Privacy at a glance

• No cameras. No microphones. Nothing to wear. LiLoHome™ does not collect video, audio, photographs, or GPS location.
• Your information is stored in Canada. Some service providers we rely on operate outside Canada.
• We never sell your information. Not to advertisers, not to data brokers, not to anyone.
• The Resident decides who sees their insights — and can change or remove anyone from their Care Team at any time, without giving a reason.
• The Resident can withdraw at any time. Withdrawing stops new insights and ends Care Team access, and costs the Account Owner nothing.
• You can ask us what we hold about you, correct it, or ask us to delete it. Write to privacy@lilohealth.care and we respond within 30 days.
• LiLoHome™ is a wellness product, not a medical device, and not an emergency service. It does not call for help.

This summary is here to help. It does not replace the full Policy below, which is what governs.

1. About This Policy

1.1 Purpose

This Privacy Policy (the “Policy”) explains how LiLo Health Ltd. (“LiLo Health,” “we,” “us,” or “our”) collects, uses, discloses, retains, and protects personal information in connection with the LiLoHome™ passive wellness service (“LiLoHome™” or the “Service”). It applies to information about Account Owners, Residents, Care Team Members, and people who interact with LiLo Health’s website, application, and support channels.

This Policy is a separate document. The Customer expressly consents to it on the signature page of the LiLoHome™ Membership Agreement. Care Team Members expressly consent to it by giving a separate, express consent through a discrete control in the LiLoHome™ App Terms of Use at in-app sign-up, distinct from acceptance of those Terms. Residents expressly consent to it through the Resident Participation Consent signed before activation.

1.2 Governing Law and Framework

LiLo Health Ltd. is governed by the laws of British Columbia, Canada. This Policy is written to the Personal Information Protection Act (British Columbia) (“PIPA”) and the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) where applicable.

1.3 How to Read This Policy

In this Policy, the “Customer Contract” means the LiLoHome™ Membership Agreement or, for customers who signed before its effective date, the LiLoHome™ Customer Agreement. Unless otherwise defined here, this Policy uses the same defined terms as the Customer Contract: Account Owner, Resident, Care Team Member, Organizational Care Team Member, and LiLoHome™.

1.4 Updates to This Policy

We may update this Policy from time to time. The current version number and effective date are shown at the top of this page. Material changes will be communicated to Account Owners by email and through the LiLoHome™ application (the “App”), and posted here. Updates are effective when posted, unless we specify a later effective date in the notice. Continued use of the Service after the effective date of an update constitutes acceptance of the update.

Each version of this Policy is identified by a version number and an effective date, and supersedes all earlier versions. Earlier versions are retained internally as audit evidence under the retention rules in Section 6.

2. Who We Are and How to Reach Us

2.1 The Organization

LiLo Health Ltd. is a company established in Kelowna, British Columbia, Canada. LiLo Health develops and operates LiLoHome™, and operates from the domain lilohealth.care, including the corporate website, this Policy, customer-facing pages, application endpoints, and email communications.

2.2 Privacy Contact

The dedicated channel for all privacy-related inquiries, requests, and complaints is privacy@lilohealth.care. LiLo Health’s Privacy Officer may be contacted at that address.

2.3 Complaints

If you believe LiLo Health has not handled your personal information appropriately, please contact us first at privacy@lilohealth.care. We will acknowledge your complaint and work with you to resolve it.

If you are not satisfied with our response, subject to applicable laws you may escalate to:

• the Office of the Information and Privacy Commissioner for British Columbia (OIPC BC), at oipc.bc.ca, for matters governed by PIPA; and/or
• the Office of the Privacy Commissioner of Canada (OPC), at priv.gc.ca, for matters governed by PIPEDA.

3. What We Collect

3.1 From the Resident’s Home

LiLoHome™ collects information relating to patterns of daily living through devices installed in the Resident’s home. This may include:

• Motion detection events, presence and absence events, and door open and close events.
• Ambient temperature and humidity readings.
• Vibration and time-of-flight occupancy events.
• Sleep and rest indicators (in bed, out of bed, restlessness signals).
• Physiological indicators including heart rate and breathing rate.
• Weight readings and the time of measurement.
• Plain-language summaries generated by our software from the indicators above (for example, “kitchen activity recognized” inferred from motion and vibration patterns, or “in bed by 10:14 PM” inferred from bed presence). These are estimates based on sensor patterns, not clinical determinations.
• Operational state of the hub and each sensor (online, offline, reporting, silent), used to surface system health to the Care Team and to our operations team.

3.2 About Account Owners and Care Team Members

• Account data: name, email address, phone number, postal address, the home address where LiLoHome™ is installed, the role of each person on the account, and any preferred communication settings.
• Application use data: sign-in events, App settings, notification preferences, acceptance records of this Policy, the Customer Contract, and the LiLoHome™ App Terms of Use, and the version of each document accepted.
• Billing data: payment history, payment method tokens (we do not store full credit card numbers; tokenization is performed by our payment processor), and refund and adjustment records.
• Customer support records: correspondence with our support team and notes from sales calls.

3.3 About Residents

• Identity and contact information (name, date of birth where voluntarily provided, preferred contact method).
• Consent records (which version of the Resident Participation Consent was signed, when, where, and through what channel).
• Sensor patterns and derived indicators under §3.1.
• Where the Resident is also the Account Owner, the categories listed in §3.2.

3.4 Content Entered by Users

The App allows Account Owners, Residents, and Care Team Members to enter and share tasks, reminders, notes, and messages with one another. We store that content, together with who entered it and when. It is written by users, not generated by LiLoHome™, and we do not review, verify, or act on it. It may include information about the Resident—such as health, appointments, or medications—that LiLoHome™ does not collect itself.

Content about a Resident is personal information of that Resident, regardless of who entered it, and the Resident may exercise the rights in Section 7 in respect of it. Where a Care Team Member’s access is removed, what that person entered remains in the Resident’s record and visible to the Resident and their current Care Team, unless the Resident asks us to remove it. LiLoHome™ is not a clinical record, and this content is not a medical record.

3.5 What LiLoHome™ Does Not Collect

LiLoHome™ does not collect video, audio, still images, or GPS location data. The hub and the qualified sensor fleet do not include cameras or microphones. The cellular weight scale does not transmit GPS coordinates to us.

3.6 Children’s Data

LiLoHome™ is designed for adult Residents who choose to participate in the Service in their own homes, and for adult Account Owners and Care Team Members. The Service is not directed to children, and we do not knowingly collect personal information from children, other than the limited circumstance in which a child may incidentally appear on a sensor reading (for example, a grandchild visiting, whose presence may be reflected in a motion event). If you believe a child’s personal information has been collected outside that limited circumstance, contact us at privacy@lilohealth.care.

4. Why We Collect It

We use personal information to:

• Provide the Service. Operate the LiLoHome™ system, present the activity timeline and the information and analysis generated from gathered information, and deliver awareness notifications to authorized Care Team Members.
• Support Care Team coordination. Store and display the tasks, notes, and messages users enter so the Resident and their Care Team can coordinate support. We do not review, verify, or act on that content.
• Operate and support the account. Bill the Account Owner, answer support requests, dispatch service visits, and run the operational processes that keep the system working.
• Safeguard the Service. Detect and respond to security incidents, fraud, abuse, misuse, and unauthorized access, and preserve audit records demonstrating consent and operational integrity.
• Improve the Service. Analyze operational performance, identify defects, and improve the qualified device fleet, consistent with this Policy and applicable law.
• Comply with our legal obligations under PIPA, PIPEDA, the BC consumer-protection framework, applicable tax law, and lawful requests from authorities with jurisdiction.

We do not sell personal information. We do not use personal information for advertising. We do not share personal information with data brokers.

5. Your Consent

5.1 Consent-Based Operation

LiLoHome™ operates on the basis of express, informed consent. The following consents are recorded for every active Service relationship:

• Customer consent to this Policy is captured on the signature page of the Customer Contract, where the Customer gives express, separate consent to this Policy in addition to agreeing to the Customer Contract itself.
• Resident Participation Consent is signed by the Resident (or, where §5.2 applies, by a substitute decision-maker) before activation. It authorizes the collection, processing, storage, and sharing of the categories described in §3.1 and §3.4 with Care Team Members identified at install or subsequently authorized.
• Care Team Member consent is given as a separate, express consent through a discrete control in the LiLoHome™ App Terms of Use at in-app sign-up, distinct from acceptance of those Terms. It authorizes the processing of that Care Team Member’s own personal information described in §3.2.
• Organizational Care Team Member access is authorized by the Resident in the Resident Participation Consent, which names the organization and records that its named individuals will have access. Each individual receiving access must separately activate an account and give the Care Team Member consent described above. We maintain the list of individuals currently authorized through that organization and provide it to the Resident on request.

5.2 Capacity and Substitute Decision-Makers

LiLo Health expects the Resident to have the legal capacity required to give informed consent to participate. Where a Resident does not have that capacity, an appropriate substitute decision-maker (including under a power of attorney covering personal matters, a representation agreement, or similar authority) may sign the Resident Participation Consent on the Resident’s behalf. Authority over a Resident’s property or financial affairs alone is not authority to consent to the collection and use of the Resident’s personal information.

6. Where We Store It, and How Long We Keep It

6.1 Primary Location: Canada

LiLoHome™ personal information is stored in Canada, on Amazon Web Services (Canada) infrastructure. Our primary records, consent records, audit logs, and operational logs reside in Canada only.

6.2 Cross-Border Transfers

Some of the service providers we use to operate LiLoHome™ are located outside Canada, and some information passes through them in the course of delivering the Service. Information held outside Canada may be subject to the laws of the jurisdiction where the provider operates, which may differ from Canadian law, including laws permitting government access in circumstances that differ from Canadian law.

6.3 How Long We Keep It

We keep personal information only as long as necessary to provide the Service and for the purposes described in Section 4, and as required by law — including legal and tax obligations, and the limitation periods that apply to legal claims. When information is no longer needed for those purposes, we delete or de-identify it.

Two periods are fixed by law or by our obligation to demonstrate lawful operation: billing and payment records are kept for seven (7) years as required by the Canada Revenue Agency, and signed consent records are kept for the duration of the customer relationship plus ten (10) years as evidence that consent was properly obtained.

7. Your Rights

7.1 Rights Available

Subject to applicable law, you have the following rights in respect of your personal information held by LiLo Health:

• Access. Request a copy of the personal information we hold about you, and an explanation of how we use it.
• Correction. Request that we correct information you believe is inaccurate or incomplete.
• Withdrawal of consent. Withdraw your consent to ongoing processing.
• Deletion or de-identification. Request that we delete or de-identify your personal information, subject to §7.4.

7.2 How to Make a Request

Send your request to privacy@lilohealth.care. We will acknowledge it promptly and respond within thirty (30) days, subject to any extension permitted under PIPA or PIPEDA. We may need to verify your identity first, typically by confirming information already on file or technical details of your installation. We generally do not request additional personal information in order to verify identity.

7.3 Effect of Withdrawing Consent

Resident. Withdrawal stops new insights being generated and ends Care Team access to the Resident’s insights through the App. Withdrawal does not, by itself, terminate the Customer Contract. Under the LiLoHome™ Membership Agreement, a Resident’s withdrawal does not cause the Account Owner to incur an early-exit fee.

Care Team Member. Withdrawal ends that person’s App access. It does not, by itself, terminate other contractual relationships.

Account Owner billing. Withdrawal of a Care Team Member’s or a Resident’s consent does not, by itself, terminate the Account Owner’s billing obligations, which are governed by the Customer Contract.

7.4 Effect of a Deletion Request

Where we accept a deletion request, we delete the personal information we hold about you, including tasks, notes, and Care Team messages. A Resident may request deletion of content about the Resident whether or not the Resident entered it, and the person who entered it cannot prevent that deletion.

Signed consent records and related audit records are de-identified rather than deleted, and kept as anonymous evidence that consent was obtained and the Service was operated lawfully. We do not attempt to re-identify them. Deletion may be delayed or limited where the law requires us to retain specific records. Where a request affects information held by a service provider, we will instruct that provider to give effect to it so far as the contract and applicable law permit.

8. Who We Share It With

8.1 Service Providers

We share personal information with service providers that perform functions on our behalf — including cloud hosting, payment processing, device data processing, electronic signature, and message delivery. They may use personal information only to perform those functions for us, and not for their own purposes.

8.2 Financing Parties

LiLo Health may assign, pledge, or grant a security interest in the amounts payable by the Customer under the Customer Contract to a financing party. Where it does, we share personal information with that financing party only to establish and administer that arrangement.

What is shared is limited to what the financing party requires for those purposes: the Customer’s identity and contact information, the address where LiLoHome™ is installed, and the amounts payable and paid under the Customer Contract. LiLoHome™ sensor information, Resident insights, and the categories described in §3.1 and §3.3 are never shared with any financing party.

A financing party is an independent organization, not a service provider acting on our behalf. The Customer does not enter into any credit agreement with a financing party, and no financing party acquires any right in the LiLoHome™ equipment or in the Resident’s personal information. If we add or replace a financing party, this Policy will be updated as described in §1.4.

8.3 Organizational Care Team Members

Where the Resident has authorized an organization — for example, a home-care agency — as an Organizational Care Team Member, the individuals that organization names receive access to the Resident’s insights in the same way as any other Care Team Member, and may enter the content described in §3.4.

An Organizational Care Team Member is a recipient authorized by the Resident, not a service provider acting on our behalf. Once that organization or its named individuals see or record information, the organization is responsible for how it collects, uses, retains, and discloses that information, under its own privacy policy and applicable law. The Resident may withdraw the organization’s access, or that of any individual named by it, at any time and without giving a reason.

8.4 Disclosures Required by Law

We may disclose information where required by law, by a valid court order, by a regulator, or to investigate and respond to suspected violations of our agreements, fraud, or threats to the security or integrity of the LiLoHome™ system or any person who uses it.

9. Security and Breach Notification

9.1 Security

We maintain reasonable physical, organizational, and technological security arrangements to protect personal information against loss, theft, unauthorized access, disclosure, copying, use, alteration, or destruction, appropriate to the sensitivity of the information. Personal information is encrypted in transit and at rest, and access within LiLo Health is restricted to personnel with an operational need. No system is completely secure, and we cannot guarantee that personal information will be secure from every attempt to circumvent our protections. Contact us immediately at privacy@lilohealth.care if you believe the security of your personal information has been compromised.

9.2 Breach Notification

If we determine that personal information has been compromised in a way that creates a real risk of significant harm to an affected individual, we will notify the affected individual(s) and the appropriate regulator (the OIPC BC and/or the OPC, as applicable) as soon as possible, and in any event within the timeframes required by PIPA and PIPEDA.

10. Text Messaging (SMS) Notifications

10.1 What This Section Covers

LiLo Health Ltd. offers Account Owners, Residents, and Care Team Members the option to receive certain transactional notifications from LiLoHome™ by SMS text message. This section explains how that option works and how we handle the mobile information you provide for it. It supplements, and does not replace, the rest of this Policy.

10.2 The Messages We Send

When you enable text messaging, we send transactional activity and account notifications related to the Service — for example, no-activity and other wellness notifications, and account or security notices. We do not send marketing or promotional text messages. Message frequency varies and depends on activity in the Resident’s home. Message and data rates may apply.

10.3 How You Opt In

Text messaging is off by default. To receive texts, an Account Owner, Resident, or Care Team Member turns on the “Text messages” setting in the LiLoHome™ application, provides a mobile number, and confirms that number by entering a one-time code we send to it by SMS. Consent to receive text messages is given for each mobile number and is never a condition of purchasing or using the Service. You can continue to use LiLoHome™ and receive notifications through other channels without enabling text messages.

10.4 How You Opt Out or Get Help

You can stop text messages at any time by replying “STOP” to any message; we will send one confirmation and then send no further texts to that number. Reply “HELP” for help, or contact us at privacy@lilohealth.care. You can also turn the “Text messages” setting off in the application.

10.5 How We Handle Your Mobile Information

Mobile information and SMS opt-in consent are not shared with, sold to, or rented to any third parties or affiliates for marketing or promotional purposes. We share your mobile number only with the messaging service providers that deliver these texts on our behalf, and only to deliver them, as described in §8.1.