Privacy Policy

Last Updated: October 6, 2026

Halo 27, Inc., doing business as Bels (“Bels,” “we,” “us,” or “our”), provides a personal wellness and behavior-change application that helps people make decisions and take action using information they choose to share with Bels.

This Privacy Policy explains how we collect, use, disclose, retain, and protect information when you use our mobile applications, websites, beta products, and related services (collectively, the “Services”).

This Privacy Policy also includes our Consumer Health Data Privacy Policy for purposes of applicable consumer health privacy laws.

Bels is intended for users who are at least 18 years old.

Privacy at a Glance

Bels works by understanding the information you choose to share with it. That can include your conversations, goals, health and wellness information, and information from services you choose to connect.

Here are the important things to know:

The full details are below.

1. Information We Collect

The information we collect depends on how you use Bels and which features and integrations you choose to enable.

Information You Provide to Bels

We may collect information you provide directly to Bels, including:

When you use voice features, audio may be processed to create a transcript. Bels does not retain voice recordings after they are processed for transcription, although audio may be processed temporarily as necessary to provide the feature.

Health and Wellness Information

If you choose to provide it or connect a source that contains it, we may collect information relating to your physical or mental health or wellness.

This may include information about:

Some of this information may be considered sensitive information or “consumer health data” under applicable law.

Information From Services You Connect

At your direction, Bels may receive information from third-party services, devices, and applications you choose to connect.

These may include health and fitness platforms, wearable devices, calendars, productivity tools, and other services.

The information we receive depends on the permissions you grant and the functionality of the connected service.

You control whether to connect optional data sources.

Location Information

If you enable location-related features, we may collect location information to provide contextual features and recommendations.

Unless a particular feature clearly requires otherwise and you expressly enable it, Bels is designed to use approximate rather than precise location information.

Device, Usage, and Technical Information

We may automatically collect information about how you access and use Bels, including:

Information We Derive

We may derive, infer, or generate information based on information you provide to us.

For example, Bels may identify patterns, preferences, routines, likely context, or other information in order to personalize the Services and better respond to you.

Derived or inferred health-related information may itself constitute consumer health data under applicable law.

2. How We Use Information

We use information to provide, operate, maintain, personalize, secure, evaluate, develop, and improve Bels.

This includes using information to:

Bels does not use your personal information or consumer health data to target you with advertising.

3. AI Processing and Human Review

Bels uses artificial-intelligence and machine-learning systems to provide the Services.

Depending on the feature you use, information you provide to Bels, together with relevant context associated with your account, may be processed by AI models operated by Bels or by service providers acting on our behalf.

We may use different models, including third-party and open-source models, and may change the models and technical systems that power Bels over time.

We do not permit external model providers acting on our behalf to use your personal information to train their generalized models.

Human Review

Authorized members of the Bels team and service providers working on our behalf may review product interactions and related technical information where reasonably necessary to operate, test, troubleshoot, secure, evaluate, develop, or improve Bels.

This review may include:

Because conversations with Bels may contain sensitive or health-related information, human reviewers may encounter that information when reviewing a product interaction.

Access is limited to people who have a legitimate need for the information for product, engineering, research, support, safety, or security purposes.

4. Information From Connected Services

Information obtained from a connected service may be subject to additional restrictions imposed by that service or applicable law.

We use information obtained from connected services only as permitted by the applicable provider, your authorization, and applicable law.

For example, information obtained through health and fitness integrations may be subject to restrictions on advertising, disclosure, resale, model development, or other secondary uses.

Where a connected service imposes restrictions that are more protective than the general rights described in this Privacy Policy, we follow those restrictions for information obtained from that service.

Disconnecting a service generally stops future collection from that source. It does not automatically delete information that Bels previously received from that source.

You may delete that information as described in Section 10.

Google User Data

If you connect a Google account, Bels accesses your Google Calendar through Google’s authorization process, including your list of calendars, events on the calendars you choose to share, and the email address of the connected account. Bels uses this information to understand your schedule and plan around it and, where you allow it, to add, update, or remove events on your calendar. You can ask Bels to stop making changes to your calendar at any time, and you can disconnect your Google account in Bels or revoke access at myaccount.google.com/permissions.

Bels’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Notwithstanding anything else in this Privacy Policy:

5. De-Identified and Aggregated Information

We may create information that has been aggregated, de-identified, or otherwise processed so that it cannot reasonably be used to identify or be linked to an individual or a device associated with an individual.

We may use de-identified or aggregated information for lawful purposes, including to:

For example, Bels may in the future develop products that allow organizations to understand aggregated patterns, preferences, behaviors, or trends without identifying individual Bels users.

When we treat information as de-identified, we take reasonable measures designed to prevent it from being associated with an identifiable individual, publicly commit not to attempt to reidentify it, and require recipients of de-identified information to maintain it in de-identified form and not attempt to reidentify it.

We do not treat merely pseudonymized information—such as information with a name removed but that can reasonably be linked back to an individual—as de-identified information.

The uses described in this section remain subject to restrictions imposed by applicable law and by services from which information originated.

6. How We Disclose Information

We may disclose personal information in the following circumstances.

Service Providers

We use service providers that help us operate Bels, including providers of:

These providers process information on our behalf and are subject to contractual or other restrictions appropriate to the services they provide.

At Your Direction

We may disclose information when you direct us to do so, including when you connect Bels to another service or ask Bels to take an action involving another provider.

Legal, Safety, and Security Purposes

We may disclose information if we reasonably believe doing so is necessary to:

Corporate Transactions

If Bels is involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar transaction, information may be transferred as part of that transaction subject to applicable law.

De-Identified Information

We may use and disclose de-identified and aggregated information as described in Section 5.

7. We Do Not Sell Identifiable Personal or Health Information

Bels does not sell personal information or identifiable consumer health data.

We do not sell identifiable information to data brokers, advertising platforms, or information resellers.

We do not use personal or health information to target users with advertising.

As described in Section 5, we may use, license, disclose, or commercialize information and products created from information that has been properly de-identified or aggregated so that it cannot reasonably be linked to an identifiable person.

8. Consumer Health Data Privacy

This section provides additional information about our practices involving “consumer health data” as that term is defined under applicable consumer health privacy laws, including Washington’s My Health My Data Act.

Consumer Health Data We May Collect

Depending on how you use Bels, consumer health data may include information relating to:

Sources of Consumer Health Data

We may obtain consumer health data:

Why We Collect and Use It

We collect and use consumer health data to:

We will obtain affirmative consent where applicable law requires it.

Categories of Consumer Health Data We Disclose

We may provide consumer health data to processors and service providers where reasonably necessary to perform services on our behalf, such as cloud infrastructure, AI processing, data storage, security, transcription, and other product infrastructure.

We may also disclose consumer health data when you direct us to do so or when required or permitted by law as described in this Privacy Policy.

We do not currently sell identifiable consumer health data.

Categories of Recipients

Recipients may include:

Bels does not currently have affiliates with which it shares consumer health data for their independent purposes.

Your Consumer Health Data Rights

Where applicable, you may have the right to:

You may exercise these rights by emailing privacy@withbels.com.

If you have a Bels account, we may ask you to verify the request using information associated with your account.

You may also withdraw permissions for a connected service through the relevant service or device, where available.

If we deny a privacy request, you may appeal by emailing privacy@withbels.com with the subject line “Privacy Appeal.”

We will respond within the periods required by applicable law.

9. Your Other Privacy Rights

Depending on where you live, you may have additional rights regarding your personal information.

These may include rights to:

You may submit a request to privacy@withbels.com.

We may take reasonable steps to verify that the person making the request is the person to whom the information relates.

10. Account Deletion and Data Deletion

You may initiate deletion of your Bels account through the account settings in the Bels application.

Deleting your account will initiate deletion of personal information associated with your account, including conversations and stored personal context, except for information that we are permitted or required to retain.

You may also request deletion by emailing privacy@withbels.com.

After a deletion request is authenticated, we will delete applicable personal information from our active systems and instruct relevant processors to delete information they maintain on our behalf, in accordance with applicable law.

Certain information may be retained where necessary to:

Information maintained in archived or backup systems may require additional time to delete. Where Washington’s consumer health privacy law applies, deletion of consumer health data from archived or backup systems will occur within the period permitted by that law.

Information that was validly de-identified before your deletion request and can no longer reasonably be linked to you may be retained.

Deleting Bels from your device does not delete your account or information stored by Bels.

Disconnecting an integration stops future collection from that integration but does not by itself delete information previously received.

11. Data Retention

We retain identifiable personal information for as long as reasonably necessary for the purposes described in this Privacy Policy.

The length of time we retain particular information depends on factors including:

We may retain de-identified or aggregated information for longer periods where it can no longer reasonably be linked to you.

12. Security

We maintain administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, use, alteration, loss, or disclosure.

We restrict access to sensitive information to authorized personnel and service providers with a legitimate need for access.

We also require processors handling sensitive information on our behalf to maintain appropriate protections.

No method of storing or transmitting information is completely secure, and we cannot guarantee absolute security.

13. Children

Bels is not intended for anyone under 18.

We do not knowingly permit individuals under 18 to create consumer Bels accounts.

If you believe that someone under 18 has provided personal information to Bels, contact privacy@withbels.com.

14. International Access

Bels’s consumer Services are currently designed and offered primarily for users in the United States.

The Services may nevertheless be accessible from other countries. If you access Bels outside the United States, you understand that information may be transferred to and processed in the United States and other locations where Bels or its service providers operate, subject to applicable law.

Availability of Bels in a particular app store, TestFlight program, or location does not necessarily mean that Bels actively offers the Services in that jurisdiction.

15. Changes to This Privacy Policy

We may update this Privacy Policy as Bels evolves.

If we make material changes, we will provide notice as required by applicable law.

Where applicable law requires additional consent before we collect, use, or disclose consumer health data for a new purpose, we will obtain that consent before doing so.

16. Contact Us

For privacy questions, requests, or complaints:

Halo 27, Inc.
doing business as Bels
privacy@withbels.com