Privacy Policy

Abra ("we", "us", "our") is committed to protecting your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) contained in Schedule 1 of that Act.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website, purchase our products, or interact with us in any other way.

We may collect the following types of personal information:

Identity & Contact Information Name, email address, phone number, and postal/delivery address.

Transaction Information Purchase history, payment method details (processed securely via Stripe — we do not store full card numbers), billing address, and order fulfilment records.

Device & Health Data If you use an Abra smart ring or connected device, we may collect biometric and wellness data (heart rate, sleep patterns, activity metrics, blood oxygen levels) that you choose to sync with our app or platform. This data is treated as sensitive information under the APPs.

Technical Information IP address, browser type, device identifiers, pages visited, and referral source, collected via cookies and analytics tools.

Communications Records of correspondence if you contact us by email, phone, or through our website.

We collect personal information:

• Directly from you when you create an account, place an order, join our waitlist, or contact us
• Automatically through cookies and similar technologies when you use our website
• From your Abra device when you sync health and wellness data
• From third-party service providers (such as payment processors and logistics partners) in the course of fulfilling your order

We use your personal information to:

• Process and fulfil your orders and manage returns or exchanges
• Provide, operate, and improve our products and services
• Send transactional communications (order confirmations, shipping updates)
• Send marketing communications where you have consented or where permitted by law — you may opt out at any time
• Personalise your experience on our website and app
• Conduct analytics and research to improve our products
• Comply with our legal obligations
• Detect and prevent fraud or other unlawful activity

We will not use your health or biometric data for purposes beyond providing and improving our wellness services without your explicit consent.

We may disclose your personal information to:

• **Service providers** who assist us in operating our business (payment processors, logistics and fulfilment partners, cloud hosting providers, analytics platforms, email service providers) — these parties are contractually required to handle your information in accordance with the APPs
• **Stripe** for secure payment processing (see Stripe's Privacy Policy at stripe.com/au/privacy)
• **Government and regulatory bodies** where required by law or court order
• **Successors** in the event of a business sale, merger, or acquisition

We do not sell your personal information to third parties.

Some of our service providers are located overseas, including in the United States and the European Union. Where we disclose personal information to overseas recipients, we take reasonable steps to ensure those recipients handle your information in a manner consistent with the APPs.

By using our services, you consent to your personal information being transferred to and processed in countries outside Australia.

Health and biometric data collected by your Abra device is sensitive information under the Privacy Act 1988 (Cth). We handle this data with additional care:

• We collect health data only with your explicit consent
• Health data is encrypted in transit and at rest
• We do not share your individual health data with third parties for marketing or advertising purposes
• You may delete your health data at any time through your account settings or by contacting us
• Aggregated, de-identified health data may be used for product research and improvement

Our website uses cookies and similar technologies to enhance your browsing experience, analyse site traffic, and personalise content. You can control cookie settings through your browser; however, disabling certain cookies may affect website functionality.

We use analytics tools (such as Google Analytics) that may collect information about your use of our website. This data is used in aggregate form to improve our services.

We take reasonable steps to protect your personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. These measures include SSL/TLS encryption, secure payment processing via Stripe, access controls, and regular security reviews.

No method of transmission over the internet is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security.

Under the Privacy Act 1988 (Cth), you have the right to:

• Request access to the personal information we hold about you
• Request correction of personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading

To make an access or correction request, please contact us using the details in Section 13. We will respond within 30 days. We may charge a reasonable fee for providing access in certain circumstances.

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, accounting, or reporting requirements. When personal information is no longer required, we take reasonable steps to destroy or de-identify it.

If you believe we have breached the Australian Privacy Principles or the Privacy Act 1988 (Cth), you may lodge a complaint with us by contacting us at the details below. We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days.

If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

Office of the Australian Information Commissioner Website: oaic.gov.au Phone: 1300 363 992 Post: GPO Box 5218, Sydney NSW 2001

For any privacy-related enquiries, access requests, correction requests, or complaints, please contact our Privacy Officer:

Abra Email: privacy@abra.com.au Website: abra.com.au

We will respond to your enquiry within a reasonable timeframe.

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. We will post the updated policy on our website with a revised "Last Updated" date. We encourage you to review this policy periodically.