Privacy Policy

Effective Date: March 8, 2026

1. Introduction

elephantmilk asia LLC (“we,” “us,” or “our”) operates the website and mobile application known as Pinnacle Pulse (the “Service”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service, including any health, biometric, and wearable data that may be processed by or in connection with Pinnacle Pulse.

By using the Service, you consent to the practices described in this Privacy Policy. If you do not agree, please do not use the Service.

2. Information We Collect

2.1 Account and Contact Data

When you create an account or join our waitlist, we may collect:

  • Name
  • Email address

2.2 Waitlist Data

When you sign up for our waitlist through the website, we collect:

  • Email address (required)
  • Name (optional)
  • Source (e.g., hero section, pricing section, final CTA)
  • UTM parameters (utm_source, utm_medium, utm_campaign) for marketing attribution

2.3 Health and Biometric Data (App)

When you use the Pinnacle Pulse application, the Service may process the following categories of health-related data. Much of this data is processed and stored on your device only:

  • Peptide protocol data: substance names, dosage, unit (e.g., mcg, mg), injection site, protocol combinations
  • Biometric inputs: heart rate variability (HRV), soreness scores (1–10), sleep duration and quality
  • Body scan data: images from multi-angle captures, 3D avatar data, body measurements (e.g., shoulders, chest, waist, thighs in cm), morph metrics (e.g., chest, arms, waist, definition, vascularity)
  • Wearable sync data: resting heart rate, HRV, sleep score, step count, SpO₂, and similar metrics from connected devices (e.g., Xiaomi Smart Band 10, HUAWEI Band 10)
  • Blood panel data (Pro tier): laboratory results such as testosterone, IGF-1, HGH, cortisol, and related biomarkers when you choose to integrate data from partner labs

Our AI forecasting (EvoEngine) runs on-device using TensorFlow Lite. Health and biometric data used for predictions are processed locally and do not leave your device unless you explicitly use features that sync data (e.g., cloud backup, if offered).

2.4 Device and Usage Data

We may collect or receive:

  • Device model and operating system
  • Session identifiers
  • Page or in-app event data (e.g., event_type, event_data) where applicable

2.5 Automatically Collected Data

When you use our website or app, we may automatically receive:

  • IP address (used for rate limiting and security; not stored persistently for identification)
  • Browser type and version
  • Referral URLs and referring domains

3. How We Use Your Information

We use the information we collect to:

  • Manage waitlist sign-ups and communicate product updates and launch information
  • Provide, operate, and improve the Service
  • Run AI and prediction features on your device (health data remains on-device for core forecasting)
  • Analyze usage patterns and improve user experience (where analytics are used)
  • Send transactional or marketing communications where you have opted in
  • Comply with legal obligations and enforce our terms

4. On-Device Processing

Our EvoEngine and related AI features run entirely on your device using TensorFlow Lite. Your peptide logs, body scans, biometric data, and wearable-derived metrics used for these predictions do not need to be sent to our servers for core functionality. We are committed to keeping sensitive health data on your device unless you choose to use optional cloud or sync features, which will be clearly described and consented to separately.

5. Data Sharing

We do not sell your personal information. We may share your information only in the following circumstances:

  • Service providers: With vendors who assist in hosting, analytics, email delivery, or other operational needs, under contractual obligations to protect your data
  • Legal requirements: When required by law, court order, or governmental authority
  • Protection of rights: To protect our rights, your safety, or the safety of others, or to investigate fraud or violations of our terms

6. Data Retention

Waitlist data is retained until the launch of the product or until you request deletion. Health and biometric data processed by the app are stored on your device; we do not retain copies of such data on our servers unless you use an optional cloud or backup feature. For data stored on our systems, we retain it only as long as necessary to fulfill the purposes described in this policy or as required by law.

7. Your Rights

Depending on your location, you may have the right to:

  • Access: Request a copy of the personal data we hold about you
  • Correction: Request correction of inaccurate or incomplete data
  • Deletion: Request deletion of your personal data
  • Data portability: Request your data in a structured, machine-readable format
  • Opt-out: Unsubscribe from marketing communications or withdraw consent where applicable

To exercise these rights, contact us using the details in Section 14. We will respond in accordance with applicable law.

8. Cookies and Tracking

We use minimal tracking. UTM parameters and session identifiers may be used for attribution and basic analytics. We do not use cookies or similar technologies for advertising purposes on the waitlist or core app experience. Any future use of cookies or tracking will be disclosed and, where required, subject to your consent.

9. Children's Privacy

The Service is not intended for users under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a minor, please contact us and we will take steps to delete it.

10. International Data Transfers

Your information may be processed in countries other than your country of residence. We take appropriate safeguards (such as Standard Contractual Clauses or equivalent mechanisms) to ensure that your data is protected in accordance with this Privacy Policy and applicable law.

11. Security Measures

We implement technical and organizational measures to protect your data, including encryption where applicable, rate limiting to prevent abuse, and access controls. Data that syncs to our systems is protected in transit and at rest. You are responsible for securing your device and account credentials.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated policy on this page and update the “Effective Date.” Material changes may be communicated via email or a prominent notice in the Service. Your continued use after the effective date constitutes acceptance of the updated policy.

13. Contact Information

For questions about this Privacy Policy or to exercise your privacy rights, contact:

elephantmilk asia LLC
Pinnacle Pulse
[Contact email or address to be inserted]