Privacy Policy

Last Modified: March 30, 2026

 

Mobile App Addendum for the Feno App

Last updated: March 9, 2026

This addendum applies specifically to the Feno mobile application, including the Android app published under the package name co.feno.fenoapp, and supplements the policy below with app-specific disclosures.

Information Collected Through the App

In addition to the information described below, the Feno mobile app may collect or process:

- Email address and phone number used for account login or passcode authentication
- One-time passcode authentication information
- Scan images, videos, and related inputs you choose to capture or upload
- Scan analysis results, related summaries, and scan history associated with your account
- Smartbrush connection, authentication, and session data
- Subscription or membership status needed to enable paid features
- Device information such as device model, operating system, app version, identifiers used for security or diagnostics, and crash data
- Log, diagnostic, and performance data used to operate, debug, and improve the app

App Permissions and Device Access

The app may request access to device features when needed for specific functionality:

- Camera: used to capture scans, oral images, and related in-app scanning workflows
- Microphone: used for chat or communication features that support audio input or recording
- Bluetooth: used to discover, connect to, authenticate, and sync with compatible Feno devices such as the Smartbrush
- Notifications: used to send operational or product-related notifications if you allow them
- Local storage and secure storage: used to store authentication tokens, onboarding state, app preferences, and similar app data on your device

If you deny certain permissions, some app features may not work.

App-Specific Service Providers and Use

The mobile app may use service providers such as Sentry for crash reporting and diagnostics, and Stream for chat and messaging functionality. We do not sell personal information collected through the app. We do not use scan-related information for third-party advertising.

 

Introduction

Feno Labs, Inc. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website feno.co (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

- On this Website.
- In email, text, and other electronic messages between you and this Website.
- Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
- When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
- Through third-party health testing services integrated into certain Feno product offerings, including but not limited to biological sample collection programs offered as part of Feno Elite or any other Feno product bundle that includes Health Partner services.

It does not apply to information collected by us offline or through any other means, including on any other website operated by Company or any third party, or any third party, including through any application or content that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 16

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at support@feno.co.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Age Requirements for Health Partner Services

Certain Feno products and features that involve third-party health testing services, biological sample collection, or AI-generated health insights — including Feno Elite Bundles — are available only to users who are 18 years of age or older, regardless of parental or guardian consent. By purchasing or activating any such product or feature, you represent that you are at least 18 years of age. This requirement supersedes the general age eligibility provisions of this policy solely with respect to those products and features.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information by which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline; information that is about you but individually does not identify you; and information about your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

- Directly from you when you provide it to us.
- Automatically as you navigate through the Website.
- From third parties, for example, our business partners.
- From Health Partners, when you purchase and activate a Feno product that includes third-party health testing services, as described in the Health Data Categories section below.

Face Data Collection through TrueDepth API

In our commitment to advanced oral care, Feno Labs, Inc. harnesses Apple Inc.’s TrueDepth API for the precise collection of facial depth data. This approach enables us to construct 3D models of users’ lower jaws, essential for customizing our TrueFit Mouthpieces. This process ensures a personalized fit for enhanced comfort and effectiveness in oral hygiene. We maintain high standards of data security and privacy, with this data strictly used for internal product development and not shared with any third parties for any marketing-related activities.

Retention of Facial Data Collected Through TrueDepth API

Feno Labs, Inc. retains facial data collected through Apple Inc.’s TrueDepth API only for the period necessary to achieve its intended purpose of customizing TrueFit Mouthpieces and enhancing user experience. This retention period is determined by considering factors such as product lifecycle, ongoing user engagement, and compliance with legal and regulatory obligations. Throughout this period, we ensure that robust security measures are in place to protect the data from unauthorized access or misuse.

Information You Provide to Us

The information we collect on or through our Website may include information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, purchasing our products, subscribing to our services, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Website.

We collect records and copies of your correspondence, including email addresses, if you contact us. We collect your responses to surveys that we might ask you to complete for research purposes. We collect details of transactions you carry out through our Platform and of the fulfillment of your orders.

You also may provide information to be published or displayed on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other users of the Website with whom you may choose to share your User Contributions.

In addition, you agree to our Messaging Terms and Messaging Privacy Policy.

Health Data Categories

When you purchase a Feno product that includes third-party health testing services, the following additional categories of data may be collected, received, or processed by Feno in connection with your use of those services:

Biological Sample Data

Certain Feno products include a biological sample collection kit provided by a Health Partner. You will self-collect and submit your sample directly to the Health Partner’s laboratory. Feno does not receive your raw biological samples. The Health Partner processes your samples under their own terms of service and privacy policy, which you will be required to accept separately prior to sample submission.

Health Partner Test Results and Insights

Following laboratory analysis of your sample, the Health Partner transmits result outputs and health insights to Feno. These outputs may include microbiome composition indicators, functional health scores, and wellness recommendations generated by the Health Partner’s platform. These result outputs — not the underlying sample or sequencing data — are the data category received and processed by Feno.

Combined Platform Data

Feno combines Health Partner result outputs with data collected through your Feno device and application — including Smartbrush session data, oral scan images, oral health scores, and self-reported information — to generate your personalized health insights through the Fenome intelligence platform.

Self-Reported Health Information

You may provide health-related information directly within the Feno app, including information about your diet, lifestyle, existing health conditions, and health goals. This information may be used as an additional input to the Fenome AI platform.

Protected Health Information

To the extent any data generated through a Health Partner service qualifies as Protected Health Information (PHI) under HIPAA, that data is handled in accordance with applicable law and the Business Associate Agreement in place between Feno and the relevant Health Partner. Feno processes only the minimum information necessary for fulfillment coordination and AI platform delivery. All clinical processing is performed by the Health Partner.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including details of your visits to our Website including traffic data, location data, logs, and other communication data, and information about your computer and internet connection including your IP address, operating system, and browser type.

The technologies we use for this automatic data collection may include cookies, Flash cookies, and web beacons. You may refuse to accept browser cookies by activating the appropriate setting on your browser, however if you select this setting you may be unable to access certain parts of our Website. We do not currently respond to “do not track” signals from web browsers.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, for the purposes described below: to present our Website and its contents to you; to provide you with information, products, or services that you request from us; to fulfill any other purpose for which you provide it; to provide you with notices about your account; to carry out our obligations and enforce our rights arising from any contracts entered into between you and us; to notify you about changes to our Website or any products or services we offer; to allow you to participate in interactive features on our Website; in any other way we may describe when you provide the information; and for any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences.

AI Model Improvement — All Users

Regardless of whether you have enrolled in a Health Partner program, by using the Feno Platform you consent to Feno using de-identified, aggregated data derived from your use of the Platform, including Smartbrush session data, oral scan images, oral health scores, and self-reported information you provide within the Feno app, to train, improve, and refine the Fenome AI model and platform recommendations. This data is processed in a form that cannot reasonably be used to identify you as an individual. Feno will not use individually identifiable data for AI model training without your separate, explicit consent. You may opt out of this use at any time as described in the Your Rights section below.

In addition, for users who have enrolled in a Feno product that includes third-party health testing services, we use your information for the following additional purposes:

Health Partner Program Coordination

We use your name, email address, shipping address, and order information to coordinate kit delivery, confirm activation, and facilitate communication between you and the Health Partner as required to fulfill your order.

Fenome AI Platform — Combined Health Analysis

With your explicit consent obtained at the point of kit activation, Feno uses Health Partner result outputs in combination with your Smartbrush session data, oral scan images, Fenome platform metrics, and self-reported health information to generate personalized oral health recommendations and systemic health insights delivered through the Feno app. This is the primary purpose for which Feno receives Health Partner data.

AI Model Improvement — Health Partner Enrollees

In addition to the platform-wide AI model improvement described above, Feno may use de-identified, aggregated data — combining oral health metrics from your Feno device and Fenome platform with de-identified Health Partner insights — to further improve the accuracy and performance of its AI models and platform recommendations. You may opt out of all AI model improvement use at any time as described in the Your Rights section below.

All insights generated through the Fenome AI platform are for informational and wellness purposes only. They do not constitute medical advice, clinical diagnosis, or treatment recommendations. You should consult a qualified healthcare professional before making any decisions about your health based on information provided through the Feno platform.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy:

- To our subsidiaries and affiliates.
- To contractors, service providers, and other third parties we use to support our business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Feno Labs, Inc.’s assets.
- To third parties to market their products or services to you if you have not opted out of these disclosures.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.

We may also disclose your personal information to comply with any court order, law, or legal process; to enforce or apply our terms of use; or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Feno Labs, Inc., our customers, or others.

In addition, for users enrolled in a Health Partner program:

To Health Partners

We share your name, email address, shipping information, and order data with our Health Partners solely for the purpose of kit fulfillment, activation confirmation, and transmission of result outputs back to the Feno platform. Health Partners are contractually required to handle your information in accordance with applicable privacy law and the terms of our agreements with them. Health Partners’ processing of your biological sample and the data derived from it is governed by their own terms of service and privacy policy.

For AI Platform Purposes

Feno does not disclose your Health Partner result outputs or combined health profile to any third party for advertising, marketing, or commercial data purposes. Health Partner data received by Feno is used solely for delivering your personalized Feno experience as described in this policy.

As Required by Law

Health data held by Feno may be subject to disclosure pursuant to legal process, court order, or regulatory requirement, in accordance with the general disclosure provisions of this policy and applicable HIPAA requirements where relevant.

HIPAA and Protected Health Information

To the extent that Feno receives Protected Health Information (PHI) as defined under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and its implementing regulations, Feno will handle such information in accordance with applicable law and any Business Associate Agreement (BAA) in place with the relevant Health Partner.

Feno is not a Covered Entity under HIPAA. Where Feno acts as a Business Associate, it will implement and maintain appropriate technical, administrative, and physical safeguards to protect the privacy and security of PHI as required by HIPAA and the HITECH Act.

Your Rights — Health Data

You have the following rights with respect to health data held by Feno:

- Access: You may request a copy of the health data Feno holds about you by contacting support@feno.co.
- Correction: You may request correction of inaccurate health data held by Feno.
- Deletion: You may request deletion of your health data from Feno’s systems. Note that deletion requests relating to biological sample data processed by a Health Partner must also be submitted directly to that Health Partner, as Feno does not control data held in third-party systems.
- Portability: You may request an export of your Feno health data in a machine-readable format.
- Withdrawal of AI model training consent (all users): You may withdraw consent for your de-identified data to be used for AI model improvement at any time by contacting support@feno.co with the subject line “Opt Out of Model Training”. This right applies regardless of whether you have enrolled in a Health Partner program. Withdrawal will not affect data already incorporated into prior training cycles.
- Withdrawal of combined data analysis consent: You may withdraw consent to Feno’s use of Health Partner result outputs within the Fenome AI platform at any time by contacting support@feno.co with the subject line “Withdraw Health Data Consent”. Withdrawal applies on a going-forward basis and does not affect data held independently by the Health Partner.

To exercise any of these rights, contact us at support@feno.co. We will respond to verified requests within 30 days.

Data Retention — Health and Biological Sample Data

Health data received from Health Partners, including test result outputs and functional health insights, will be retained by Feno for as long as your account remains active and for a period of up to 3 years following account termination, except where longer retention is required by applicable law.

Upon account termination or a verified deletion request, Feno will delete or permanently anonymize your health data within 60 days, except where retention is required by law or where the data has already been irreversibly incorporated into anonymized aggregate datasets used for AI model improvement.

Feno does not control the retention practices of Health Partners. Raw biological samples and underlying sequencing data are retained by Health Partners under their own policies. You should review each Health Partner’s privacy policy for information about their retention schedule and your rights.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and personal health information are encrypted using SSL technology.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website.

When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We, or service providers on our behalf, may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with control over your information including tracking technologies and advertising controls, disclosure opt-outs for third-party advertising, and promotional offer opt-outs. If you do not wish to have your contact information used by the Company to promote our own or third-parties’ products or services, you can opt out by sending us an email stating your request to support@feno.co.

Health data opt-out and withdrawal rights are described in the Your Rights — Health Data section above.

Accessing and Correcting Your Information

You can review and change your personal information by sending us an email at support@feno.co to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Health data access, correction, and deletion rights are separately described in the Your Rights — Health Data section above.

State Privacy Rights — Health Data

Washington State — My Health My Data Act

Data generated through a Health Partner integration may qualify as consumer health data under the Washington My Health My Data Act (MHMDA). Data processed by Health Partners is governed by their own MHMDA-compliant consumer health data privacy policies. Feno will separately assess whether AI-generated oral health outputs produced by the Fenome platform independently constitute consumer health data under MHMDA and will update this policy if that assessment concludes they do.

California, Colorado, Virginia, Utah, Nevada, and Connecticut

Residents of these states may have additional rights with respect to health-related personal information processed by Feno or its Health Partners in connection with Feno Elite or any other Feno product that includes health testing services. Rights requests relating to health data held by Feno may be submitted to support@feno.co. Rights requests relating to data held by a Health Partner must be submitted directly to that partner.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our app that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to support@feno.co.

International Customers — Health Data

Health Partners engaged by Feno process personal data from international customers in compliance with applicable data protection laws, including GDPR, UK GDPR, and the Swiss Federal Act on Data Protection, where relevant. Feno does not independently transfer health data internationally in connection with Health Partner integrations. Feno will update this policy if its own AI platform activities create independent international data transfer obligations as its customer base expands.

International customers with questions regarding data protection rights relating to Health Partner-originated data should contact the relevant Health Partner directly. Questions regarding Feno-held health data may be directed to support@feno.co.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at support@feno.co.

To register a complaint or concern, please email our Marketing Department at support@feno.co.

For questions specifically relating to health data, Health Partner integrations, HIPAA matters, or to exercise any of the health data rights described in this policy, contact us at support@feno.co with the relevant subject line as described in the Your Rights — Health Data section above.