Privacy Policy

Ascendward, LLC, doing business as Togethium (“Togethium,” “we,” “us,” or “our”), respects the privacy of people who visit our website, use the Togethium mobile application, or otherwise use our related services (collectively, the “Service”). This Privacy Policy explains the information we collect, how we use and disclose it, and the choices available to you.

Togethium is a peer-support service, not a health-care provider, therapy service, or medical service. Certain information processed through the Service may nevertheless be considered “consumer health data” under broadly defined state privacy laws. Togethium is not professional counseling, a crisis line, or an emergency service.

The Service is offered only to people who are at least 18 years old and are located in the United States.

Account Information

When you create an account, we collect your email address, display name, account identifiers, and account-related dates and times. Our authentication provider processes your password and related security information. Togethium does not store your password in readable form.

We ask for your date of birth to determine whether you are at least 18 years old. We use the date only to make that determination and do not retain the full date of birth. We may retain the eligibility result, the date and method of the check, and records showing the versions of our legal terms and notices that you accepted.

Circle and Session Information

When you use Togethium, we may collect the predefined circle topic you select, queue and matching information, random meeting identifiers, participant assignments, join and leave times, connection status, turn information, and other information needed to operate and secure a circle. Togethium does not provide users with an attendance or topic history or use topic history to make recommendations.

These records may show that you used a peer-support service or selected a particular support topic and may therefore be considered sensitive information or consumer health data under some state laws.

Live Audio

When you join a circle, your voice is transmitted live to the other participants through our live-audio provider. Togethium does not record, transcribe, or retain the contents of circle audio. We do not create voiceprints or use your voice to identify you biometrically.

We or our live-audio provider may process limited technical information needed to connect or troubleshoot a session, such as a random meeting identifier, connection time, device or network information, and connection quality.

Other participants can hear what you say. Although our rules prohibit participants from recording or redistributing circle conversations, we cannot guarantee that every participant will follow those rules.

Circle Safety Information

Togethium does not provide a written or narrative reporting system or a user blocking workflow. We may process limited session, turn, skip, cooldown, restriction, ban, and appeal information created through features that are available in the Service.

Communications, Feedback, Surveys, and Waitlists

We collect information you provide when you contact us, request support, provide feedback, respond to a survey, appeal a restriction, submit a privacy request, or join our waitlist. Our waitlist collects an email address. If you provide feedback or ideas, we may use them to operate, improve, and develop the Service as described in our Terms of Service.

Purchases and Subscriptions

If you make a purchase, Apple, Google, a website payment processor, or a subscription-management provider may process the transaction. We may receive information such as the product purchased, subscription status, transaction or receipt identifier, payment status, and renewal or cancellation information. Togethium does not receive or store your full payment-card or bank-account number.

Usage and Technical Information

When you visit our website or use the app, we and providers that help us operate the Service may collect information such as your IP address, approximate location inferred from your IP address, device type, operating system, browser type, app version, device or app identifiers, referring page, pages or screens viewed, features used, access dates and times, cookies, security logs, crash information, and other diagnostic or performance information.

We may use cookies and similar technologies on our website to operate the site, remember preferences, understand use, and improve performance. You can control cookies through your browser settings, although disabling them may affect some website features.

We may use information to:

• create, authenticate, maintain, secure, and support accounts;
• confirm that users meet the age requirement;
• match participants and operate live circles;
• transmit live audio to the intended participants;
• operate available safety features and apply or review restrictions and bans;
• process purchases and administer subscriptions;
• respond to support messages, feedback, surveys, appeals, and privacy requests;
• send account, transaction, security, service, waitlist, survey, and marketing communications;
• monitor performance, troubleshoot problems, conduct analytics, and improve or develop the Service;
• prevent and address fraud, abuse, unauthorized access, evasion, illegal activity, and security incidents;
• enforce our Terms of Service and Community Rules;
• comply with law and legal process and establish, exercise, or defend legal claims; and
• protect the rights, property, and safety of Togethium, our users, and others.

Because Togethium does not record or retain circle audio, we do not use circle audio content for advertising, profiling, transcription, content analysis, or artificial-intelligence training.

We may share information as follows:

Other Circle Participants

People in your circle receive your display name, your live voice, and limited information needed to show that you are present in the circle. Employees and volunteers who use Togethium participate as ordinary users and do not receive special information or access merely because of that relationship.

Service Providers

We may share information with companies that help us provide the Service, such as providers of authentication, database infrastructure, hosting, website delivery, live audio, security, analytics, diagnostics, email, customer support, surveys, payment processing, and subscription management. These providers may process information as needed to perform services for us.

App Stores and Payment Providers

Apple, Google, payment processors, and subscription providers may process purchases under their own terms and privacy policies. We may exchange limited transaction and subscription information with them to provide purchased features, verify payment status, and respond to billing issues.

Legal, Security, and Safety Reasons

We may preserve or disclose available information if we reasonably believe it is necessary or permitted to comply with law or legal process; respond to a lawful government request; investigate or prevent fraud, abuse, illegal activity, or a security incident; enforce our agreements; protect the rights, property, or safety of Togethium, our users, or others; or establish, exercise, or defend legal claims.

Togethium does not monitor every conversation and does not operate an emergency-reporting system. If we independently receive credible information indicating an imminent threat of serious harm, we may disclose available information to emergency services or law enforcement when permitted or required by law. We cannot guarantee that we can identify or locate a person or arrange emergency assistance.

Business Transactions

Information may be disclosed as part of a financing, merger, acquisition, reorganization, sale of assets, bankruptcy, or similar business transaction, subject to applicable law.

At Your Direction

We may share information when you request or authorize us to do so.

We do not sell personal information, share personal information for cross-context behavioral or targeted advertising, disclose personal information to data brokers, or use personal information to train artificial-intelligence models.

We use reasonable administrative, technical, and organizational measures designed to protect personal information. No security measure or method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

We retain information for as long as reasonably needed to provide, operate, secure, support, and enforce the Service; process transactions; comply with legal, accounting, or reporting requirements; resolve disputes; prevent fraud, abuse, or ban evasion; and protect our rights and users.

Togethium does not retain the contents of live circle audio.

If you delete your account, we will endeavor to remove your account and personal information that we no longer need from our active systems within 14 days. We may retain limited information when reasonably needed for legal compliance, transactions and accounting, disputes or claims, fraud and security, enforcement of our Terms and Community Rules, prevention of ban circumvention, or protection of rights and safety. We may retain a limited record concerning a banned user when reasonably necessary to address a future threat or evasion risk. Information may remain temporarily in restricted backups until those backups are overwritten through normal processes.

Deleting the Togethium app does not delete your account. Deleting your Togethium account also does not automatically cancel a subscription purchased through Apple or Google; you must manage that subscription through the applicable app store.

You may update your display name through the Service when that feature is available. You may unsubscribe from marketing emails by using the unsubscribe link in the message or contacting us. We may still send nonmarketing messages concerning your account, purchases, security, legal notices, or the Service.

Depending on where you live and subject to applicable exceptions, you may have the right to request access to, correction of, or deletion of personal information; receive a copy of certain information; learn about how information is collected, used, or disclosed; withdraw consent where processing depends on consent; and appeal our refusal to act on a request. We will not discriminate against you for exercising an applicable privacy right.

You may request account deletion through the in-app Settings flow or our website Account Deletion page. You may submit another privacy request or appeal by emailing hi@togethium.com with the subject “Togethium Privacy Request.” We may take reasonable steps to verify your identity or authority before completing a request.

Togethium accounts and circles are not directed to or available to anyone under 18. If we learn that someone under 18 has created an account or provided personal information through the account service, we may suspend the account and delete the information as appropriate. If you believe a person under 18 is using Togethium, please contact us.

The Service may contain links to independent websites or resources, including emergency and crisis resources. This Privacy Policy does not govern the privacy practices of third parties. Information processed independently by an app store, payment provider, or other third party is subject to that party’s privacy policy.

Our providers may process information in the United States or other locations where they operate, subject to applicable law.

We may update this Privacy Policy as the Service, our practices, or the law changes. When we do, we will update the date at the top of the Policy. If a change is material, we may provide additional notice through the Service or by email and obtain consent when required by law.

If you have questions, requests, or complaints about this Privacy Policy or our privacy practices, contact us at:

Effective: August 8, 2026

Ascendward, LLC, doing business as Togethium (“Togethium,” “we,” “us,” or “our”), provides this Consumer Health Data Privacy Policy to supplement the Togethium Privacy Policy. This Policy applies only to the extent that information we process is considered “consumer health data” under applicable U.S. state privacy laws.

Togethium is a peer-support service. Togethium is not a healthcare provider, mental-health provider, medical provider, therapist, professional counselor, clinical service, crisis line, or emergency service. Togethium does not diagnose, treat, cure, or prevent any medical or mental-health condition. The fact that certain information may be legally defined as consumer health data does not mean that Togethium provides healthcare or that the information is protected health information under HIPAA.

Consumer Health Data We Collect

Depending on how you use Togethium, the following information may be considered consumer health data when it is linked or reasonably linkable to you:

Account and Eligibility Information

Your email address, display name, account identifier, account dates and times, and adult-eligibility result may be considered consumer health data when connected to your use of a peer-support service. We use your date of birth only to determine whether you are at least 18 and do not retain the full date of birth.

Circle and Session Information

We may process the predefined peer-support topic you select, queue and matching information, random meeting identifiers, participant assignments, join and leave times, connection status, turn information, and related information needed to operate and secure a circle. This information may show that you sought or used a peer-support service or selected a particular support topic.

Togethium does not provide users with an attendance or topic history and does not use topic history to make recommendations.

Live Audio

When you join a circle, our live-audio provider processes and transmits your voice in real time so the other participants can hear you. Live audio may include information about emotional, mental-health-related, or other personal experiences that you choose to discuss.

Togethium does not record, transcribe, or retain the contents of circle audio. We do not create voiceprints or use your voice for biometric identification, diagnosis, profiling, advertising, content analysis, or artificial-intelligence training.

Circle Safety Information

Togethium does not provide a written or narrative reporting system or a user blocking workflow. We may process limited session, turn, skip, cooldown, restriction, ban, and appeal information created through features that are available in the Service.

Communications and Feedback

Information you choose to provide in support messages, feedback, surveys, restriction appeals, privacy requests, or other communications may be considered consumer health data if it concerns your health, wellbeing, emotional experiences, or use of the Service.

Transaction, Usage, and Technical Information

Transaction or subscription information, IP address, approximate location inferred from IP address, device or app identifiers, pages or screens viewed, feature interactions, access times, connection diagnostics, analytics information, and crash or performance information may be considered consumer health data when they identify or can reasonably be linked to your use of Togethium.

We do not collect precise location for health-related purposes or use location to identify visits to healthcare or mental-health facilities.

Sources of Consumer Health Data

We may collect consumer health data:

• directly from you, including through account creation, circle selections, live audio, support, feedback, surveys, appeals, and privacy requests;
• automatically from your device and use of the website or app;
• from providers that help us operate Togethium, such as authentication, database, hosting, live-audio, security, analytics, diagnostics, email, support, payment, and subscription providers.

We do not obtain consumer health data from data brokers or public databases.

How We Use Consumer Health Data

We may use consumer health data to:

• create, authenticate, secure, maintain, and support accounts;
• confirm adult eligibility;
• place participants in queues, match participants, and operate circles;
• transmit live audio to the intended circle participants;
• operate available safety features and apply or review restrictions and bans;
• process purchases and administer subscriptions;
• provide support and respond to feedback, surveys, appeals, and privacy requests;
• operate, secure, troubleshoot, analyze, improve, and develop the Service;
• prevent fraud, abuse, unauthorized access, ban evasion, illegal activity, and security incidents;
• enforce our Terms of Service and Community Rules;
• comply with law and legal process and establish, exercise, or defend legal claims; and
• protect the rights, property, and safety of Togethium, our users, and others.

We do not use consumer health data to diagnose or treat a condition or to provide medical, therapeutic, or professional counseling services. We do not use consumer health data for targeted advertising or to train artificial-intelligence models.

How We Share Consumer Health Data

We may share consumer health data with the following categories of recipients:

Other Circle Participants

People in your circle receive your display name, live voice, and limited presence or circle-status information needed to provide the circle. Other participants may hear health-related or personal information that you choose to say. Our rules prohibit recording and redistribution, but we cannot guarantee that every participant will comply.

Employees and volunteers who use Togethium participate as ordinary users. They do not receive special information or administrative access merely because of their relationship with Togethium.

Service Providers

Providers may process consumer health data on our behalf when they help us with authentication, databases, hosting, website delivery, live audio, security, analytics, diagnostics, email, support, surveys, payment processing, or subscription management. We provide them only the information reasonably needed for their services.

App Stores and Transaction Providers

Apple, Google, payment processors, and subscription providers may process limited purchase, receipt, and subscription information to complete transactions, provide purchased features, verify payment status, and respond to billing issues. Their independent processing is governed by their own privacy policies.

Legal, Security, and Safety Recipients

We may preserve or disclose available information when we reasonably believe it is necessary or permitted to comply with law or legal process; respond to a lawful government request; investigate or prevent fraud, abuse, illegal activity, or a security incident; enforce our agreements; protect rights, property, or safety; or establish, exercise, or defend legal claims.

Togethium does not monitor every conversation and does not operate an emergency-reporting system. If we independently receive credible information indicating an imminent threat of serious harm, we may disclose available information to emergency services or law enforcement when permitted or required by law. We cannot guarantee that we can identify or locate a person or arrange emergency assistance.

Business Transactions and Your Direction

Consumer health data may be disclosed as part of a financing, merger, acquisition, reorganization, sale of assets, bankruptcy, or similar transaction, subject to applicable law. We may also share information with a recipient you request or authorize.

Ascendward currently has no affiliate with which it shares consumer health data.

We do not sell consumer health data, disclose it to data brokers, share it for cross-context behavioral or targeted advertising, or use it to train artificial-intelligence models. We do not permit a provider receiving consumer health data from us to use it to track you over time across unaffiliated websites or online services for that provider’s own advertising purposes.

Consent and Declining to Provide Information

Where applicable law requires consent, and processing is not otherwise permitted as necessary to provide a product or service you requested, we will request your affirmative consent before collecting or sharing consumer health data. A request to share consumer health data will be separate from a request to collect it when required by law. This Policy itself is a notice and is not a substitute for a separate consent where one is legally required.

You may decline to provide optional information. However, Togethium must process certain account, session, live-audio, and technical information to provide a live circle. If you decline or withdraw permission for processing that is necessary to provide the Service, some or all of the Service may be unavailable.

Your Consumer Health Data Rights

Depending on applicable law and subject to legal exceptions, you may have the right to:

• confirm whether we collect, share, or sell your consumer health data;
• access or receive a copy of your consumer health data;
• correct inaccurate consumer health data;
• request deletion of consumer health data;
• withdraw consent to future collection or sharing where we rely on consent;
• receive a list of third parties and affiliates, if any, with which we shared or sold your consumer health data, together with available contact information; and
• appeal our refusal to act on a request.

You may submit a request by emailing hi@togethium.com with the subject “Consumer Health Data Request.” Account deletion is also available through the in-app Settings flow and our website Account Deletion page. If we deny a request, you may appeal by emailing the same address with the subject “Consumer Health Data Appeal.”

We may take reasonable steps to authenticate your identity and authority before completing a request. We will respond within the period required by applicable law and will not discriminate against you for exercising an applicable privacy right.

Retention and Deletion

We retain consumer health data only for as long as reasonably needed for the purposes described in this Policy, including providing, operating, securing, supporting, and enforcing the Service; processing transactions; complying with law; resolving disputes; preventing fraud, abuse, or ban evasion; and protecting rights and safety.

Togethium does not retain the contents of live circle audio.

Following a valid account-deletion request, we will endeavor to remove your account and consumer health data that we no longer need from active systems within 14 days. We may retain limited information when reasonably necessary for legal compliance, transactions and accounting, disputes or claims, fraud and security, enforcement, prevention of ban circumvention, or protection of rights and safety. We may retain a limited record concerning a banned user when reasonably necessary to address a future threat or evasion risk.

Information may remain temporarily in restricted backups. We will complete deletion from backups within the period required by applicable law, including within six months after authentication of a qualifying Washington consumer-health-data deletion request. We will notify relevant providers and other recipients of a deletion request when required by law.

Security

We use reasonable administrative, technical, and organizational measures designed to protect consumer health data. We limit access to people and providers who reasonably need it for the purposes described in this Policy. No security measure or method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

Changes to This Policy

We may update this Policy as the Service, our practices, or the law changes. We will update the effective date when we do. If a change is material, we may provide additional notice through the Service or by email. We will obtain affirmative consent before collecting, using, or sharing new categories of consumer health data or using existing consumer health data for materially different purposes when required by law.

Contact Us

Questions, requests, or complaints concerning this Policy or our consumer-health-data practices may be sent to: