Positive Development Privacy Policy

Effective as of 03/06/2026

This “Privacy Policy” describes the privacy practices of Positive Development, Inc. and our subsidiaries and affiliates (collectively, “Positive Development”, “we”, “us”, or “our”) in connection with the Positive Development App www.positivedevelopment.app (the “App”), www.positivedevelopment.com website (“Website”), and Positive Development Clinicians Portal (“Portal”), and the services made available through the App and Portal (collectively, the “Service”), and the rights and choices available to individuals with respect to their information.

This Privacy Policy also applies to any clinician’s office, business, organization, or practice that has subscribed to oun service, or through which a subscription has been made. In addition to the uses described in this Privacy Policy, we will use and process Personal Data collected from Subscribers in accordance with any additional rights and obligations set forth in that separate terms of use agreement and/or BAA entered into between the Subscriber and Positive Development.

Table of Contents

• Personal Information We Collect
• How We Use Your Personal Information
• How We Share your Personal Information
• Your Choices
• Other sites, mobile applications and services
• Security practices
• International data transfers
• Children
• Changes to this Privacy Policy
• How to Contact Us
• Your California Privacy Rights

Personal Information We Collect

Information you provide to us. Personal information you provide to us through the Service or otherwise includes:

• Personal contact information, such as your first and last name, telephone number, email, and mailing addresses.
• Profile information, such as your username and password that you may set to establish an online account
with us.
• Registration information, such as information that may be related to a service or an account.
• Feedback or correspondence, such as information you provide when you contact us with questions,
feedback, or otherwise correspond with us online.

• Usage information, such as information about how you use the Service or view content, as well as other products and services of Positive Development (including any Positive Development devices), how you
interact with us, and information you provide when you use any interactive features of the Service.
• Other information that we may collect which is not specifically listed here, but which we will use in
accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from other third parties. We may receive personal information about you from third-party sources. For example, we may collect information from your developmental client coaches, speech therapists,
occupational therapists, physical therapists, therapists and related therapy providers (collectively, “Clinicians”)
who are Subscribers. Such information may include your diagnosis and onset data. We only use this data to allow
your Clinicians to provide its services to you through the Services. Personal Information may include Protected
Health Information (“PHI”), which we may collect, process, and store, on behalf of our Subscribers.

Clinicians may record therapy sessions with you (or your child) using means outside of our Services, and in such
event Clinicians, rather than Positive Development, are responsible for securing any necessary consents from you and storing such recordings. Positive Development will maintain such recorded sessions that are uploaded by Clinicians through the Services only for as long as the Clinician and patient maintain a relationship; provided,
however, you may opt-in to additional sharing as described below in “Your Choices”.

Cookies and Other Information Collected by Automated Means

We, our service providers, and our business partners may automatically log information about you, your computer, or mobile device, and activity occurring on or through the Service. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, general location information such as city, state or geographic area; and information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or
screen, navigation paths between pages or screens, information about your activity on a page or screen, access
times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

In our mobile application, we may collect this information directly or through our use of third-party software
development kits (“SDKs”). SDKs may enable third parties to collect information directly from our App.

See our Cookie Policy for more information.

Referrals

Users of the Service may have the opportunity to refer contacts to us. If you are an existing user, you may only
submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Service. We use your personal information to:

• Provide, operate and improve the Service
• Provide information about our products and services
• Establish and maintain your user profile on the Service
• Enable security features of the Service, such as by sending you security codes via email or SMS, and
remembering devices from which you have previously logged in

• Communicate with you about the Service, including by sending you announcements, updates, security
alerts, and support and administrative messages
• Understand your needs and interests, and personalize your experience with the Service and our
communications
• Provide support and maintenance for the Service
• Respond to your requests, questions and feedback

For research and development. We analyze use of the Service to analyze and improve the Service and to develop
new products and services, including by studying user demographics and use of the Service.

To send you marketing and promotional communications. We may send you Positive Development related
marketing communications. You will have the ability to opt-out of our marketing and promotional communications as described in the opt out of marketing section.

To comply with law. We use your personal information as we believe necessary or appropriate to comply with
applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law
enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect
our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce
the terms and conditions that govern the Service; and (c) protect, investigate and deter against fraudulent,
harmful, unauthorized, unethical or illegal activity.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal
information.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified
data from your personal information. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

How We Share your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

Clinicians. We may share your personal information with Clinicians who are Subscribers and who have invited to
you to join the Services.

Affiliates. We may share your personal information with our corporate parent, subsidiaries, and affiliates, for
purposes consistent with this Privacy Policy.

Service providers. We may share your personal information with third party companies and individuals that
provide services on our behalf. These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy.

Professional advisors. We may disclose your personal information to professional advisors where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud
prevention and safety purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your
personal information, in connection with a business transaction (or potential business transaction) such as a
corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of
bankruptcy or dissolution.

Your Choices

Access or Update Your Information. If you have registered for an account with us, you may review and update
certain personal information in your account profile by logging into the account.

Revocation/opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at privacy@positivedevelopment.com.
You may continue to receive service-related and other non-marketing emails. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message.

Opt-In to Continued Use of Videotaped Sessions: By default, Positive Development will only use recorded
therapy sessions to provide the Services. However, as a patient, you have to opt-in to additional sharing.

Cookies & Browser Web Storage. We may allow service providers and other third parties to use cookies and
similar technologies to track your browsing activity over time. For more details, see our Cookie Policy.

Choosing not to share your personal information. If you do not provide this information when requested, we may not be able to provide you with our services.
We will tell you what information you must provide to receive the Service.

Other sites, mobile applications and services

The Service may contain links to other websites, mobile applications, and other online services operated by third
parties. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions.

Security practices

The security of your personal information is important to us. We employ a number of organizational, technical and
physical safeguards designed to protect the personal information we collect.

Children

As a general rule, children under the age of 13 should not use the Service. We define "children" as anyone under the age of 13.

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 Service.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to privacy@positivedevelopment.com.

Last modified 03/06/2026.