User Agreement — Neiry Pulse

Effective date: June 24, 2026 Last updated: June 24, 2026

1. General Provisions

1.1. This User Agreement (the “Agreement”) governs the relationship between the Operator and the user (the “User”) of the Neiry Pulse mobile application and related services (the “Services”).

Depending on the channel through which the User obtained the application, the Operator is:

1.2. Use of the Operator’s Services constitutes full and unconditional acceptance by the User of the terms of this Agreement. If the User does not agree with the terms of the Agreement, the User must discontinue using the Services.

1.3. This Agreement has been drawn up in accordance with the legislation of the Russian Federation, including Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (“FZ-152”).

1.4. The Services are intended for healthy adults aged 16 or older. The Services are not intended for children under 16 or for individuals in clinical care.

2. Rights and Obligations of the Parties

2.1. Rights and obligations of the Operator:

2.1.1. To provide access to the Services and ensure their proper functioning in accordance with this Agreement.

2.1.2. To process the User’s personal data in accordance with this Agreement and the Privacy Policy available at https://pulse.neiry-bci.com/privacy-policy/.

2.1.3. To notify Users of changes to the terms of this Agreement by notifications in the application or by email.

2.1.4. To take measures to protect the confidentiality and security of the User’s personal data.

2.2. Rights and obligations of the User:

2.2.1. To provide accurate and current personal data during registration and use of the Services.

2.2.2. Not to use the Services for unlawful purposes and not to violate the rights of third parties, including intellectual property rights.

2.2.3. To comply with the terms of this Agreement and the Privacy Policy.

2.2.4. To have the right to access, correct and delete their personal data, as well as to withdraw consent to its processing.

3. Rules for Using the Services

3.1. The Operator’s Services are designed to track the User’s wellness and fitness indicators (heart rate variability, heart rate, sleep phases, activity) using a compatible Neiry wearable device, calculate the User’s personal baseline, and provide general wellness recommendations.

3.2. The Services are a wellness and fitness tool, not a medical device. The Services are classified under the Health & Fitness category in both the Apple App Store and Google Play, not under Medical. The Services are not intended to diagnose, treat, cure, mitigate, monitor, or prevent any disease, injury or medical condition; they are not intended for clinical decision-making; and they are not intended for use by patients in clinical contexts. The Services are designed for general wellness and fitness tracking by healthy adults. The information and recommendations provided by the Services are for general informational purposes only and do not replace consultation with a qualified healthcare professional. The User should consult a qualified healthcare professional for any health-related questions or before making decisions that may affect their health.

3.3. The Operator’s applications may use data on biometric parameters (HRV, heart rate, R-R intervals, IMU, sleep phases, SpO2), as well as GPS location data solely in training mode, started by explicit action of the User.

3.4. To access the functionality of the Services, the User registers with an email address and password.

3.5. The User undertakes not to transfer their account credentials to third parties and is responsible for the security of their account.

3.6. The Operator reserves the right to restrict access to the Services in case of violation by the User of the terms of this Agreement.

4. Intellectual Property

4.1. All rights to software, graphic materials, texts, logos and other elements placed on the Services belong to the Operator or its licensors and are protected by the legislation of the Russian Federation. The trademark "neiry" (Russian Federation Certificate No. 981484) is owned by LLC "Neiry" (ООО «Нейри»; OGRN 1197746458073, INN 9701140612, registered address: 105082, Moscow, Bakuninskaya str., 73, building 2, Russian Federation). Use of the "Neiry" brand and the "Neiry Pulse" product name by the Operators is conducted under a licensing authorization from the rightsholder.

4.2. The User may not copy, distribute, modify, transmit or otherwise use the content of the Services without the prior written consent of the Operator.

4.3. Health-related data and other personal data generated by the User when using the Services (HRV indicators, training records, etc.) remain the property of the User. The Operator processes them in accordance with the Privacy Policy.

5. Limitation of Liability

5.1. The Operator is not liable for any direct or indirect damage caused as a result of use or inability to use the Services, including data loss, disruption of equipment operation, connection failures, or actions of third parties.

5.2. The Operator is not liable for the correct operation of the Services and devices if they were used for purposes other than intended or in violation of the Operator’s recommendations.

5.3. The Operator does not verify and is not responsible for the accuracy of personal data provided by the User.

5.4. Accuracy of wellness measurements. The Neiry wearable device and Services use optical photoplethysmography (PPG) sensors and inertial measurement units (IMU) to calculate wellness and fitness indicators. The accuracy of these indicators depends on the correct positioning of the device on the wrist, the User’s physiological characteristics, activity at the time of measurement, and the condition of the device. The Operator does not warrant the clinical or medical accuracy of measurements (the Services are wellness, not medical) and is not responsible for decisions made by the User regarding their health on the basis of this data.

6. Changes to the Agreement

6.1. The Operator reserves the right to make changes to this Agreement. Changes take effect upon their publication on https://pulse.neiry-bci.com/user-agreement/, unless otherwise specified in the new version of the Agreement.

6.2. The Operator shall notify Users of changes to the Agreement by publication on the website, and for material changes — also through the Application.

7. Termination of the Agreement

7.1. This Agreement is valid as long as the User uses the Operator’s Services.

7.2. The User may terminate use of the Services and delete their account at any time through the application settings (Settings → Privacy → Delete Account) or by sending a request to privacy@neiry-bci.com.

7.3. The Operator reserves the right to terminate this Agreement in case of violation by the User of its terms, with notification via the email provided at registration.

8. Dispute Resolution

8.1. All disputes arising from or in connection with this Agreement shall be resolved through negotiations. In case of failure to reach agreement, the dispute shall be referred to court in accordance with the legislation of the Russian Federation:

8.2. Pre-trial procedure: prior to going to court, the User shall send the Operator a written claim using the contacts specified in Section 10. The response period to a claim is 30 calendar days.

9. Transfer of Rights and Obligations

9.1. The Operator has the right to transfer its rights and obligations under this Agreement to third parties in case of reorganization, sale of business or other legally significant events. The User will be notified of such transfer.

9.2. The User has no right to transfer their rights and obligations under this Agreement to third parties without prior written consent of the Operator.

10. Feedback and Contact Information

The User may contact the Operator on all matters related to the use of the Services and processing of personal data:

For App Store users (Operator — Konstantin Valeryevich Dvugroshev, private individual): - Email: hello.solomono@gmail.com - Postal address: Moscow, Vysokaya str., bldg. 20, apt. 41, Russian Federation

For Google Play users (Operator — LLC NMF “Neirotech” / ООО НМФ «Нейротех»): - Email: privacy@neiry-bci.com - Postal address: 347905, Rostov Region, Taganrog, Dzerzhinskogo str., 119-a, Russian Federation - OGRN 1026102573419, INN 6154082572

General privacy and data processing inquiries: privacy@neiry-bci.com

11. Final Provisions

11.1. If any provision of this Agreement is found to be invalid or unenforceable, this does not affect the legality or validity of the other provisions of the Agreement.

11.2. This Agreement enters into force upon its publication on the Operator’s website and is valid until replaced by a new version.

11.3. This Agreement is drawn up in Russian and English. In case of discrepancies between the versions, the Russian version shall prevail for users from the Russian Federation.