Terms of Service

This Privacy Policy, Terms of Service, and Data Governance document explains how Pragma collects, uses, and protects your information, the rules governing your use of the site and community, and the privacy and security practices — including HIPAA-aligned safeguards — that apply to your health-related data. Please read it carefully before using the Service, as it governs your relationship with Pragma.

Pragma is operated by Pear Partners LLC, a Delaware limited liability company doing business as "Pragma" ("Pragma," "Pear Partners," "we," "us," or "our"). We operate the website located at https://www.pragmahealth.ai (the "Site") and the associated mobile-responsive application, community features, tracker, healthcare-professional verification program, and related services (collectively, the "Service").

Registered address: 8 The Green, Suite A, Dover, DE 19901

General contact: hello@pragmahealth.ai

• "Service" means the Site, the intake and recommendation experience, the daily tracker/check-in tools, the community feed, the HCP verification portal, the brand/supplement partner portal, and any related features Pragma makes available.
• "Recommendation Engine" or "Engine" means the rules-based, artificial-intelligence-assisted system Pragma uses to synthesize a user's inputs into personalized nutrition and supplement guidance, described further in Part II, Section 2 and Part III, Section 4.
• "Consumer" or "User" means an individual who uses the Service to receive personalized nutrition or supplement guidance.
• "HCP" means a licensed healthcare professional (e.g., MD, DO, RD/RDN, DCN, NP, PA, CNM, PharmD, or other licensed practitioner) who participates in Pragma's HCP verification program.
• "Personal Information" means information that identifies, relates to, or could reasonably be linked with an identified or identifiable individual.
• "Health Information" or "Consumer Health Data" means Personal Information that identifies a consumer's past, present, or future physical or mental health status, including reproductive or hormonal health status, and is used to identify a consumer's health status, consistent with the usage of that term under applicable state consumer health data laws.
• "De-Identified Data" or "Aggregate Data" means information that has been processed so that it can no longer reasonably be used to identify an individual, and that Pragma maintains and uses only in de-identified or aggregated form, as described in Part III, Section 5.

Please read these Terms of Service ("Terms") carefully before using the Service. By accessing or creating an account on the Service, you agree to be bound by these Terms, our Privacy Policy (Part III), and our HIPAA-Aligned Data Practices (Part IV). If you do not agree, do not use the Service.

Pragma is a recommendation layer for nutrition and supplement guidance, built to reflect a user's life stage and hormonal health context (for example, perimenopause, hormonal birth control use, GLP-1 medication use, or the postpartum period). The Service is brand-agnostic: Pragma does not sell its own supplements, and affiliate relationships (Section 10) never influence which products are recommended or how they are ranked.

Recommendations are generated by our Recommendation Engine, which combines:

• a rules-based clinical logic layer built on Pragma's three-lane evidence model (Lane 1–3 classification of evidence strength), under which safety findings can downgrade or override a recommendation regardless of its efficacy evidence, with every entry reviewed and approved by Pragma's Registered Dietitian clinical leadership and higher-complexity entries additionally referred to Pragma's Clinical Advisory Board for consultation;
• training and reference material drawn from open-source, peer-reviewed, and other publicly available health and nutrition publications, curated and subject to internal scientific-quality guardrails; and
• proprietary clinical content and protocols developed by, and vetted by, licensed healthcare professionals engaged by Pragma, including members of its Clinical Advisory Board.

Certain Engine functions, such as extracting structured values from a lab document you upload, are performed with the assistance of a third-party AI/large-language-model provider (currently Anthropic), operating under contractual data-protection terms described in Part IV. Every recommendation rule is reviewed and approved by Pragma's Registered Dietitian clinical leadership before it goes live, and the Engine is designed so that recommendations remain auditable back to the evidence and rule that produced them (shown to users as a "why this, for you" explanation and rule reference).

You must be at least 18 years old to use the Service. By using the Service, you represent that you meet this requirement and that any information you provide is accurate.

If the Service requires account creation, you agree to provide accurate and complete information, maintain the confidentiality of your login credentials, and notify us promptly of any unauthorized use of your account. You are responsible for activity that occurs under your account.

As part of onboarding and ongoing use, you may choose to provide information such as your life stage, symptoms, medications and prescriptions (including pregnancy or nursing status, which we use as a gating input to suppress or flag unsafe recommendations), laboratory results (either uploaded as a document, which our systems use AI to extract into structured data, or entered manually), current supplements, dietary preferences, budget, and goals. Providing this information is voluntary, but the Service's ability to personalize recommendations depends on the depth of information you share.

You acknowledge and agree that:

• recommendations are generated using a combination of automated, rules-based logic and, where noted, generative AI, and are provided for general informational and educational purposes only;
• Pragma does not warrant that recommendations will be complete, accurate, or suitable for your specific health needs, and recommendations should never be treated as a diagnosis or prescription;
• flagged or higher-risk scenarios (for example, potential medication interactions) are designed to be routed to "provider questions" framing that encourages you to raise the topic with a licensed clinician, rather than being resolved by the Engine alone; and
• Pragma's Clinical Advisory Board and Registered Dietitian staff periodically review flagged Engine outputs and rule performance, but this review does not constitute individualized medical review of your specific situation.

The Service includes a community feed where users may read, post, and reply to threads organized by topic (for example, perimenopause, birth control, GLP-1, postpartum, labs, and general wellness). You may choose to post anonymously or under a named profile.

• Verified HCP replies are visually badged with the HCP's credential and general practice area, consistent with Part V of this document.
• You agree not to use the community to give or solicit individualized medical advice, promote unsafe peer-to-peer dosing, or misrepresent your identity, credentials, or health information in a way intended to manipulate the Engine or other users.
• Pragma reserves the right to moderate, remove, or restrict content, including content that appears to involve misinformation, unsafe supplement "stacking" or dosing advice, or a mental health or safety crisis. Community moderation is not a substitute for emergency services; if you are in crisis, contact local emergency services or an appropriate crisis line.
• User-generated content reflects the views of the poster, not Pragma, and Pragma is not responsible for the accuracy of content posted by other users, including HCPs posting in their personal capacity.

Licensed healthcare professionals may apply for "Verified HCP" status to unlock community privileges, including the ability to reply with their credentials displayed. Participation in the HCP program is governed by this Section and by the HCP Data Addendum in Part V, which is incorporated into these Terms by reference. HCP applicants and Verified HCPs agree to the credential collection, verification, and public-display requirements described in Part V.

Pragma currently offers a free tier (personalized Foundation Stack, daily check-in tracker, and monthly protocol reviews), a Plus tier (ongoing recommendation updates and priority protocol reviews), and a Premium tier (advanced genetic and lab analysis, where genetic and laboratory testing are external services not included in the subscription price). Pragma also offers a one-time, fee-based Pragma Report. Pricing, tier features, and the Report fee are as displayed on the Site at the time of purchase and may change with notice. Subscriptions automatically renew at the then-current price for successive periods equal to your initial term unless you cancel before the renewal date through your account settings; cancellation takes effect at the end of the current billing period, and fees already paid are non-refundable except where required by law. Where required by applicable law — including California's Automatic Renewal Law and Connecticut's automatic renewal statute — we will provide clear notice of these auto-renewal terms, advance notice of any material changes, and an easy means of cancellation.

Pragma is brand-agnostic by design. We do not sell our own supplements. Where we link to a third-party product, we evaluate it on dose, form, and evidence first; if the product has an affiliate program, we use it and label the link. Affiliate relationships do not influence which products are recommended or how they are ranked, and help fund the free tier of the Service.

Supplement brands and manufacturers may participate in Pragma's partner program under separate non-disclosure and evaluation agreements. Product and formulation information shared by brands for evaluation purposes is kept confidential; specific dosing thresholds used in Pragma's clinical evaluation pipeline are not disclosed publicly or to competing brands. Brand participation does not guarantee inclusion in, or favorable placement within, Pragma's recommendations.

You agree not to:

• use the Service for any unlawful purpose;
• attempt to gain unauthorized access to the Service or its systems, including the Recommendation Engine's underlying rules or training content;
• interfere with or disrupt the integrity or performance of the Service;
• reverse engineer, scrape, or misuse the Service's content, HCP directory, or underlying technology; or
• misrepresent your identity, credentials, or health information in a way intended to manipulate recommendations for your own or another person's consumption.

All content, features, and functionality of the Service — including text, graphics, logos, the Recommendation Engine's rule logic and outputs, and software — are owned by Pear Partners LLC or its licensors and are protected by intellectual property laws. You may not copy, modify, distribute, or create derivative works without our prior written consent.

The Service may reference or link to third-party products, brands, laboratories, genetic testing services, or wearable-device platforms. Pragma does not endorse and is not responsible for the content, accuracy, or practices of third parties. Any dealings with third parties, including any purchase of a linked product or external test, are solely between you and them.

THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. WE DO NOT WARRANT THAT THE SERVICE WILL BE UNINTERRUPTED, ERROR-FREE, OR THAT RECOMMENDATIONS — INCLUDING THOSE GENERATED WITH THE ASSISTANCE OF ARTIFICIAL INTELLIGENCE — WILL BE ACCURATE, COMPLETE, OR SUITABLE FOR YOUR SPECIFIC HEALTH NEEDS.

TO THE FULLEST EXTENT PERMITTED BY LAW, PEAR PARTNERS LLC AND ITS AFFILIATES, OFFICERS, EMPLOYEES, AND PARTNERS SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF PROFITS, DATA, OR GOODWILL, ARISING FROM YOUR USE OF THE SERVICE, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

To the maximum extent permitted by law, Pragma's total liability arising out of or relating to these Terms or the Service will not exceed the greater of (a) the amounts you paid to Pragma in the twelve (12) months preceding the claim, or (b) one hundred dollars ($100).

You agree to indemnify and hold harmless Pear Partners LLC from any claims, damages, liabilities, and expenses (including legal fees) arising from your use of the Service, your violation of these Terms, or your violation of any third-party rights, including, for HCPs, any claims arising from clinical content or advice you provide within the community.

We may suspend or terminate your access to the Service at any time, with or without cause or notice, including for violation of these Terms or, for HCPs, loss of licensure or violation of the HCP Data Addendum.

These Terms are governed by the laws of the State of Delaware, without regard to conflict-of-law principles. Any dispute arising out of or relating to these Terms or the Service shall be brought exclusively in the state or federal courts located in the State of Delaware, and you consent to personal jurisdiction and venue there.

We may modify or discontinue the Service, or update these Terms, at any time. We will update the "Last Updated" date above when changes are made. Continued use of the Service after changes constitutes acceptance of the revised Terms.

Questions about these Terms should be directed to Pear Partners LLC d/b/a Pragma, 8 The Green, Suite A, Dover, DE 19901, hello@pragmahealth.ai.

This document is organized into Parts for clarity, but Parts II (Terms of Service), III (Privacy Policy), IV (HIPAA-Aligned Data Practices), and V (HCP Data Addendum) together form a single agreement between you and Pragma. In the event of a direct conflict between Parts on a given topic, the more specific provision controls (for example, Part V controls over Part III on HCP-specific data questions).

If any provision of this document is held invalid or unenforceable, that provision will be limited or eliminated to the minimum extent necessary, and the remaining provisions will remain in full force and effect.

Our failure to enforce any right or provision of this document will not be considered a waiver of that right or provision.

You may not assign or transfer these Terms without our prior written consent. We may assign or transfer these Terms without restriction, including in connection with a merger, acquisition, or sale of assets.

Pragma will not be liable for any failure or delay in performance resulting from causes beyond its reasonable control.

We may provide notices to you via email, through the Service, or by posting on the Site. You may provide notice to us at the contact information below.

Pear Partners LLC d/b/a Pragma
8 The Green, Suite A, Dover, DE 19901, hello@pragmahealth.ai