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Atlas Privacy Policy

Effective Date: August 26, 2026

OCCAM BCI, Inc. (“Atlas,” “we,” or “us”) provides our Atlas wearable device (the “Device”) through our Atlas mobile application (the “App”) that allows users to track and analyze biometric data and other personal information to provide personalized insights into health and cognitive function (collectively, the “Services”). This Privacy Policy describes how Atlas collects, uses, discloses and otherwise processes the personal information described below and the choices individuals have regarding their personal information.

Scope

This Privacy Policy applies to the personal information that we collect and process through the Device and App and otherwise related to the Services and our website, https://atlasmankind.com/ (the “Site”), including personal information related to:

  • Users of the Services (each a “User”) and individuals who visit our Site or interact with our online content
  • Purchases, orders, subscriptions, and related transactions, including when you pre-order or purchase a Device or related products, submit a return, or subscribe to the Services
  • User insights (“Insights”) that we derive or generate about Users through the Services
  • Our marketing and advertising campaigns
  • Surveys that we conduct, promotions that we offer, and events that sponsor
  • Any communications or interactions with us related to our Site or Services

Additional Privacy Information and Consents. We may provide additional or supplemental privacy notices related to certain services or features that we provide or obtain consent to collect and process certain personal information. For example, some of the personal information that we collect and process through the Services is considered sensitive personal information under certain state privacy laws—so, when you activate a Device or register for the Services, you will be asked to provide your consent. Generally, these specific notices or consents apply in addition to and supplement the information that we provide in this Privacy Policy.

Your use of our Site and Services (including any dispute over privacy) is subject to the terms of our Terms of Service and our Terms of Sale (collectively, the “Terms”), including their applicable limitations and restrictions on liability and damages.

Personal Information We Collect

The personal information we collect from you depends upon how you use our Services or otherwise interact or engage with us, but generally includes the information described below.

Your Atlas Data. To provide the Services to you, we collect and process personal information about you from different sources, including information you provide directly, information we receive from third-party sources (e.g., integrated third-party apps), information we automatically collect about through the Services, and Insights that we infer or derive (collectively, “Your Atlas Data”), including:

  • Device data: Atlas directly measures four physical signals through your Device: electrical brain activity through EEG, head movement, skin conductance (how easily your skin passes electricity) and voice-induced vibrations of your skull (speaking activity and voice patterns) (collectively “Device Data”).
  • App data and integrations: you can integrate third party mobile apps (e.g., Apple Health) and wearables (e.g., Apple Watch, Oura and Whoop) through the App (collectively, “Third-Party Accounts”) in order and sync health, wellness and fitness data from these Third-Pary Accounts with the Services.
  • Personal characteristics: information about you and your personal characteristics as part of the Services to help us provide tailored and personalized Insights to Users, including (i) demographic information, such as age, sex at birth, work, and education; and (ii) your activities, interests and habits, including physical activities (e.g., running, mobility training, lifting weights, etc.), meditation, journaling, breathing exercises, dieting or fasting, heat or cold exposure, and other activities, other information about your activities, traits, interests, habits or well-being.
  • Usage and performance data: such as how often you use the Services (including the Device or App), the screens you viewed, actions you take, features you use, access times, duration of access, and whether you have viewed notices, alerts and messages from us within the App, as well as Device health/performance information (e.g., battery level).
  • Your Insights: we infer and derive Insights for you based on Your Atlas Data, including pattern recognition and identification, personalized recommendations, metrics, changes in Presence, Stress and Energy levels, and trends and other metrics.
  • Video and images: including images of the region behind your ear to determine whether the Device is properly positioned.

Account Information and Transactions. When you create an account with us, we collect personal information from you, including your name, email address, billing and shipping information, payment details, and log-in information (e.g., the username and password you set for your account), and other information submitted to us through your account. We also maintain records of your purchases (and returns), subscription payments, warranty claims and other transactional information.

Site Data and Online Interactions. We automatically collect personal information related to your use of our Site and your interactions with us and our online content, including:

  • Device and browsing information: We use cookies, log files, pixel tags and other tracking technologies to automatically collect information when users access or use our Sites, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. For more information, see Cookie and Tracking Preferences for our Site, below.
  • Activities and usage: We also collect activity and interaction information related to when you use the Site or view or interact with our online content (e.g., HTML emails that we send to), such as information about the links clicked, searches, features used, when you opened or forwarded our emails, and date/time stamps.

Other Information You Provide to Us. We also collect information that you provide to us, including when you contact us with questions, provide feedback, or correspond with us related to our Services or Site, as well as when you participate in our surveys, promotions, and events. For example, when you fill out a ‘Contact Us’ form, signup for our mailing lists, or otherwise request information from us, we collect and maintain records of your requests. If you participate in sweepstakes, contests or other promotions that we offer, we will collect your name, age, email address, and other registration information related to the promotions. Similarly, if you register for or attend an event that we host or sponsor, we may collect information related to your registration and participation.

Aggregate and Non-identifiable Information

We may also create aggregated, de-identified or other anonymous data from personal information we collect related to the Services and otherwise. We may use this data and share it with third parties for our lawful business purposes, including to analyze and improve the Services, develop new features and services (including model training), and promote our business. We may also use and disclose aggregate, anonymous, and other non-identifiable data related to our business and the Services for quality control, analytics, research, development and other purposes. Where we use, disclose or process de-identified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) we will maintain and use the information in deidentified form and not to attempt to reidentify the information, except in order to determine whether our deidentification processes are reasonable and adequate or where required or permitted by applicable privacy laws.

Use of Personal Information

We use personal information for the following purposes:

  • Providing our Services: to provide, operate, maintain, secure and improve our Services, including to:
    • Create, maintain, and administer your account, membership and Services
    • Provide Insights to Users
    • Provide the other features of the Services you use, including to allow you to use the Device and App to analyze your Device Data
    • Communicate with you about the Services, including by sending you announcements, updates, security alerts, and support and administrative messages
    • Tailor content we may send or display to you within the Services, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
    • Respond to your requests, questions, and feedback and provide technical and customer service and support
  • Developing and improving the Services: including to monitor use of our Services, analyze the functioning of our Services, improve the Services, and develop new products and services, including to train and improve AI models, and study use of our Services.
  • Operating and maintaining our Site: including to provide and operate our Site, communicate with you about your use of the Site and our Services, respond to your inquiries, fulfill your orders and requests, process your payments, and for similar service and support purposes.
  • Analytics and improvement: to better understand how users access and use the Site and our Services, to evaluate and improve our Site and business operations, to develop new services and features, and for internal quality control and training purposes.
  • Marketing and advertising: including to send you information about our Site and Services (such as offers, promotions, newsletters and other marketing content), and to manage and improve our advertising campaigns so that we can better reach people with relevant content and ads on third party sites and services.
  • Compliance and protection: including to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; to protect our, your or others’ rights (including in response to litigation or other legal claims), privacy, safety, or property (including by making and defending legal claims); to monitor the safety and integrity of content on the Services; to audit our internal processes for compliance with legal and contractual requirements and internal policies; and to prevent, detect, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks, identity theft, and illicit uses of the Services.

Disclosures of Personal Information

We may disclose the personal information that we collect for the purposes described above and as otherwise directed or authorized by you, including to:

  • Vendors and service providers: including companies and individuals that provide services on our behalf or help us operate our Services, Site or our business (such as hosting, information technology, customer support, payment processing, email delivery, marketing and targeted advertising, and website analytics services). We also rely on third-party AI service providers to assist us with providing the Services.
  • Affiliated companies: including our affiliates and subsidiaries who will use and disclose this personal information in accordance with the principles of this Privacy Policy.
  • Professional advisors: such as lawyers, auditors, bankers, and insurers, brokers and consultants, where necessary in the course of their professional services to us.
  • Third party platforms, providers and networks: including platforms and providers that we use to provide or make available certain features or portions of the Services, as well as third party marketing, analytics, and advertising companies that we work with to deliver and measure targeted advertising and promote our Services. However, we do not share Your Atlas Data with these third parties for marketing and advertising purposes.

In addition, we may disclose personal information where we believe reasonable and appropriate, we may disclose or make available relevant personal information:

  • In support of business transfers: including if we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. We may also share certain personal information as necessary prior to the completion of such a transfer, such as to lenders, auditors, and third-party advisors, including attorneys and consultants, as part of due diligence or as necessary to plan for the transfer.
  • Compliance and legal obligations: to comply with our legal and compliance obligations and to respond to legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. This may include regulators, government entities, and law enforcement as required by law or legal process. In addition, it may include certain disclosures that we are required to make under applicable laws, such as the names of sweepstakes and contest winners.
  • Security and protection of rights: we believe doing so is necessary to protect the Services, our rights and property, or the rights, property and safety of others. For example, we may disclose personal information in order to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety or legal rights of any person or third party, or (iii) enforce, and detect, investigate and take action in response to violations of, our Terms of Service. We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.

Your Choices

Update Your Account. You may be able to update information within your account through the account settings in the App.

Delete Your Account. You may request that we delete your account (including Your Atlas Data) by emailing us at support@atlasmankind.com. Please note that the deletion of your account (and the associated Your Atlas Data) is permanent and cannot be reversed; once deleted, your account and Your Atlas Data will no longer be accessible or available, and you will not be able to reactivate your account or restore Your Atlas Data.

Unsubscribe from Marketing. You can opt out of receiving marketing emails at any time by clicking “unsubscribe” within the email footer.

Cookie and Tracking Preferences for our Site. You can opt out of third-party tracking cookies on our Site. To do so, in the cookie banner for our Site, click the ‘DENY’ button to opt-out of third-party tracking cookies or click the “CUSTOMIZE” link to review and adjust your preferences for these cookies on our Site.

Depending upon where you reside, you may have additional privacy rights (such as access, deletion and correction) under some state privacy laws, subject to certain exemptions. If you would like to request to exercise your privacy rights or have questions regarding the choices outlined above, you can email us at support@atlasmankind.com.

Third-Party Links and Services

Our Services may contain links to other websites, mobile applications, and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Retention

We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is longer.

Children

Our Services are not intended for people under the age of 18. If we learn that we have collected personal information from a person under 18, we will take steps to promptly delete that data in accordance with applicable legal requirements and our compliance obligations.

Data Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information. You use the Services at your own risk.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Services or as otherwise required by applicable laws.

Contact Us

Please direct any questions or comments about this Privacy Policy to support@atlasmankind.com.