PRIVACY POLICY

Last Updated: September 25, 2026

On Belay Holdings, Inc. (“On Belay,” “our,” “us,” or “we”) is committed to protecting the privacy and security of the information of our website visitors (“you”).  We want you to understand how we collect and use information from our website (the “Site”) and our related services, (together with the Site, the “Services”) so you can interact with us with confidence.  By using the Services, you accept and agree to the practices this Privacy Policy describes.  If you do not agree to any of the terms in this Privacy Policy, you should not use the Services. 

Notice at Collection for California Consumers: If you are located in California, please review our Privacy Notice for California Residents appended as a supplement to this Policy.

What Information Do We Collect? 

When you use our Services, we may collect, store, and process various kinds of data, including Personal Information about you.  “Personal Information” refers to information about you that can be used to identify you, such as your name, address, telephone number, e-mail address, credit card information, or transaction information.

Specifically, we may collect, store, or process information when you: 

• Submit a form on the Site;
• Contact us with inquiries, including via email;
• Subscribe to our newsletter or otherwise sign up to receive communications; or
• Voluntarily provide information.
  
  

We may also collect details of your visit to our Site and the pages you access, including, but not limited to, traffic data, location data, weblogs and other communication data, including your IP address, browser type, the date and time you accessed or left the Sites, and which pages you viewed.  Some parts of our Site uses cookies and other technologies to collect this information about your general internet usage.  See the section below called “How We Use Tracking Technologies” to learn more.

Why We Collect Information

We use your information for the following purposes:

• To present our Services to you;
• To personalize your experience; 
• To provide you with information, products or services, including customer service that you request from us;
• To fulfill any other purpose for which you provide it;
• To notify you about changes to our products or Services we offer;
• To allow you to participate in any interactive features on our Services;
• In any other way we may describe when you provide the information;
• To improve our Services; 
• To perform analytics to learn about the behavior of our Service users;
• To send periodic emails relating to your order, occasional company news, updates, or related product information;
• With your permission, we may send you marketing emails about our Services, new products and other updates;
• For any other purpose with your consent;
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Site visitors is among the assets transferred;

How We Use Tracking Technologies 

We use cookies (small text files stored in your browser) and other techniques such as web beacons (small, clear picture files used to follow your online activities) (“Tracking Technologies”). Tracking Technologies collect information that tells us how you use our Site, web-related products and Services. The use of Tracking Technologies does not give us access to the rest of your computer.

This, in turn, helps us make our Services relevant to your interests and needs.  We use a number of different Tracking Technologies, including functional, performance, advertising, and social media or content cookies.  The types of Tracking Technologies we used are described as follows:

• Performance and Functionality Cookies. These cookies are used to enhance the performance and functionality of our Sites but are nonessential to their use. However, without these cookies, certain functionality (like videos) may become unavailable.
• Analytics and Customization Cookies. These cookies collect information that can help us understand how our Sites are being used. This information can also be used to measure effectiveness in our marketing campaigns or to curate a personalized Site experience for you.
• Advertising Cookies. These cookies are used to make advertising messages more relevant to you. They prevent the same ad from continuously reappearing, ensure that ads are properly displayed for advertisers, and in some cases select advertisements that are based on your interests.
• Social Networking Cookies: These cookies enable you to share our Sites’ content through third-party social networks and other websites. These cookies may also be used for advertising purposes.

Please note that you can opt out of Analytics and Customization, Advertising, and Social Networking cookies at any time by clicking “Decline” on our cookie banner or by clicking on the Do Not Sell or Share My Personal Information link at the bottom of any of our Sites.

Our Sites’ cookie management tool is configured to honor opt-out preference signals sent by Global Privacy Control (“GPC”) within your browser. Please note that due to technical limitations, the GPC signal may only be recognized within your current browser. For more information on GPC, please visit https://globalprivacycontrol.org. 

Some internet browsers have “Do Not Track” or “DNT” features which, when turned on, send a signal to a website that the individual visiting the website does not wish to be tracked. Such browser features and industry standards are not uniform, so our Sites do not respond to DNT signals, but you can control your cookie preferences in the settings of your Internet browser. Please note that if you block or reject cookies on our Sites, some functionality of the Sites may be limited.

Your Communication Choices

You may opt out of receiving email marketing communications from us by clicking the unsubscribe link included in our emails or by contacting us. Please note that we may still send you transactional and administrative emails even if you opt out of marketing communications.

On Belay operates an AI-powered chatbot text messaging program through which your primary care provider may partner with On Belay’s team of live Nurse Care Managers to provide follow-up care and coordination. While the text messages you receive are AI-powered, you may request to speak with a live Nurse Care Manager at any time.  

You may opt-out of receiving automated text messages from us by replying “STOP” to the message or contacting us. You may also text HELP for more information.  Message and data rates may apply, and message frequency varies. Please note that we may still send you transactional and administrative text messages even if you opt out of marketing communications. 

Based on where you live, you may have additional rights regarding your Personal Information (see further information in the Your Privacy Rights section below).

Your Privacy Rights

Depending on your state of residency, you may have certain privacy rights, subject to certain exceptions, as follows:

• Right to Access. You may have the right to request that we disclose what Personal Information we collect, use, disclose, and sell about you.

• Right to Correction. You may have the right to request correction of Personal Information that we maintain about you if you find that the Personal Information is inaccurate.

• Right to Deletion. You may have the right to request that we delete Personal Information that we have collected from you.
• Data Portability. You may have the right to request a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format.
• Right to Withdraw Consent. You may have the right to withdraw your consent to the processing of your Personal Information.
• Right to Limit Use and Disclosure of Sensitive Personal Information. You may have the right to limit the processing of your sensitive Personal Information.
• Right to Opt-Out. You may have the right to opt out of certain processing of your personal information, including: (i) targeted advertising, which may include “sharing” personal information for cross-context behavioral advertising as those terms are used under California law; or (ii) the “sale” of your personal information. You can opt out of the activities described in (i) and (ii) by adjusting your cookie settings to reject applicable analytics and advertising cookies; these choices may be specific to the browser, device, and website on which you make them. Additionally, if you visit our website with a recognized opt-out preference signal enabled, such as GPC, and we are required by law to honor that signal, we will treat the signal as a request to opt out of the “sale” of personal information and targeted advertising, including “sharing” for cross-context behavioral advertising where applicable. Please note that your request may apply only to the browser or device from which you submit it.
• Right to a List of Third Parties. You may have the right to obtain a list of third parties to which we have disclosed Personal Information. Please contact us for information on third parties to whom we have sold or may sell your personal information.
• Right to Appeal. In some circumstances, we may deny your request to exercise one of your privacy rights described in this Privacy Policy (e.g., if we cannot verify your identity). In such a case, we will communicate this in writing and explain the reasons for the denial. You may appeal our decision by responding to our denial email or submitting a request to privacy@obhs.com. We will notify you of our decision regarding your appeal in writing via an email from privacy@obhs.com within 45 days of receipt. If we deny your appeal, you may have the right to contact your state Attorney General to file a complaint.

We do not engage in profiling activities that further automated decisions producing legal or similarly significant effects; however, to the extent your Personal Information is ever used in that way, you additionally may have the right to opt-out of profiling activity that furthers an automated decision producing legal or similarly significant effects, and the right to information on profiling if any profiling is done for the purposes of an automated decision that produces legal or similarly significant effects, including to question the results of profiling, to be informed of the reason profiling resulted in a particular decision, to review your Personal Information that was processed for the purposes of profiling, to correct incorrect Personal Information processed for profiling, and to have the profiling decision reevaluated accordingly.

Additionally, we do not use automated decision-making technology (ADMT) to make significant decisions about you. However, to the extent your Personal Information is ever used in that way, you may have the right to opt out of our use of ADMT for a significant decision concerning you (such as decisions regarding financial or lending services, housing, education, employment or compensation, or healthcare or essential goods or services), and the right to receive a pre-use notice and to access information about how the ADMT was used with respect to you, including the output of the ADMT and how it was used to make the decision.

Requests to exercise these rights may be made using the contact information listed at the end of this Privacy Policy, or as otherwise described in this section. Only you or, as permitted by law, a person that you authorize to act on your behalf, may make a request related to your Personal Information. For certain requests, we must verify your request before we can fulfill it. Verifying your request will require you to provide sufficient information for us to reasonably confirm that you are the person about whom we collected Personal Information or that the requestor is authorized to act on your behalf. We will not discriminate against you for exercising your privacy rights.

 

How Do We Share Your Personal Information? 

We may disclose your Personal Information as follows:

• With affiliates, contractors, service providers, and other third parties we use to support our business;
• To fulfil the purpose for which you provide it;
• For any other purpose disclosed by us when you provide the information;
• With your consent;
• With affiliates if you opt-in to receiving communications from affiliates;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about the Website users is among the assets transferred; 
• To enforce any agreement, including any applicable terms of service;
• To establish or exercise our right to defend against legal claims; 
• To law enforcement and other government authorities such as legislatures, courts, agencies and litigants if we reasonably believe that such action is necessary to: (a) comply with the law and the reasonable requests of governmental authorities; (b) comply with legal process; (c) respond to requests from public or government authorities, including public or government authorities outside your country of residence; (d) protect the security or integrity of the Services’ information systems; and/or (e) exercise or protect our rights, privacy, safety or those of affiliates, clients, you or others; and
• If we reasonably believe disclosure is necessary or appropriate to protect the rights, property, or safety of the On Belay or others. 

On Belay does not sell Personal Information for monetary consideration, though certain of our digital analytics and advertising activities may constitute a “sale” or “sharing” of Personal Information as those terms are defined under applicable privacy laws (see further discussion in the Your Privacy Rights section above and the Privacy Notice for California Residents below).

On Belay does not collect, use, or sell Personal Information for the purpose of training large language models.

How Do We Protect Your Information?

To protect your Personal Information, we take commercially reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered, or destroyed. However, no data protection procedures are entirely infallible. As a result, while we strive to protect your Personal Information, we cannot guarantee that it will be 100% secure. Your transmission of your information to our Platform thus is done entirely at your own risk.

Retention of Personal Information

We retain the Personal Information we collect for the time period required to fulfill the legitimate business purposes for which it was collected and to engage in the use and disclosure practices outlined in this Privacy Policy, unless a different retention period is required by applicable law, or otherwise to fulfill a legal obligation or protect our legal rights. We may also maintain for an indefinite period of time certain Personal Information that has been de-identified. This information is no longer considered Personal Information, and we commit not to attempt to reidentify such information.

 

Third-Party Websites and Social Media

Our Site may contain links to other sites, including those of third parties or partners.  While we seek to link only to sites that share our high standards and respect for privacy, we cannot be responsible for the privacy practices other websites use.  By accessing other third party websites or applications through our Site, you are consenting to the terms and privacy policies of those websites.  It is possible that other parties may collect personally identifiable information about your online activities over time and across different web sites when you use our Site. 

Our Site may include social media features, such as Facebook “Likes” or “Recommend” buttons, Pinterest, Twitter, Tumblr, and YouTube.  These social media features may require cookies to be set to function properly.  These features may also collect Personal Information such as your IP address.  These features are governed by the Privacy Policy of the social media platform.  Please review the Privacy Policy of the social media platforms to learn how they protect your information. 

International Visitors 

Our Site is hosted and operated in the United States (“US”).  By using this Site, you are consenting to the transfer of your Personal Information to the US.  If you are accessing our Site from outside the US, please be advised that US law may not offer the same privacy protections as the law of your jurisdiction.  

Users Only of Legal Age of Majority

Our Services are not intended for children under 18 years of age. We do not knowingly collect Personal Information from children under 18. If you are under 18, do not use or provide any information on this Services or on or through any of its features/register on the Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18 without verifiable parental consent, please contact us at marketing@obhs.com.

Contacting Us

We welcome any questions, comments, or complaints you may have regarding this Privacy Policy.  Please do not hesitate to contact us by email at marketing@obhs.com or writing to us: 

privacy@obhs.com

or

On Belay Health Solutions

100 Summer St. Boston, MA

SUPPLEMENTAL NOTICE

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Effective Date: September 25, 2026

This Privacy Notice for California Residents supplements the information contained in the On Belay Privacy Policy above (“Privacy Policy”), and applies only to California residents (“you,” “your,” or “consumer”). This section provides additional disclosures for residents of California, as required by the California Consumer Privacy Act, as amended (the “CCPA”). Please remember that the information we collect varies based on our relationship with you and note that certain Personal Information or activities may not be reflected in this section because they are exempt from the CCPA.

CCPA Categories of Personal Information We Collect, How and Why We Collect Them 

We collect the following categories of Personal Information about California consumers. This information may be, or may have been, collected directly from you, automatically when you use our Services, from third parties, or from publicly available sources.

• Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, Social Security number, or other similar identifiers.
• Personal Information described in Cal. Civ. Code § 1798.80(e), including name, signature, address, telephone number, education, employment, employment history, bank account information, or other financial information, or health insurance information.
• Characteristics of protected classifications under California or federal law, including age and date of birth, gender, medical condition, or disability. Additional protected classification characteristics may also be collected from job applicants such as veteran status, race or ethnicity.
• Commercial information, including records of samples, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Internet or other electronic network activity information, including Internet or other similar activity, browsing history, search history, information about a consumer’s interaction with our Sites.
• Geolocation data, including location data inferred from your device IP address.
• Audio, electronic, visual, thermal, olfactory, or similar information, including audio recordings of customer calls and webinars.
• Professional or employment-related information, including business contact information as well as information collected from job applicants during the hiring process including resumes, cover letters, education history, employment history, and background check information.
• Non-public education information, including transcripts or other information which may be collected during the hiring process.
• Inferences used to create a profile reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• Sensitive Personal Information, including information collected and analyzed concerning a consumer’s health; account log-credentials; precise geolocation; and citizenship or immigration status, race, and ethnicity (job applicant context only). To the extent we collect sensitive personal information, we may use it (namely, information concerning a consumer’s health) for purposes of inferring characteristics about a consumer.

We use the Personal Information we collect for the purposes described in the Information Use section of our Privacy Policy.

CCPA Categories of Personal Information Disclosed 

We disclose all of the above categories of Personal Information to service providers or to other third parties as described in the Information Disclosure section above. 

CCPA Categories of Personal Information Sold or Shared

Under the CCPA, a “sale” of Personal Information includes disclosures of Personal Information to third parties who may use the information for their own purposes, such as analytics and advertising partners. Similarly, “sharing” Personal Information refers to disclosing Personal Information to third parties for cross-context behavioral advertising. Per these definitions, we may sell and/or share the following categories of Personal Information to third party analytics and advertising partners:

• Identifiers
• Personal Information described in Cal. Civ. Code § 1798.80(e)
• Commercial information
• Internet or other electronic network activity information
• Geolocation data
• Inferences
• Sensitive Personal Information (e.g., precise geolocation) 

California residents should refer to the Your Privacy Rights section of our Privacy Policy for information regarding their privacy rights under the CCPA and how to exercise them.

You have the right to direct us to not share, disclose, or sell your Personal Information. To exercise this right, you or your authorized representative may submit a request by clicking on the Do Not Sell or Share My Personal Information link on the homepage of our Sites. 

California’s “Shine the Light” law (Civil Code § 1798.83) permits users of our Sites that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes.

Notice of Financial Incentive

We may offer financial incentives permitted by the CCPA, such as discounts, rewards, or other benefits, in exchange for the collection or retention of your Personal Information. Any financial incentive we offer will reasonably relate to the value of your Personal Information, and we will provide you with written terms describing the program’s material aspects before you opt in. Participation in any financial incentive program requires your prior opt-in consent, which you may revoke at any time by contacting us as described in the Contact Us section.

Contact Us

If you have any questions, comments, or concerns about this Privacy Notice for California Residents or our information protection practices, please contact us as follows:

privacy@obhs.com

or

On Belay Health Solutions

100 Summer St. Boston, MA

Changes to This Privacy Policy and Supplemental Notice

On Belay reserves the right to modify, add or remove portions of this Privacy Policy or Supplemental Notice at its discretion and without prior notification.  Any changes to this Privacy Policy or Supplemental Notice will be posted on our Site.  Please check back periodically, and especially before you provide any Personal Information to us.