ARC Intelligence – Privacy Policy

Last Updated: May 2026

1. Overview

ARC Intelligence (“we,” “us,” or “our”) operates a sports biomechanics analysis platform that combines video analysis, AI-driven insights, coaching tools, and community features (collectively, the “Service”). This Privacy Policy explains how we collect, use, store, share, and protect your personal information when you use our mobile application, website, and related services.

By creating an account or using the Service, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, please do not use the Service.

This policy applies to all users of ARC Intelligence, including athletes, coaches, contributors, and any other individuals who interact with the Service.

2. Information We Collect

We collect information in the following categories depending on how you interact with the Service:

2.1 Account Information

When you register for an account, we collect your name, email address, and password (stored in hashed form only). You may also provide your role (e.g., athlete, coach), sport preference, date of birth (optional), and additional profile data such as a display name or biography.

2.2 Content You Provide

You may upload or submit content to the Service, including videos, images, PDFs, text submissions, coaching insights, annotations, and contributor content. You are responsible for the content you provide and should not upload content that contains sensitive personal information of third parties without their consent.

2.3 Biomechanical and Analysis Data

When you use the analysis features of the Service, we generate and store biomechanical data including pose estimation data, movement measurements, shot and motion classifications, AI-generated insights, and analysis results derived from your uploaded content.

2.4 Usage and Device Data

We automatically collect information about your interactions with the Service, including feature usage patterns, timestamps, session data, device type, operating system version, and general device information. This data helps us maintain, improve, and troubleshoot the Service.

2.5 Payment Information

Payments are processed by Apple (via StoreKit for in-app purchases) and Stripe (for web-based transactions). ARC Intelligence does not directly collect or store your credit card numbers, bank account details, or other full payment instrument data. We receive limited transaction information (such as subscription status, transaction identifiers, and purchase history) from these processors to manage your account and entitlements.

2.6 Contact Hashes

If you choose to use our friend discovery feature, phone numbers from your device contacts are processed locally and transmitted to our servers only as one-way SHA-256 cryptographic hashes. We do not store or have access to the underlying plaintext phone numbers.

2.7 Referral Data

If you participate in our referral program, we collect referral codes, referral relationships between accounts, and commission tracking data associated with your referral activity.

2.8 Notification Data

To deliver in-app notifications and push notifications, we store notification records and device tokens associated with your account.

3. How We Use Your Information

We use the information we collect for the following purposes:

• Providing the Service: To create and manage your account, deliver biomechanical analysis, generate AI-driven insights, display coaching tools, and enable community and contributor features.
• Communication: To send you notifications related to your account, analysis results, coaching feedback, referral activity, and Service updates.
• Payment Processing: To manage subscriptions, verify entitlements, process referral commissions, and coordinate with our payment processors.
• Improvement and Development: To analyze usage patterns, diagnose technical issues, improve existing features, and develop new functionality.
• Safety and Integrity: To detect, prevent, and address fraud, abuse, security incidents, and violations of our Terms of Service.
• Legal Compliance: To comply with applicable laws, regulations, legal processes, and enforceable governmental requests.

4. AI and Machine Learning Processing

ARC Intelligence may use third-party AI and machine learning providers to support analysis, moderation, insight generation, infrastructure, platform improvement, and related services. Data processed by these providers may include uploaded content, biomechanical measurements, generated insights, metadata, account information, and related operational or system information, depending on feature usage. ARC Intelligence may use a combination of on-device and secure cloud-based processing to deliver these features.

AI Chat (in-app coaching). When you use AI Chat, we store your conversation threads and messages in our database (including optional compressed summaries of longer threads to control cost) and send a minimal performance-coaching context packet to our AI provider (for example, short analysis score summaries and recent chat text — not raw video files or full pose trajectory exports). AI Chat is intended as tennis performance coaching support only, not medical, mental health, legal, or financial advice. Retention follows your account lifecycle and the schedules in Appendix B unless we state otherwise in product settings.

We select AI and ML providers that maintain appropriate security practices for the data they process. ARC Intelligence conducts or will conduct data protection impact assessments where required by applicable law. However, the specific providers, processing methods, and technical architectures we use may change over time as the Service evolves. For additional information about how data is used in connection with AI features, please see our AI, Biomechanics & Coaching Disclaimer.

5. How We Share Your Information

ARC Intelligence does not sell your personal information. We share data only in the following circumstances:

5.1 Infrastructure Providers

We use Supabase as our primary infrastructure provider for database hosting, cloud object storage, and authentication services. Your account data, uploaded content, and associated records are stored and processed through Supabase infrastructure.

5.2 Payment Processors

We share limited account and transaction data with Apple and Stripe to facilitate payment processing, subscription management, and purchase verification.

5.3 AI and ML Service Providers

We share data with AI and machine learning service providers as described in Section 4 above, to the extent necessary to deliver analysis, moderation, insights, and other platform features.

5.4 Legal Requirements

We may disclose your information if required to do so by law or in response to valid legal process, including subpoenas, court orders, or governmental requests. We may also disclose information when we believe in good faith that disclosure is necessary to protect our rights, your safety or the safety of others, investigate fraud, or respond to a government request.

5.5 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or similar transaction, your personal information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.

6. Data Retention

We retain personal data for as long as your account is active or as needed to provide the Service. Upon account deletion, identifiable account data is removed or deactivated in accordance with the process described in Section 7 below.

Certain categories of data may be retained beyond account deletion, including de-identified data, aggregated data, moderation records, security logs, backup data, analytics data, contributor content (subject to the Contributor License Agreement), and system-integrity data. Anonymized or de-identified pose data, biomechanical measurements, movement-derived metrics, analytical and system outputs, and aggregated platform data may be retained indefinitely to support ongoing research, platform improvement, and service development.

We may also retain information as required by applicable law, regulation, or legal obligation. For detailed retention schedules and deletion procedures, see Appendix B below.

7. Account Deletion

You may request deletion of your account through the in-app settings. Upon processing your deletion request:

• Your frontend access to the Service will be removed.
• Your identifiable user account will be removed or deactivated from our active systems.
• Certain data may be retained as described in Section 6 above.

If you have questions about the deletion process or need assistance, please contact us at hello@arcintelligence.online.

8. Children’s Privacy

ARC Intelligence is intended for users aged 13 and older. We do not knowingly collect personal information from children under the age of 13. If we become aware that we have collected personal information from a child under 13 without appropriate parental consent, we will take steps to delete that information promptly.

If you are a parent or guardian and believe your child under 13 has provided personal information to ARC Intelligence, please contact us at hello@arcintelligence.online so that we can take appropriate action. For additional information about minors and the Service, please see Appendix D below.

9. Your Rights and Choices

9.1 General Rights

Depending on your jurisdiction, you may have the following rights regarding your personal information:

• Access: You may request a copy of the personal information we hold about you.
• Correction: You may request that we correct inaccurate or incomplete personal information.
• Deletion: You may request that we delete your personal information, subject to certain legal exceptions.
• Data Portability: You may request a copy of your data in a structured, commonly used, and machine-readable format.
• Objection: You may object to certain types of processing of your personal information.
• Withdrawal of Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.

To exercise any of these rights, please contact us at hello@arcintelligence.online. We will respond to your request within the timeframe required by applicable law.

9.2 Rights Under the General Data Protection Regulation (GDPR)

For detailed information about your rights under GDPR and UK GDPR, including lawful bases, international transfers, and supervisory authorities, see Appendix C below.

9.3 Rights Under the California Consumer Privacy Act (CCPA)

If you are a California resident, the CCPA provides you with the following rights:

• Right to Know: You have the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purposes for collection, and the categories of third parties with whom we share your information.
• Right to Delete: You have the right to request deletion of your personal information, subject to certain legal exceptions.
• Right to Opt-Out of Sale: ARC Intelligence does not sell your personal information. As such, there is no need to opt out of the sale of personal information.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

To submit a verifiable consumer request, contact us at hello@arcintelligence.online. We may need to verify your identity before processing your request.

10. Cookies and Tracking Technologies

For detailed information about cookies and similar technologies, see Appendix A below.

11. Data Security

We implement industry-standard security measures to protect your personal information, including encryption of data in transit and at rest, secure cloud infrastructure, role-based access controls, and regular security practices. While we strive to protect your information, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

If you become aware of a security vulnerability or suspect unauthorized access to your account, please contact us immediately at hello@arcintelligence.online.

12. International Data Transfers

ARC Intelligence is operated from the United States. If you are accessing the Service from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States and other jurisdictions where our service providers operate. By using the Service, you consent to the transfer of your information to the United States and other jurisdictions that may have different data protection laws than your country of residence.

We implement appropriate safeguards for international data transfers as required by applicable law, which may include standard contractual clauses, data privacy frameworks, or other recognized mechanisms.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will notify you by updating the “Last Updated” date at the top of this policy and, where appropriate, through in-app notifications or other communication channels.

Your continued use of the Service after any changes to this Privacy Policy constitutes your acceptance of the updated policy. We encourage you to review this Privacy Policy periodically.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: hello@arcintelligence.online

We will respond to your inquiry within a reasonable timeframe.

Appendix A — Cookie Policy

A.1 What Are Cookies

Cookies are small text files placed on your device by websites or applications you visit. They are widely used to make services work efficiently, to remember your preferences, and to provide information to site operators. Similar technologies include local storage, session storage, and device identifiers.

A.2 How ARC Intelligence Uses Cookies

ARC Intelligence uses a limited set of cookies and similar technologies for the following purposes:

Strictly Necessary Cookies

These cookies are essential for the operation of ARC Intelligence and cannot be disabled without affecting core functionality:

• Authentication session cookies: Maintain your signed-in state across pages and sessions. Set by Supabase Auth.
• Security cookies: Protect against cross-site request forgery and other security threats.

Functional Cookies

• Referral tracking: A cookie may be set when you arrive via a referral link. This cookie attributes your account to the referring user and is used solely for the ARC Intelligence referral program. It is cleared after signup or expiration.
• Preference cookies: May store interface preferences such as theme or layout selections.

Limited Analytics

ARC Intelligence may use limited analytics to understand how the platform is used and to improve the service. Analytics data is aggregated and not used to personally identify individual users. ARC Intelligence does not use third-party advertising trackers.

A.3 Third-Party Cookies

ARC Intelligence does not serve third-party advertising cookies. However, if you interact with embedded third-party services (such as payment processors), those services may set their own cookies subject to their respective privacy policies.

A.4 iOS Application

The ARC Intelligence iOS application does not use browser cookies. Authentication state is maintained through secure device storage. This cookie policy primarily applies to the ARC Intelligence website at arcintelligence.online.

A.5 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to:

• View and delete existing cookies
• Block all cookies or only third-party cookies
• Set preferences for specific websites

Disabling strictly necessary cookies may prevent you from signing in or using certain features of ARC Intelligence.

For more information about managing cookies in your browser, visit your browser's help documentation or allaboutcookies.org.

Appendix B — Data Retention & Deletion

B.1 General Retention Principle

ARC Intelligence retains personal data for as long as your account is active or as needed to provide services, comply with legal obligations, resolve disputes, and enforce agreements. We do not retain identifiable personal data longer than reasonably necessary for the purposes described in this Privacy Policy.

B.2 Retention by Data Category

Account Data

Account information (name, email, role, sport preference, profile data) is retained for the duration of your active account. Upon account deletion, identifiable account data is removed or deactivated within a reasonable timeframe.

Uploaded Content

Videos, images, and other media uploaded by users for analysis purposes are retained while your account is active. Upon account deletion, user-uploaded media files are queued for removal from active storage. Copies may persist temporarily in backups and caches before being overwritten through normal operational cycles.

Biomechanical & Analysis Data

Pose estimation data, joint angles, movement metrics, shot classifications, and AI-generated analysis results may be retained in de-identified or aggregated form indefinitely. This data supports the ongoing development and improvement of ARC Intelligence’s MovementNet technology and biomechanics systems.

De-identified biomechanical measurements, movement-derived metrics, analytical outputs, and aggregated platform data do not constitute personal data once they can no longer be linked to an identifiable individual, and are therefore not subject to deletion requests.

Contributor Content

Content submitted through the ARC Intelligence Incubator (coaching insights, annotations, skill area analyses, moderation feedback) is retained in accordance with the Contributor Licensing Agreement. Contributors grant ARC Intelligence a perpetual, irrevocable license to this content. Contributor content may persist in ARC Intelligence systems, trained models, datasets, and derived outputs after account deletion. This is a condition of the contributor relationship and is disclosed at the time of contribution.

Transaction & Payment Data

Subscription status, transaction identifiers, and payment metadata are retained for the duration required by applicable tax and financial record-keeping laws (typically 7 years). ARC Intelligence does not store raw payment card numbers — these are held by Apple and Stripe respectively.

Referral Data

Referral codes, referral relationships, and commission records are retained for the duration of the referral program and any applicable financial record-keeping requirements.

Communications & Moderation

Messages exchanged through the ARC Intelligence Incubator submission feedback system, moderation records, and support correspondence are retained for platform integrity, quality assurance, and dispute resolution purposes. These records may be retained after account deletion where necessary for legal compliance or platform safety.

Usage & Analytics Data

Aggregated usage data, feature interaction metrics, and de-identified analytics are retained indefinitely for platform improvement. Device-specific identifiers and session data are retained only while an account is active.

Security & Moderation Records

Records related to content moderation decisions, account enforcement actions, abuse reports, and security incidents are retained for as long as necessary to maintain platform integrity and comply with legal obligations. These records may be retained after account deletion.

B.3 Account Deletion Process

Users may request account deletion through the in-app settings or by emailing hello@arcintelligence.online with the subject line “Account Deletion Request.”

Upon receiving a valid deletion request, ARC Intelligence will:

• Remove frontend access to the account.
• Deactivate or remove identifiable personal data (name, email, profile) from active systems.
• Cancel any active subscriptions where technically possible (users should also cancel directly through Apple or Stripe).
• Queue user-uploaded media for removal from active storage.

B.4 Data That May Persist After Deletion

The following categories of data may be retained after account deletion:

• De-identified and anonymized biomechanical data, movement metrics, and analytical outputs.
• Contributor content licensed under the Contributor Licensing Agreement.
• Aggregated platform analytics and system metrics.
• Moderation records, enforcement actions, and abuse reports.
• Financial and transaction records required by law.
• Data incorporated into trained AI/ML models, datasets, and derived insights.
• Backup copies, which are overwritten through normal operational cycles.

ARC Intelligence does not guarantee immediate or complete removal of all data from all systems, including backups, caches, and disaster recovery infrastructure.

B.5 Data Portability

Users may request a copy of their personal data by contacting hello@arcintelligence.online. We will provide the data in a commonly used, machine-readable format within a reasonable timeframe and in accordance with applicable law (including GDPR Article 20 where applicable).

B.6 Legal Holds

Where ARC Intelligence is subject to a legal obligation, regulatory investigation, or active dispute, data that would otherwise be deleted may be retained for the duration of the applicable legal hold. Users will be notified of legal holds where legally permitted.

B.7 Children’s Data

ARC Intelligence does not knowingly collect data from children under 13. If we discover that data has been collected from a child under 13, we will take steps to delete it promptly. See Appendix D for additional information about minors.

Appendix C — GDPR & UK Privacy Addendum

C.1 Scope

This appendix supplements the ARC Intelligence Privacy Policy with additional information required under the European Union General Data Protection Regulation (GDPR), the UK General Data Protection Regulation (UK GDPR), and related data protection laws. It applies to users located in the European Economic Area (EEA), the United Kingdom, and Switzerland.

C.2 Data Controller

ARC Intelligence is the data controller responsible for the processing of your personal data. ARC Intelligence is based in the United States.

Contact: hello@arcintelligence.online

C.3 Lawful Bases for Processing

ARC Intelligence processes personal data on the following lawful bases under GDPR Article 6:

C.3.1 Consent (Article 6(1)(a))

• Account creation and registration.
• Processing of uploaded content for analysis.
• Receipt of communications and notifications.
• Participation in the referral program.

You may withdraw consent at any time by contacting hello@arcintelligence.online or by deleting your account. Withdrawal of consent does not affect the lawfulness of processing performed before withdrawal.

C.3.2 Performance of a Contract (Article 6(1)(b))

• Providing the ARC Intelligence service (analysis, insights, platform access).
• Processing subscription payments.
• Managing your account.
• Fulfilling the Contributor Licensing Agreement for contributors.

C.3.3 Legitimate Interests (Article 6(1)(f))

• Improving ARC Intelligence technology, AI models, and biomechanics systems using de-identified data.
• Platform security, fraud prevention, and abuse detection.
• Aggregated analytics and platform performance monitoring.
• Content moderation and community safety.

We balance our legitimate interests against your rights and freedoms. You have the right to object to processing based on legitimate interests.

C.3.4 Legal Obligation (Article 6(1)(c))

• Compliance with tax and financial record-keeping requirements.
• Response to valid legal requests from authorities.
• DMCA and intellectual property compliance.

C.4 Special Category Data

ARC Intelligence may process data that could be considered health or biometric data under certain interpretations of GDPR (biomechanical measurements, movement analysis). This processing is based on your explicit consent provided during account creation and content upload, and is performed solely for the purpose of providing sports performance analysis — not medical diagnosis or health monitoring.

C.5 International Data Transfers

ARC Intelligence is based in the United States. Your data may be transferred to and processed in the United States and other countries where our infrastructure providers operate. These transfers are necessary for providing the service.

For transfers from the EEA/UK to countries not recognized as providing adequate data protection, ARC Intelligence implements appropriate safeguards as required by applicable law, which may include:

• Standard Contractual Clauses (SCCs) approved by the European Commission, where applicable.
• The EU-U.S. Data Privacy Framework, where applicable and where ARC Intelligence or its processors are certified.
• Other recognized transfer mechanisms under applicable data protection legislation.
• Your explicit consent to the transfer, provided during account creation.

You may request information about the specific safeguards applied to your data transfers by contacting hello@arcintelligence.online.

C.6 Your Rights Under GDPR

If you are located in the EEA, UK, or Switzerland, you have the following rights:

• Right of Access (Article 15): Request a copy of the personal data ARC Intelligence holds about you.
• Right to Rectification (Article 16): Request correction of inaccurate personal data.
• Right to Erasure (Article 17): Request deletion of your personal data, subject to the exceptions described in Section B.4 of this policy.
• Right to Restriction (Article 18): Request restriction of processing in certain circumstances.
• Right to Data Portability (Article 20): Request your data in a structured, commonly used, machine-readable format.
• Right to Object (Article 21): Object to processing based on legitimate interests, including profiling.
• Right Not to Be Subject to Automated Decision-Making (Article 22): ARC Intelligence uses automated processing (AI analysis) to generate insights, but these do not produce legal effects or similarly significant effects on you. AI analysis is informational and educational only.

To exercise any of these rights, contact hello@arcintelligence.online with the subject line “GDPR Rights Request.” We will respond within 30 days.

C.7 Right to Erasure — Limitations

Your right to erasure may be limited where ARC Intelligence has a lawful basis for retaining data, including:

• De-identified biomechanical data that can no longer be linked to an identifiable individual.
• Contributor content licensed under the Contributor Licensing Agreement (perpetual license).
• Data incorporated into trained AI/ML models and derived datasets.
• Financial records required by tax and regulatory obligations.
• Moderation and security records necessary for platform integrity.
• Data subject to active legal holds or ongoing disputes.

See Appendix B for complete details on data retention and deletion.

C.8 Children’s Data

ARC Intelligence requires users to be at least 13 years old. In EU member states where the GDPR age of consent for data processing is higher (up to 16), ARC Intelligence relies on parental consent for users below the applicable threshold. See Appendix D for additional information.

C.9 Supervisory Authority

If you are located in the EEA or UK and believe ARC Intelligence has not adequately addressed your data protection concerns, you have the right to lodge a complaint with your local data protection supervisory authority. A list of EEA supervisory authorities is available at edpb.europa.eu. For UK residents, contact the Information Commissioner’s Office (ICO) at ico.org.uk.

C.10 Data Protection Impact Assessments

ARC Intelligence conducts or will conduct data protection impact assessments where required by applicable law for high-risk processing activities, including AI-powered video analysis and biomechanical data processing.

C.11 UK-Specific Provisions

For users in the United Kingdom, references to GDPR in this appendix include the UK GDPR as retained in UK law. The International Data Transfer Addendum to the EU SCCs, as issued by the ICO, applies to data transfers from the UK where applicable.

C.12 Contact for GDPR Inquiries

For GDPR-related inquiries, rights requests, or complaints: hello@arcintelligence.online with “GDPR” in the subject line.

Appendix D — Minor & Youth Athlete Protection

D.1 Age Requirement

You must be at least 13 years old to create an account or use ARC Intelligence. ARC Intelligence does not knowingly collect personal information from children under the age of 13. If we become aware that a user is under 13, we will take steps to deactivate the account and delete associated personal data.

If you are a parent or guardian and believe your child under 13 has created a ARC Intelligence account or provided personal information, please contact us immediately at hello@arcintelligence.online so we can take appropriate action.

D.2 Users Between 13 and 18

Users between the ages of 13 and 18 (or the age of majority in their jurisdiction, if different) may use ARC Intelligence with the consent and supervision of a parent or legal guardian. By permitting a minor to use ARC Intelligence, the parent or guardian agrees to these terms on behalf of the minor and accepts responsibility for the minor’s activity on the platform.

Parents and guardians are encouraged to monitor their minor’s use of ARC Intelligence and to discuss responsible use of sports performance and coaching technology.

D.3 Coach, Contributor, and Employer Eligibility

Users must be at least 18 years old to register as a coach, contributor, or employer on ARC Intelligence. The Incubator contribution system, job application features, and referral program are restricted to adult users only.

D.4 Content Involving Minors

ARC Intelligence is a sports performance and coaching platform. Videos uploaded by minor users (ages 13 to 17) are used solely for the purpose of providing sports analysis and coaching insights. ARC Intelligence applies the following safeguards:

• Minor user content is processed for performance analysis only and is not used for advertising or marketing purposes.
• ARC Intelligence does not publicly display or share minor user videos outside the platform without explicit parental consent.
• Contributor content submitted to the Incubator is only available to approved moderators and contributors — not to the general public.

D.5 Data Collection for Minors

ARC Intelligence collects the same categories of data from minor users (ages 13+) as from adult users, as described in Section 2 of this Privacy Policy. This includes account information, uploaded content, biomechanical data, and usage data. We do not collect more data from minors than is reasonably necessary to provide the service.

ARC Intelligence does not engage in behavioral advertising targeted at minor users.

D.6 Parental Rights

Parents and guardians of minor users have the right to:

• Review the personal information ARC Intelligence has collected about their child.
• Request correction or deletion of their child’s personal information.
• Request that ARC Intelligence stop collecting or using their child’s personal information.
• Request deletion of their child’s ARC Intelligence account.

To exercise any of these rights, contact us at hello@arcintelligence.online. We may require verification of the parent-child relationship before processing requests.

D.7 Physical Activity Disclaimer for Parents

ARC Intelligence provides sports performance analysis and coaching insights for informational and educational purposes only. Parents and guardians should be aware that:

• ARC Intelligence is not a substitute for qualified professional coaching, medical advice, or physical therapy.
• AI-generated analysis is not guaranteed to be accurate and should not be relied upon as the sole basis for training decisions.
• Parents and guardians are responsible for ensuring that any training activities undertaken by their minor are appropriate, safe, and supervised.
• ARC Intelligence does not guarantee injury prevention. All physical activity carries inherent risk.

D.8 Compliance

ARC Intelligence is designed to comply with the Children’s Online Privacy Protection Act (COPPA) by restricting account creation to users 13 and older. ARC Intelligence also adheres to applicable provisions of the General Data Protection Regulation (GDPR) and other privacy laws regarding the processing of minor data.

Where applicable law requires a higher minimum age (for example, 16 in certain EU member states for consent to data processing), ARC Intelligence relies on parental consent for users below the applicable threshold.