy at any time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases (for example, if we plan to use your information in a way that materially differs from this Privacy Policy), we will provide you with additional notice (such as sending you a notification).

We encourage you to review this Privacy Policy whenever you access the Community or otherwise interact with us to stay informed about our information practices and the choices available to you.

  1. Our Relationship with Circle

The Community is hosted on and powered by a technology platform provided by CircleCo, Inc. (“Circle”).

For most of the personal information described in this Privacy Policy, The AlgaeCal Community is the “data controller” (or “business”) and Circle processes that information on our behalf as our service provider.

Circle may also process certain information about your account and use of Circle’s platform as an independent controller under its own privacy notices. In those cases, Circle’s own privacy notice and cookie policy will govern its independent processing. 

For more information on Circle’s practices, please review Circle’s Privacy Notice (https://circle.so/privacy) and Cookie Policy (https://circle.so/cookie-policy).

  1. Personal Information We Collect

We may collect the following types of personal information from and about you when you use the Community.

2.1. Personal Information You Provide to Us

2.1.1. Registration and Profile Information

When you open an account with us through the Community (“Account”), we may ask you to provide identifiers and contact information such as your name, email address, and any other information you choose to provide in your profile.

2.1.2. Communications with Us

We may also collect identifiers and related information, such as your name, email address, and the content of your communications, when you:

• participate in any interactive features of the Community (for example, send us a message through the Community)• fill out a form• publish statements or posts on our platform• participate in a contest or promotion• communicate with us via third-party social media sites• request customer support• otherwise communicate with us

If you subscribe to any of our newsletters or updates relating to the Community, we will collect your email address and any other information you choose to provide. When we send you emails, we may track whether you open them or click links to help us improve the Community and our communications.

2.1.3. Messages Between Members

When you communicate with other members through the Community (for example, direct messages, group discussions, or comments), we and our service providers (including Circle) receive and process:

• the content of the messages you send and receive, and• information about those messages, such as when they were sent or received.

We do not routinely monitor private messages between members, but they may be processed by our systems (and Circle’s systems) for security, abuse detection, and support purposes, as described in this Privacy Policy and in the Community Terms of Service.

Please be aware that information you share in any part of the Community, including private or semi-private spaces, may reveal information about your health, medical history, or other sensitive topics. You should carefully consider what you choose to disclose and to whom.

2.1.4. Content You Share in the Community

We may collect other content and information you share through the Community when you:

• submit information or content (for example, by commenting on a blog, posting in groups or forums, or uploading photos or videos), or• otherwise interact with the Community.

Because The AlgaeCal Community focuses on bone health and related topics, the content you choose to share may include information about your health or medical history. We do not require you to share such information, and you should only share what you are comfortable making available to us and, where applicable, to other members.

2.1.5. Payment Information

If you make a purchase through the Community, your payment-related information, such as credit card or other financial information, is collected and processed by our third-party payment processor(s) on our behalf. We do not store your full payment card number on our own systems. We may receive limited information related to your transactions, such as:

• the fact that a transaction occurred• the last four digits of your card number• the amount paid and items purchased• the date and time of the transaction

We use this information for recordkeeping, customer support, and compliance purposes.

2.2. Personal Information Collected Automatically

When you access or use the Community or transact business with us, we and our third-party partners (including Circle) may automatically collect information you provide to us, information about how you access and use the Community, and information about the device you use to access the Community, including:

2.2.1. Device Identifiers

Identifiers such as your:

• IP address• internet service provider• type of mobile or other device you use• temporary or persistent unique device identifiers (sometimes called UDIDs)• identifiers associated with browser cookies, web beacons, and similar technologies that Circle or we deploy on the Community

2.2.2. Internet or Other Electronic Network Activity Information

We and our third-party partners may collect information about the devices and computers you use to access the Community, such as:

• browser type, language, and operating system• referrer web page• pages visited within the Community• hyperlinks clicked• videos or content you view• purchase information and your checkout process• your approximate location when you access or interact with our Community• other similar actions

We may also use tools (including those provided by Circle and other service providers) to record or analyze how you interact with the Community, such as mouse movements, scrolling, clicks, and general navigation patterns, as well as certain data you enter when you interact with the Community. We use this information primarily to improve usability, detect and prevent fraud or abuse, and understand how members engage with the Community.

2.2.3. Geolocation Information

We may derive the approximate location of your device from your IP address. We may combine this information with other location-based information, such as your billing or postal code. You have the ability to stop the collection of more precise location information at any time (see “Your Choices” below for details).

2.2.4. Cookies and Similar Technologies

Circle communities use both standard cookie tracking (which is essential for the site to function) and, in some cases, third-party tracking (for analytics and marketing). Circle’s cookie practices are described in its Cookie Policy (https://circle.so/cookie-policy). You can manage your browser cookie settings as described below under “Your Choices”.

Within The AlgaeCal Community:

• We and Circle use cookies and similar technologies that are necessary for security, login, basic functionality, and to remember your preferences.• We will use tracking within the Community to understand member behaviour, conversion, and engagement metrics (for example, which content is most engaged with, how members move through onboarding flows, and how features are used).• We do not currently use external analytics tools (such as Google Analytics) specifically for the Community, and we do not currently use third-party advertising pixels (such as Meta/Facebook Pixel) within the Community.• We may, however, export or sync Community member data to certain third-party databases and tools (such as Braze, Salesforce, BigQuery, or similar platforms) to support our own internal analytics, member communications, and personalization efforts. The exact integrations and configurations may evolve over time and will be aligned with this Privacy Policy and applicable law.

For more information about how Circle uses cookies and similar technologies on the platform, please review Circle’s Cookie Policy at https://circle.so/cookie-policy. You can manage your browser cookie settings as described below under “Your Choices.”

2.3. Personal Information Collected from Third Parties

2.3.1. Information from Other Members

When you interact with other members in the Community, we may collect from them any content or information that they choose to share about you (for example, if another member mentions you in a post or message).

2.3.2. Information from Other Sources

We may also obtain information about you from other sources, including but not limited to:

• social media platforms• marketing partners• other third parties

For example, if you connect your social media account to your Account or create or log into your Account through a social media site, certain information from your social media account will be shared with us, which may include information that is part of your profile. We may also supplement the information that you provide to us with demographic or interest-based information we receive from other sources. Once combined with your information, we treat the combined data in accordance with this Privacy Policy.

  1. How We Use Personal Information

We use the information we collect about you, including personal information, for the following purposes:

3.1. Provide, Maintain, and Improve the Community

• provide, operate, and maintain the Community and its features• personalize and improve your experience on the Community• understand how members use and engage with different sections, content, and features

3.2. Process Transactions

• process, complete, and maintain records of purchases or other transactions in the Community• provide you with receipts, customer support, and information related to your transactions

3.3. Communicate with You

• send you technical notices, updates, security alerts, and support and administrative messages• respond to your comments, questions, and requests, and provide customer service• communicate with you about products, services, offers, promotions, rewards, and events offered by The AlgaeCal Community and, where appropriate, our affiliates• provide you with news and information we think will be of interest to you

We may use Community activity data (for example, what content you engage with) to personalize some of these communications so they are more relevant to your interests.

3.4. Analytics, Research, and Product Development

• monitor and analyze trends, usage, engagement, and effectiveness in connection with the Community, including offers, content, and communications features• develop new features, content, and functionality for the Community• understand and improve member experience and outcomes (for example, how different resources or programs are used)

We may perform some of this analysis using data exported from the Community into our own systems or tools (such as Braze, Salesforce, or BigQuery), as described above.

3.5. Security, Fraud Prevention, and Legal Compliance

• detect, investigate, and prevent fraudulent transactions and other illegal activities• protect the rights, property, and safety of The AlgaeCal Community, our members, and others• comply with our legal obligations, including responding to lawful requests from public authorities

3.6. Promotions and Contests

• facilitate contests, sweepstakes, and promotions• process and deliver entries and rewards

3.7. Combining Information

• link or combine information we get from the Community with information we obtain from other sources (for example, from AlgaeCal’s other systems) to better understand your needs and provide you with more relevant services and content

3.8. Administrative and Other Purposes

• maintain appropriate records for internal administrative purposes• carry out any other purpose described to you at the time the information was collected or permitted by law

  1. Legal Bases for Processing (EEA/UK/Canada Visitors)

While the Community is hosted in the United States and primarily intended for visitors located in the U.S., individuals from the European Economic Area (“EEA”), United Kingdom (“UK”), and Canada may also access it. When we process personal information of individuals in those regions, we rely on one or more of the following legal bases (as applicable):

• Performance of a contract: where processing is necessary to provide the Community, manage your Account, or perform our agreement with you (for example, to allow you to participate in the Community, process your transactions, or respond to your requests).• Legitimate interests: where processing is necessary for our legitimate interests or those of a third party, and those interests are not overridden by your rights and interests (for example, to secure our systems, understand Community usage, improve content, or send certain non-essential but relevant communications).• Consent: where we rely on your consent (for example, for certain marketing communications, or where local law requires consent for certain cookies or tracking), you may withdraw that consent at any time using the methods described in this Privacy Policy.• Legal obligations: where processing is necessary for us to comply with a legal obligation (for example, recordkeeping, responding to lawful requests, or complying with applicable health or safety regulations).

4.1. Cross-Border Transfers of Personal Information

We and many of our service providers (including Circle) are located in, or process personal information from, countries outside of your place of residence, including the United States. Where we transfer personal information from the EEA, UK or Switzerland to countries that do not provide an equivalent level of data protection, we will rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (and the UK and Swiss equivalents where applicable) or other transfer mechanisms approved under applicable data protection laws. You may contact us using the details in the “Contact Us” section below if you would like more information about these safeguards.

  1. How We Disclose Personal Information

We may disclose personal information we collect about you as described below or at the time of collection.

5.1. Partners and Affiliates

We may disclose any information we receive to our partners, corporate affiliates, parent entities, or subsidiaries for any of the purposes described in this Privacy Policy. Those entities will handle your information in accordance with this Privacy Policy or a privacy policy that offers a similar level of protection.

5.2. Circle (Platform Provider)

The Community is powered by a technology platform provided by Circle. We may disclose your information to Circle in connection with the operation and support of the Community. Circle processes this information as our service provider and may also process limited information for its own purposes as described in its privacy notices (https://circle.so/privacy).

5.3. Service Providers and Vendors

We may disclose your information to other vendors, consultants, and service providers retained in connection with the operation of the Community and our business, such as:

• hosting and infrastructure providers• email and message delivery providers• analytics and reporting tools• customer relationship management (CRM) platforms (for example, Salesforce)• customer engagement and messaging tools (for example, Braze)• data storage and data warehouse services (for example, BigQuery or similar platforms)• customer support tools

These third parties are authorized to use your personal information only as necessary to provide services to us and are contractually required to protect it.

5.4. Other Members of the Community

If you provide or share information with other members of the Community, they may use it for their own purposes. If you post information or content—such as photos, comments, stories, or experiences—or participate in discussion groups or other public or group features, that information may be visible within the Community and, depending on the configuration, may be discoverable by other members.

In some cases, content shared within the Community may also be accessed via links from other websites or social media platforms, depending on how you or other members choose to share it. We cannot control what other members or third parties may do with information that you choose to make available to them. You should carefully consider what you disclose in any public or group areas of the Community.

Because many members may join the Community to discuss bone health and related topics, you may choose to share health-related or other sensitive information. Sharing such information is entirely voluntary, and you should only disclose what you are comfortable making available to others.

5.5. Analytics and Measurement Partners

We may disclose certain information to analytics and measurement partners (including tools integrated with Braze, Salesforce, BigQuery, or other internal analytics systems) to help us:

• understand member engagement and behaviour• measure the performance of content, programs, or campaigns• improve member experience and outcomes

We do not use this data for third-party targeted advertising across other companies’ websites. At this time, we do not deploy external advertising pixels (such as Meta/Facebook Pixel) within the Community.

5.6. Legal and Law Enforcement

We may disclose information we collect about you with law enforcement, governmental agencies, or authorized third parties if we believe that disclosure is:

• reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request• necessary to enforce our agreements, Terms of Service, or other policies• necessary to detect, prevent, or otherwise address fraud, security, or technical issues• necessary to protect the rights, property, or safety of The AlgaeCal Community, our members, or the public, as required or permitted by law

5.7. In Connection with a Change of Control

We may transfer or disclose your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company. In such cases, we will take reasonable steps to ensure that the receiving party protects your personal information in a manner consistent with this Privacy Policy.

5.8. With Your Consent or at Your Direction

Where required by law, or where appropriate, we may share your information with your consent or at your specific direction (for example, if you request that we share a testimonial or connect you with a particular expert or partner).

  1. No Sale or Third-Party Advertising Use of Personal Information

We do not sell personal information and we do not share personal information for cross-context behavioral advertising as those terms are defined under applicable U.S. state privacy laws (including the California Consumer Privacy Act, as amended).

We may use your personal information and Community activity data for our own internal purposes to:• understand your interests and engagement with Community content• send you personalized or segmented communications about our own content, programs, or offerings• improve how we design and offer AlgaeCal resources to you

We do not use your Community data to support third-party advertising on other Company sites or on unrelated third-party sites, and we do not permit our analytics or customer engagement providers to use Community data to build or enrich profiles for advertising to you or others on their own or other clients’ services.

  1. Data Retention

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

• provide the Community and services you request• support the purposes described in this Privacy Policy• comply with our legal and regulatory obligations• resolve disputes and enforce our agreements• maintain appropriate business and financial records

In practice, this generally means:

• We keep your Account information while your Account is active and for a reasonable period afterwards (for example, to allow you to re-activate or to maintain transaction records), unless a longer retention period is required or permitted by law.• We may retain certain transaction, support, or log records for a longer period where we have a legal obligation to do so or where it is necessary to protect our legal rights (for example, in relation to disputes, audits, or tax requirements).• Content you have posted in public or group areas of the Community may remain visible to other members even after your Account is deactivated or deleted, but we will generally cease to associate that content with your identifiable profile unless retention is required for legal or operational reasons.

We may also retain and use de-identified or aggregated information derived from personal information after it has been deleted, but we will not attempt to re-identify such data.

  1. Children’s Privacy

The Community is not intended for individuals under the age of 18. No one under the age of 18 is authorized to provide any personal information through the Community. We do not knowingly collect personal information from anyone under the age of 18. If we learn that we have collected or received personal information from a child under the age of 18, we will take reasonable steps to delete that information. If you believe we might have any information from or about a child under 18, please contact us at support@algaecal.com.

  1. Social Sharing Features and Third-Party Links

The Community may offer social sharing features and other integrated tools, which let you share actions you take on the Community with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.

For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the third-party platforms or services that provide those features.

  1. Your Choices and Rights

10.1 Account Information

You may update and correct certain Account information you provide to us at any time by logging into your Account and editing your profile or settings. If you wish to request deactivation or deletion of your Account, you may email us at support@algaecal.com. We may retain certain information as required or permitted by law, or for legitimate business purposes (for example, recordkeeping, security, and dispute resolution), as described in this Privacy Policy.

10.2 Communications Preferences

• Email marketing: You can unsubscribe from promotional emails we send by following the instructions in those emails (usually via an “unsubscribe” link), or by contacting us at support@algaecal.com. Even if you opt out of promotional messages, we may still send you non-marketing communications, such as those about your Account, transactions, or important updates to the Community or this Privacy Policy.

• In-app and push notifications: With your consent, we may send you in-app notifications or push notifications to your mobile device. You can disable push notifications at any time by changing the notification settings on your device or, where available, within the Community settings.

10.3 Cookies and Similar Technologies

Most web browsers are set to accept cookies by default. You can usually choose to remove or reject browser cookies through your browser settings. You may also be able to configure your device or browser to block certain other tracking technologies. If you remove or reject cookies, this could affect the availability and functionality of some features of the Community.

For more information about the cookies and similar technologies used in the Community and how to control them, please see Section 2.2.4 (Cookies and Similar Technologies)

10.4 Location Information

If you initially consent to our collection of location information (for example, via your device settings), you can stop the collection of more precise location information at any time by changing the settings on your device. If you do so, some features of the Community may not function properly.

10.5 Access, Deletion, and Correction Requests (Available to All Users)

In addition to any rights you may have under local law, we provide the following rights to all Community users, regardless of where they live:

• Right to Access/Know: You may request that we confirm whether we process personal information about you and provide you with a copy of certain information we hold about you, as well as additional details about how we use and disclose it.

• Right to Deletion: You may request that we delete personal information we have collected from you, subject to applicable legal exceptions (for example, where we need the information to complete a transaction you requested, detect or prevent fraud or security incidents, comply with law, or maintain certain business records).

• Right to Correction: You may request that we correct inaccurate personal information that we maintain about you.

California residents and certain other users may have additional rights under applicable law, as described in Section 11 (Additional Information for California Residents) or other region-specific notices where applicable. 

To exercise any of these rights, please contact us at support@algaecal.com with a clear description of your request. We may need to verify your identity before we can process your request, which may include matching information you provide with information we already maintain. Where we deny your request, we will explain the reasons, unless we are legally prevented from doing so.

If we deny your request, you may contact us at support@algaecal.com and request that we review the decision; where required by law, we will provide you with information on how to submit an appeal.

  1. Additional Information for California Residents

If you are a resident of California, you may have additional rights with respect to your personal information under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”). This Section 11 describes those rights and explains how you may exercise them. To the extent this Section 11 conflicts with other parts of this Privacy Policy, this Section 11 governs for California residents.

11.1 Categories of Personal Information We Collect

In the 12 months preceding the “Last Updated” date of this Privacy Policy, we have collected the following categories of personal information (as defined by the CCPA) about individuals who use the Community:

We collect these categories of personal information from the sources described in Section 2 of this Privacy Policy and use them for the business and commercial purposes described in Section 3.

11.2 Disclosure of Personal Information

We may disclose the categories of personal information listed above with the types of third parties described in Section 5 of this Privacy Policy, including:

We do not “sell” personal information and we do not “share” personal information for cross-context behavioral advertising, as those terms are defined in the CCPA. We also do not sell or share the personal information of consumers we know are under 16 years of age.

11.3 Your Privacy Rights Under the CCPA

Subject to certain exceptions and limitations, California residents have the following rights under the CCPA:

Because we do not sell or share personal information for cross-context behavioral advertising, we do not offer a right to opt out of sale or sharing.

11.4 How to Exercise Your CCPA Rights

If you are a California resident, you may submit requests to know/access, delete, or correct your personal information in the following ways:

We may need to verify your identity before processing your request. The verification process may vary depending on the type of request and the sensitivity of the personal information involved, but we will generally seek to match the identifying information you provide with information we already maintain about you. If we cannot verify your identity to a reasonable degree of certainty, we may not be able to fulfill your request, and we will let you know.

You may also designate an authorized agent to submit a request on your behalf, where permitted by law. We will require the authorized agent to provide proof of their authorization and may also require you to verify your own identity directly with us.

We will respond to your request within the time periods required by the CCPA (typically within 45 days, with the possibility of a 45-day extension where reasonably necessary), and we will inform you if we need additional time and why.

11.5 Questions

If you are a California resident and have questions about this Section 11 or how to exercise your CCPA rights, please contact us at support@algaecal.com.