Privacy notice

Introduction

Purpose and scope

Carrot Fertility, Inc. (“Carrot Fertility”) and Carrot Medical, LLC (“Carrot Medical”) are committed to protecting your privacy. This Privacy Notice explains how your Personal Information is collected, used, stored, processed, transferred, and disclosed by Carrot Fertility and Carrot Medical (collectively, “Carrot,” “we,” “our,” or “us”).

This Privacy Notice applies to our website https://get-carrot.com (our "Website") and any other website, mobile application, or online service that links to this Privacy Notice (collectively, our "Service").

The Service may contain links to and from third party websites of our business partners, advertisers, and social media sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We may also share a user ID with third-party websites allowing us and the third-party website provider to jointly track specified activities across both websites. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third party sites.

Before accessing or using our Service, please ensure that you have read and understood our collection, storage, use, and disclosure of your Personal Information as described in this Privacy Notice.

HIPAA Applicability

This Privacy Policy does not apply to Carrot’s use and disclosure of Protected Health Information. Carrot Medical uses and discloses Protected Health Information about Carrot Medical patients in accordance with its Notice of Privacy Practices. Carrot Medical uses and discloses Protected Health Information about Carrot Medical patients in accordance with its obligations as a HIPAA Covered Entity.

In addition, to the extent that you are subject to United States benefit and taxation laws, and that your employer has established a health reimbursement arrangement plan (“HRA”), Carrot uses and discloses Protected Health Information that it receives from or on behalf of the HRA as a Business Associate under a Business Associate Agreement with the HRA. Please review the HRA’s Notice of Privacy Practices for an explanation of how the HRA uses and discloses your Protected Health Information.

Important Terminology

Carrot is the “Data Controller” responsible for protecting your Personal Information, which means we determine and are responsible for how your Personal Information is handled. If your access to Carrot is sponsored by an employer, health plan, or other benefit sponsor (collectively, a "Plan Sponsor"), the Plan Sponsor will initially send us your name and eligibility information ("Eligibility File"). If you have queries regarding the information contained in the Eligibility File, please contact your Plan Sponsor.

"Personal information" encompasses all “Personal Data” as defined in Art. 4 (1) of the General Data Protection Regulation ("GDPR"), meaning any information that relates to an identified or identifiable individual.

Geographic considerations

Supplemental information for certain states

If your state of residence has specific privacy requirements that go beyond the general scope of this Privacy Notice, it is listed below:

• California
• Connecticut
• Delaware
• Nebraska
• Nevada
• New Jersey
• Texas
• Washington

If you are a resident of Washington, you can also click here for more detailed information.

If you are resident of Nevada, you can also click here.

If you are a resident of a state that is not listed above, please contact us at legal@get-carrot.com if you have any questions about this Privacy Notice.

Supplemental Information for certain countries

If your country of residence has specific privacy requirements that go beyond the general scope of this Privacy Notice, it is listed below:

EMEA: European Union (EU); United Kingdom (U.K.); Switzerland; Serbia; Turkey; South Africa

Latin America: Chile; Colombia; Guatemala; Brazil

Asia: China; The Philippines; Thailand; India

North America: Canada; Mexico

Oceania: Australia; New Zealand

If you are a resident of a jurisdiction that is not listed above, please contact us at legal@get-carrot.com if you have any questions about this Privacy Notice.

International data transfers

In order to provide services, Carrot will store and process your Personal Information in the United States. To the extent that your local jurisdiction considers this an “international data transfer,” we will comply with that jurisdiction’s requirements for transferring Personal Information to other countries.

For Residents of the EEA, Switzerland, and the United Kingdom

When your employer sends us your name and eligibility information ("Employee Eligibility File"), we will store and process that information in the United States.

Use of Artificial Intelligence (AI) and Machine Learning (ML)

Overview and legal bases

We use Artificial Intelligence (AI) and Machine Learning (ML) technology in different ways across the Service. Our uses fall under two broad categories:

• AI uses for which we rely on your consent. For certain AI uses, we will only process your Personal Information with your consent. You may withdraw consent at any time.

• AI uses for which we rely on performance of contract and/or our legitimate interests. For other AI uses, we rely on performance of contract and/or our legitimate interests.

Carrot Sprints

If you participate in Carrot Sprints, our fertility and metabolic health coaching program, AI technology supports personalized guidance based on the medical history, lifestyle data, and engagement patterns you provide. Direct identifiers are not sent to the AI system used for personalization.

Human oversight and automated decision-making

We do not rely on AI alone to make decisions that have a legal or similarly significant effect on you without meaningful human review.

Collection, use, and disclosure of personal information

Collection

Personal information we collect from you and from third parties

How we collect Personal Information

We collect Personal Information about you when you voluntarily submit information to us when you use our Service.

• Categories of Personal Information we Collect
  • Contact and profile information
  • Sensitive Personal Information, such as health data, biometric data, and data about your sexual orientation
  • Payment and transaction information
  • Location information
  • Information provided by third parties

Use

Overview of how and why we use personal information

• To communicate with you directly about the Service.
• To send you marketing or promotional communications.
• To verify eligibility for services offered by third party partners and service providers.

Disclosure

How and why we may disclose your information

• Employers: We share information with your employer to support the operation and administration of that benefit.
• Third Party Partners and Service Providers: We will share certain Personal Information with third party partners and service providers as necessary to achieve the purpose for which we have shared it.

Your choices and control over your information

Your rights under applicable data protection laws

You have the right to understand how your personal and health information is collected, used, shared, and protected. Specifically:

• Right to access: Obtain access to your Personal Information along with certain related information.
• Right to rectification: Obtain rectification of your Personal Information without undue delay.
• Right to erasure: Obtain the erasure of your Personal Information without undue delay in certain circumstances.

How we store and protect your information

Keeping your information safe

We care about the security of your information and employ safeguards designed to preserve the integrity and security of all information collected through our Service.

Retention of your information

We will retain your information only as long as necessary for the purposes outlined in this Privacy Notice.

Questions about and changes to this privacy notice

If you have any questions about this Privacy Notice, please contact us at legal@get-carrot.com.

Effective Date: June 2026