Overview

ME24 Limited (“we”, “us”, “our”) is committed to transparency in our use of artificial intelligence (“AI”) within the Areela platform. This AI Transparency and Use Policy explains how AI is used, what data it processes, its limitations, and your rights in relation to AI- assisted features. The Areela platform integrates AI across multiple features to enhance the coaching experience for both coaches and clients. AI is used as an assistive tool, it supports and augments human coaching, but does not replace it.

AI Features

The Platform uses AI in the following features:

AI Providers and Models

We use the following third-party AI providers and models: These providers are listed as approved Sub-processors in Schedule 4 of the Subscription Services Agreement and are subject to the sub-processor management provisions in the Data Processing Addendum (Schedule 2 of the Subscription Services Agreement). The AI Features and related use requirements should also be read with Clause 11 (AI Features) of the Subscription Services Agreement.

Data Inputs

AI features process the following categories of data to generate outputs:

a) Health data: injuries, medical conditions, PAR-Q responses, allergies, medication, blood type

b) Workout data: exercise history, performance metrics, programme progress, completion rates

c) Nutrition data: meal logs, calorie and macronutrient intake, hydration levels, dietary preferences

d) Sleep data: duration, quality, stages (from wearable devices via Terra API)e) Messages: communications between coaches and clients within the Platform

f) Profile information: age, gender, goals, activity levels, lifestyle information

g) Check-in data: progress updates, body measurements, subjective feedback, progress photographs, and other images or files; images or files may be sent to OpenAI where an AI feature requires them and are subject to the image/file Safety Classification exception.

h) Wearable metrics: heart rate, blood oxygen, steps, calories, body temperature, glucose (where available) Zero Data Retention (ZDR) and OpenAI Safeguards OpenAI will not use your data to develop or improve its services. This is confirmed by the Modified Retention Amendment and the OpenAI Services Agreement, which provide that OpenAI will not use Customer Content to develop or improve the Services unless explicitly agreed. ME24 Limited has a confirmed Modified Retention Amendment with OpenAI OpCo, LLC dated 6 September 2026 under its OpenAI Enterprise Agreement. Under this arrangement, Zero Data Retention (ZDR) is enabled for eligible API endpoints. Text-based inputs and AI responses are not logged for abuse monitoring or human review and are not retained beyond the immediate processing request. ZDR does not apply to image or file inputs, which may be retained for automated Safety Classification. Image and file inputs (such as progress photos uploaded through AI features) are excluded from Zero Data Retention and may be retained by OpenAI for automated safety classification purposes. Automated safety classification may generate metadata (classifier types, dates, counts, and confidence scores) but this metadata does not contain your content. If you use an API endpoint that is not eligible for Zero Data Retention, data will not be logged but may be retained for application state. Your data is processed in the United States by OpenAI OpCo, LLC at 1455 3rd Street, San Francisco, CA 94158. Appropriate transfer safeguards apply, including the EU Standard Contractual Clauses as amended by the UK Addendum. The OpenAI Data Processing Addendum instructs OpenAI OpCo, LLC to process UK Data under those clauses and the UK Addendum. OpenAI may suspend or revoke approval for Modified Retention, suspend access to the Services, or take other action if Safety Classifiers indicate persistent or material violations or OpenAI reasonably suspects a violation of the applicable agreement, OpenAI Policies, or the Amendment. If ME24 Limited is notified that ZDR has been suspended or revoked, or otherwise ceases to apply, ME24 Limited will promptly notify affected users and suspend the AI features that send data to OpenAI until an equivalent compliant arrangement or alternative processing solution is restored.

OpenAI Policy Monitoring

OpenAI may update its Usage Policies and other terms from time to time. ME24 Limited conducts a quarterly review of the OpenAI Data Processing Addendum, Usage Policies, Business Terms, Your Data documentation and applicable security materials, and maintains version-controlled copies recording the applicable version and effective date. If a material change adversely affects data processing, transfer safeguards, ZDR coverage or the availability of AI features, we will notify affected users and review whether the affected feature should be suspended or changed. OpenAI’s Usage Policies prohibit the automation of high-stakes decisions in sensitive areas, including medical decisions, without human review. The Platform complies with this requirement by implementing guardrails that: redirect medical queries, require coach reviewof escalated recommendations, and clearly label all AI outputs as not constituting medical advice.

Customer Use Requirements for Modified Retention

To comply with the Modified Retention Amendment, the Platform is configured so that:

a) AI conversations are restricted to health, fitness, nutrition, and programme-related topics.

b) All end users are authenticated using email one-time passwords and biometric authentication.

c) Content moderation, safety guardrails, and monitoring are in place.

d) Off-topic requests are redirected to permitted topics.

e) Coaching recommendations are escalated for human review before delivery to clients.

ElevenLabs: Text-to-Speech

ElevenLabs receives only the text of AI-generated replies for conversion to speech. It does not receive:

a) User personal data or health data

b) Conversation history or context

c) Client profiles or coaching data Data sent to ElevenLabs is retained in accordance with ElevenLabs’ own privacy policy and data processing terms.

AI Limitations and Accuracy

IMPORTANT: AI outputs are assistive only. AI-generated content may contain errors, inaccuracies, or omissions. AI outputs should not be relied upon as the sole basis for any decision, particularly decisions relating to health, fitness, nutrition, or wellbeing. THE AREELA PLATFORM AND ITS AI FEATURES DO NOT PROVIDE MEDICAL ADVICE. AI-GENERATED CONTENT IS NOT A SUBSTITUTE FOR PROFESSIONAL MEDICAL ADVICE, DIAGNOSIS, OR TREATMENT. ALWAYS SEEK THE ADVICE OF A QUALIFIED HEALTHCARE PROVIDER WITH ANY QUESTIONS REGARDING A MEDICAL CONDITION. THIS DISCLAIMER SHOULD BE READ TOGETHER WITH THE END USER LICENCE AGREEMENT.

Beta Status

Areela is beta AI and can make mistakes. The AI features on the Platform are under active development and improvement. Users should exercise independent judgement and verify AI outputs where appropriate.

AI Reasoning

Where AI generates recommendations, such as workout suggestions, nutrition guidance, or check-in insights, the AI provides explanatory reasoning alongside its output. This reasoning explains the basis for the recommendation, including relevant data points and considerations, to help coaches and clients understand and evaluate the AI’s suggestions.

Guardrails and Safety Measures

We implement the following guardrails to ensure safe and appropriate AI behaviour:a) Content review: AI-generated content is reviewed before display to filter inappropriate, harmful, or off-topic material

b) Topic redirection: AI assistants are configured to redirect conversations that stray outside the scope of health, fitness, nutrition, and coaching back to relevant topics

c) Content filtering: Inappropriate, harmful, or dangerous content is automatically removed or rewritten by the AI system before being presented to users

d) Coaching escalation: Where AI generates coaching recommendations that warrant human review, these are escalated to the coach for approval before being delivered to the client

e) Medical disclaimer: AI outputs include appropriate disclaimers where health-related content is generated Human Oversight The Platform does not implement general human-in-the-loop (HITL) review for all AI processing. However, the following human oversight mechanisms are in place:

a) Coaching recommendations generated by AI are escalated for coach review before delivery to clients

b) Coaches retain full override authority over all AI-generated content and recommendations relating to their clients

c) Users (coaches and clients) can provide feedback on AI outputs, which is used to improve system prompts and guardrails

d) ME24 Limited’s development team monitors AI performance and safety metrics on an ongoing basis User Rights in Relation to AI You have the following rights in relation to AI processing on the Platform:

a) Contest or correct AI outputs: If you believe an AI output is incorrect, inappropriate, or harmful, you can flag it for review.

b) Provide feedback: You can provide feedback on AI outputs to help us improve the system.

c) Report issues: You can report AI-related issues, concerns, or bugs to support@areela.com.

d) Choose not to use optional AI features: Non-AI alternatives, including manual programme creation, workout building, food logging, activity logging and messaging, remain available. Where the relevant control is available, users may disable AI assistants in settings; coaches may also request that AI processing be disabled for an account or client by contacting support@areela.com. No opt-out from OpenAI model training is necessary because OpenAI does not use user data to develop or improve its services under the Modified Retention Amendment and the OpenAI Enterprise Agreement. This does not limit the separate right to opt out of optional AI features or request that AI processing be disabled as described above.

EU AI Act Obligations

The AI features of the Areela platform use general-purpose AI models provided by OpenAI. ME24 Limited applies the transparency, risk-management and human-oversight principles relevant to the EU AI Act (Regulation (EU) 2024/1689) and maintains records supporting the classification and governance of each AI feature. Transparency: Users must be clearly informed when they are interacting with an AI assistant or receiving AI-generated content. AI-generated outputs and recommendations are identified as assistive and are accompanied by appropriate limitations and medical disclaimers. AI feature classification: ME24 Limited classifies each feature by intended purpose and risk. On the current assessment, the features are assistive fitness, nutrition and coaching tools and are not intended to make high-risk automated decisions or decisions producing legal or similarly significant effects. Human oversight: Coaching recommendations are escalated for coach review before delivery to clients; coaches retain override authority; users may flag outputs; and ME24 Limited monitors AI performance, safety metrics, prompts and guardrails. Documentation and risk management: ME24 Limited maintains records of the models, intended purposes, risk assessments, fundamental-rights considerations, safeguards and mitigation measures for its AI deployments, and reviews them when features or applicable requirements change.

UK AI Governance Framework

ME24 Limited aligns its use of AI with the UK’s AI governance framework and the Information Commissioner’s Office (ICO) guidance on AI and data protection. Specifically:

a) We conduct Data Protection Impact Assessments (DPIAs) for high-risk AI processing activities.

b) We ensure that AI processing is lawful, fair, and transparent.

c) We implement appropriate technical and organisational measures to protect personal data processed by AI systems.

d) We maintain accountability records demonstrating compliance with data protection requirements for AI processing.

Logging and Monitoring

AI interactions and system behaviour are logged as follows:

Changes to This Policy

We may update this Policy from time to time. The most current version will be available at areela.com/legal. Where we make material changes, we will provide at least 30 days’ advance notice by: (a) displaying a prominent notice on the Platform; (b) sending an email to the address associated with your account; or (c) both. Material changes include changes that affect: your rights and obligations; how your personal data is processed; the scope of services or features available to you; or any other matter that could reasonably be expected to affect your use of the Platform.