PRIVACY POLICY

TheraHOME App

Last updated: 01/09/2026

1. Introduction

This Policy applies to the TheraHOME application ("the App"), developed and operated by H-COMMERCE GLOBAL COMPANY LIMITED ("we", "us"), and explains how we collect, use, share and protect your personal data when you use the App. By creating an account or using the App, you agree to the contents of this Policy.

TheraHOME is a home fitness & wellness app, not a medical app. Because the App processes some data you provide yourself about how your body feels (discomfort levels, training progress), we apply stronger-than-usual safeguards to this data, as described throughout this Policy.

2. Data we collect

2.1 Data you provide directly

• Account information: full name, phone number, email, password (encrypted), profile photo.
• Training profile: the discomfort level you self-report each day, the body areas/training programs you take part in, and exercise completion status.
• Content you post: posts, comments and photos in the Community section, and messages sent to the AI Assistant or the support team.
• Order information: products purchased in the Store, delivery address, order history. Card/payment details are processed directly by our payment partners; we do not store full card numbers.

2.2 Data collected automatically

• Usage data: the features you access, time spent, and consecutive days completing a program.
• Device data and technical logs: device type, operating system, app version, device identifiers, and error logs used for troubleshooting.

2.3 Data from third parties

If you sign in with an Apple/Google account, we receive some basic information (name, email) within the scope you allow at the time of sign-in.

3. How we use your data

• To create and manage your account and authenticate sign-in.
• To build and personalize your training roadmap and the charts tracking discomfort levels and progress.
• To process orders, deliveries and customer care related to the Store.
• To operate the Community section and display content posted by you and other users.
• To operate the AI Assistant that answers questions about your training program (see Section 5.1 for details).
• To send workout reminders, order updates and program information (you can turn these off in Settings).
• To analyze and improve the App and to detect and prevent fraud and technical errors.
• To comply with legal obligations upon lawful requests from competent state authorities.

4. Legal basis and consent

Under Vietnam's Decree 13/2023/ND-CP on personal data protection, the processing of your personal data is based on your consent, except in cases where the law permits processing without consent (for example to perform contractual obligations, to protect life or public health, or at the request of competent authorities). You may withdraw your consent at any time; withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

5. Sharing data with third parties

We do not sell your personal data. We only share data in the following cases, to the minimum extent necessary:

• Payment partners and shipping providers: to process orders you place in the Store.
• Cloud hosting and analytics providers: to operate and improve the App, under data-protection agreements.
• The AI-model provider behind the AI Assistant: see Section 5.1 below.
• Our customer-support team: when you actively message us or request support.
• Competent state authorities: upon lawful requests under applicable law.

5.1 AI Assistant — third-party AI service

The AI Assistant feature uses a third-party language-model service (currently: Groq, Inc., with servers located in the United States) to generate responses. Specifically:

• Data sent: only the message content you type in the conversation with the AI Assistant (together with the most recent conversation context). We do not send your name, email, phone number, order information or training data to the AI provider.
• When it is sent: data is only sent when you actively send a message in the AI Assistant, and only after you have read and agreed to the notice shown the first time you open this feature.
• Purpose: solely to generate responses for you; not used for advertising; not sold to third parties.
• Recommendation: do not share sensitive information (identity documents, financial details, detailed medical conditions) in the conversation. AI Assistant responses are for training reference only, not medical advice.

Your training data and body-feeling data are not shared with any third party beyond providing the service to you, unless you explicitly consent to another purpose.

6. Public content in the Community section

Posts, comments and achievement badges you share in the Community section may be publicly visible to other users in the App. Please consider carefully before sharing sensitive information. You can delete content you have posted at any time.

7. Data retention

We retain personal data while your account remains active and for as long as necessary for the purposes for which it was collected, to comply with legal obligations (for example accounting records and invoices), or to resolve disputes. After you request account deletion, personal data is deleted or anonymized within a reasonable time, except data the law requires us to retain longer.

8. Your rights

Under personal-data-protection law, you have the following rights over your personal data:

• The right to be informed about the processing of your personal data.
• The right to access and review the personal data you have provided.
• The right to request correction of inaccurate data.
• The right to withdraw consent.
• The right to request deletion of your personal data.
• The right to request restriction of, or to object to, data processing.
• The right to complain, report or initiate legal proceedings as provided by law.

8.1 How to delete your account directly in the App

You can delete your account yourself directly in the App at: Profile → Delete account (the button at the bottom of the Profile screen), with no need to contact support. Once you confirm deletion, all personal data linked to the account is deleted or anonymized as described in Section 7. If you run into any difficulty, you can contact support@therahomeai.com.

9. Data security

We apply appropriate technical and organizational measures to protect personal data from unauthorized access, use or disclosure. Details of these measures are set out in our separate Information Security Policy.

10. Children

The App is not directed at users under 16. If you are under 16, please only use the App with the consent and supervision of a parent or legal guardian. If we discover that we have collected a child's personal data without valid consent, we will delete that data.

11. Cross-border data transfers

Where our hosting servers or service providers are located outside Vietnam, transfers of personal data abroad are carried out in accordance with Decree 13/2023/ND-CP, including preparing and maintaining a cross-border data-transfer impact assessment where required by law.

12. Changes to this Policy

We may update this Policy from time to time. When there are significant changes, we will notify you in the App or by email before the changes take effect.

13. Contact

If you have questions about this Policy or wish to exercise your rights over your personal data, please contact:

• H-COMMERCE GLOBAL COMPANY LIMITED
• Address: 11th Floor, RoxCenter Building, 136 Ho Tung Mau, Phu Dien, Hanoi, Vietnam
• Personal-data-protection email: support@therahomeai.com