AVARE INFORMATION TECHNOLOGY

PRIVACY POLICY

Male Vitality Tracking Platform (MVTP)

avareit.com/mvtp

Last updated: March 8, 2026

1. Introduction
This Privacy Policy explains how Avare Biotech Inc. (“Avare Biotech”, “we”, “us”, “our”) collects, uses, shares, and protects your personal information when you visit avareit.com/mvtp or interact with the Male Vitality Tracking Platform (MVTP) and its services.
We collect personal information from residents of any U.S. state, regardless of their location within the United States. We comply with applicable federal law and with the privacy laws of each state whose residents we serve. By using our site, you consent to the practices described in this Policy.

2. Company Information
Avare Information Technology
1007 N Orange St., 4th Floor, Suite 1382
Wilmington, County of New Castle, Delaware 19801, USA
Email: m.mershiev@avareit.com
Website: avareit.com/mvtp

3. Applicable U.S. Privacy Laws
We comply with applicable U.S. federal and state data protection laws. Depending on your state of residence, the following laws may apply to our processing of your personal information:
•       Federal Trade Commission Act (FTC Act), Section 5 — unfair or deceptive practices
•       Children’s Online Privacy Protection Act (COPPA), including FTC amendments effective June 23, 2025
•       CAN-SPAM Act — commercial email communications
•       California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA)
•       Delaware Online Privacy and Protection Act (DOPPA)
•       Virginia Consumer Data Protection Act (VCDPA)
•       Colorado Privacy Act (CPA)
•       Connecticut Data Privacy Act (CTDPA)
•       Texas Data Privacy and Security Act (TDPSA)
•       And other applicable state privacy laws in effect at the time of data collection
Where the laws of multiple states apply, we follow the requirements of each applicable state as they relate to residents of that state.

4. Information We Collect
We may collect the following categories of personal information from U.S. residents:
•       Identity & Contact Data: Full name, phone number, social media handle or portfolio URL
•       Location Data: State and city of residence (as voluntarily provided in application forms)
•       Technical Data: IP address, browser type and version, device type, operating system, referral URL, pages visited
•       Usage Data: Interaction patterns, clickstream data, session duration
•       Cookie & Tracking Data: Session cookies, analytics identifiers, user preferences
•       Submitted Content: Information provided via contact forms, ambassador applications, or direct email
We do not collect sensitive personal information as defined under applicable state law (e.g., Social Security numbers, financial account data, precise geolocation, biometric data, health data, or racial/ethnic origin) through this website.

5. Purposes of Data Collection and Use
We use collected information solely for the following purposes:
•       To operate and improve the MVTP website and services
•       To process and respond to ambassador program applications
•       To send transactional and service-related communications
•       To analyze website traffic and user behavior via analytics tools
•       To fulfill legal obligations and enforce our Terms of Use
•       To prevent fraud, abuse, and security threats
We do not sell, rent, or share your personal information with third parties for their direct marketing purposes.

6. Cookies and Analytics
We use cookies, web beacons, and third-party analytics tools including Google Analytics. These tools collect anonymized usage data to help us understand how visitors interact with our site.
We honor the Global Privacy Control (GPC) opt-out signal. You may also manage cookie preferences through your browser settings. Disabling certain cookies may affect website functionality.

7. Data Sharing and Disclosure
We do not sell your personal information. We may share information only in the following limited circumstances:
•       Service Providers: Hosting, analytics, email delivery, and infrastructure providers who process data on our behalf under data processing agreements
•       Legal Compliance: Government authorities, law enforcement, or courts when legally required or to protect our legal rights
•       Business Transfers: In connection with a merger, acquisition, or sale of assets, subject to confidentiality obligations
All third-party service providers are contractually required to maintain the confidentiality and security of your data and may not use it for their own purposes.

8. Your Rights Under U.S. Privacy Laws
Regardless of the U.S. state in which you reside, you may have the following rights with respect to your personal information. The specific rights available to you depend on the privacy laws of your state:
•       Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you
•       Right to Access: Obtain a copy of your personal data
•       Right to Deletion: Request deletion of personal information we hold about you, subject to certain legal exceptions
•       Right to Correction: Request correction of inaccurate personal information
•       Right to Opt-Out: Opt out of the sale or sharing of your personal information
•       Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights
•       Right to Data Portability: Receive your personal data in a portable format where required by applicable state law
To exercise any of these rights, please contact us at: m.mershiev@avareit.com
We will respond to verifiable requests within the timeframe required by your state’s law (typically 45 days, with a possible 45-day extension upon notice).

9. Children’s Privacy (COPPA Compliance)
The MVTP platform is intended exclusively for adults aged 18 and older. We do not knowingly collect personal information from children under the age of 13.
In compliance with COPPA and the FTC’s updated 2025 Rule (effective June 23, 2025):
•       We do not direct our website or services to children under 13
•       We do not knowingly collect, use, or disclose personal information from children under 13
•       If we learn that we have inadvertently collected personal information from a child under 13, we will delete it promptly
If you believe we have collected information from a child under 13, please contact us immediately at m.mershiev@avareit.com.

10. Data Security
We implement industry-standard security measures to protect your personal information, including:
•       AES-256 encryption for data in transit and at rest
•       Role-based access control
•       Regular security assessments and monitoring
•       Secure hosting infrastructure
In the event of a data breach affecting your rights, we will notify you as required by applicable federal and state law.

11. Data Retention
We retain personal information only for as long as necessary to fulfill the purposes outlined in this Policy or as required by law:
•       Application data: 12 months from submission date
•       Analytics data: 26 months maximum
•       Legal compliance records: as required by applicable law
Upon request, we will delete your personal data subject to any applicable legal retention obligations.

12. Data Storage and Processing Location
Avare Biotech Inc. is incorporated in the State of Delaware. Your data is stored and processed within the United States. If you access our website from outside the U.S., please be aware that your information will be transferred to and processed in the U.S., where privacy laws may differ from those in your country.

13. Do Not Track and Opt-Out Signals
We honor the Global Privacy Control (GPC) opt-out signal as required under applicable state privacy laws. For other Do Not Track (DNT) browser signals, we do not currently alter our data collection practices.

14. Email Communications (CAN-SPAM Compliance)
Any commercial email communications we send comply with the CAN-SPAM Act. Each email will include our physical mailing address, a clear opt-out mechanism, and accurate subject lines.
You may opt out of marketing communications at any time by clicking “Unsubscribe” in any email or by contacting m.mershiev@avareit.com.

15. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The “Last updated” date at the top of this document reflects the most recent revision. Continued use of avareit.com/mvtp after any changes constitutes acceptance of the updated Policy.
For material changes, we will provide prominent notice on the website or by direct communication.

16. Contact Us
For any questions, requests, or concerns regarding this Privacy Policy or your personal data, please contact:

Avare Information Technology
1007 N Orange St., 4th Floor, Suite 1382
Wilmington, DE 19801, USA
Email: m.mershiev@avareit.com
Website: avareit.com/mvtp