3. How We Use Your Information

We use collected information to:

• Operate, maintain, and improve the Service.

• Train and improve AI models and related wellness features.

  • Thoughtful uses Inputs and Outputs to improve its AI models. This use is a core part of the Service, and by using Thoughtful you agree to this processing. If you do not agree, do not use Thoughtful.

• Monitor usage, ensure security, and detect misuse.

• Personalize recommendations and user experiences.

• Communicate with you about updates, features, and policy changes.

• Comply with legal, contractual, and regulatory obligations.

• Conduct de-identified or aggregated analytics, research, and product development. We will not attempt to re-identify such de-identified data.

Use of Sensitive Personal Information (SPI)

“Sensitive Personal Information” under California and other state laws may include things like health-related reflections, racial or ethnic origin, religious or philosophical beliefs, sexual orientation, union membership, government ID numbers, or precise location.

• Not Required: You are not required to provide SPI to use Thoughtful. We ask that you avoid submitting such information unless you are comfortable doing so.

• Default Handling: If you provide SPI while using the Service, we will process it only as necessary to deliver the Service to you (for example, to generate responses back to you).

• Optional Consent for Model Training: We will only use SPI for AI model training or product improvement if you have given us separate, explicit consent through a clear opt-in prompt. If you do not consent, your SPI will not be used for model training.

• Withdrawal of Consent: You may withdraw your consent at any time by emailing careteam@thoughtful.com or updating your privacy settings. Withdrawal will apply going forward and will not affect models already trained.

4. Sharing of Information

We may share information:

• With Our Employees, Contractors, Affiliates, and Subsidiaries: Our related entities and subsidiaries in relation to the Services and in accordance with written agreements.

• With Service Providers and Vendors: Service Providers and vendors who help us facilitate the Service including providers such as email providers, cloud service providers, marketing analytics services, lawyers, consultants, and advisors on a need-to-know-basis.

• With Research Partners: Academic or industry collaborators, but only with aggregated or deidentified data.

• During Business Transfers: If Thoughtful is involved in activity related to a merger, sale of company assets, financing, acquisition or a similar corporate event. If any such change of ownership happens, we will ensure it is under terms that preserve the confidentiality of personal information, and we will notify you on our website or by email before any transfer of your personal information.

• For Vital Interests, Legal Compliance, and Public Safety:  If required to protect the vital interests of any person, to exercise or defend our legal rights, or to comply with court orders and similar legal or regulatory obligations, or in response to a valid subpoena, court order, warrant, or similar government order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large. This may include exchanging personal information with other organizations for the purposes of fraud protection. This may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so.

We do not sell your personal information.

5. Privacy Rights (U.S. State Laws)

Depending on your state of residence, you may have rights to:

• Confirm whether we collect, share, or sell your personal information.

• Access the personal information we hold about you.

• Request correction or deletion.

• Opt out of the “sale” or targeted advertising involving your personal information.

• Withdraw consent to the collection or sharing of your personal information.

• Limit the use of sensitive personal information (see Section 3).

• Be free from discrimination for exercising your privacy rights.

• Appeal a decision regarding your privacy request.

To exercise these rights, contact us at careteam@thoughtful.com or through our designated web form.

6. Data Retention and Deletion

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When no longer needed, information is securely deleted or de-identified in accordance with applicable law.

7. Security

We implement technical and organizational safeguards consistent with industry standards and  designed to protect your data including the safeguards listed below. However, no system is 100% secure.

• Encryption in transit and at rest;

• Role-based access controls;

• Secure data centers and monitoring; and

• Employee training on privacy and data handling.

8. Third-Party Services

Thoughtful may integrate or link to third-party services. Those services are governed by their own privacy policies and terms. We are not responsible for their data practices.

9. Children’s Privacy

The Service and its AI chat and wellness tools are intended for adults aged 18 and older. We do not knowingly collect information from children under 18. If you believe we have inadvertently collected such information, please contact us immediately so we can delete it. 

10. Financial Incentives and Loyalty Programs

Thoughtful does not offer a loyalty program or financial incentives in exchange for the collection, retention, or sale of personal information.

We may, from time to time, offer certain customers a Pilot Program to trail our services. The provision of the Pilot Program is not a payment, financial incentive, or price difference in exchange for the collection, retention, sale, or sharing of personal information beyond what is strictly necessary to provide the trial service itself. We collect and use personal information from participants in a Pilot Program as described in Sections 2 and 3 of this Policy.

11. Changes to this Policy

We may update this Privacy Policy from time to time. If changes are material, we will provide notice on our website, through the Service, or by email. The “Last Updated” date indicates the latest version. Continued use of the Service constitutes acceptance of the revised policy.

12. Contact Us

For privacy questions or requests to exercise your privacy rights, contact us at:
careteam@thoughtful.com or submit a message to us via the Thoughtful app. 

REMINDER: Thoughtful IS NOT A HEALTHCARE PROVIDER, MEDICAL DEVICE, OR SUBSTITUTE FOR PROFESSIONAL ADVICE. IF YOU NEED HELP, CONTACT A LICENSED PROFESSIONAL OR EMERGENCY SERVICES.