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, shares, 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 this Policy on the signature page of the LiLoHome™ Customer Agreement. Care Team Members expressly consent to this Policy through the Care Team Member Terms of Use acknowledged at in-app sign-up. Residents expressly consent to this Policy through the Resident Participation Consent signed at installation.

1.2 How to Read This Policy

Unless otherwise defined in this Policy, this Policy uses the same defined terms as the Customer Agreement: Account Owner, Resident, Care Team Member, Arrangement A, Arrangement B, LiLoHome™, and Monthly Platform Subscription. Unless otherwise defined here, capitalized terms have the meanings given to them in the Customer Agreement.

1.3 Updates to This Policy

We may update this Policy from time to time. The current version, the version number, and the effective date are shown on the cover page of this document and on the published page at the website located at the domain https://lilohealth.care/privacy-policy/. Material changes will be communicated to Account Owners by email and through the LiLoHome™ application (the “App”), and will be posted to the online version of this Policy at https://lilohealth.care/privacy-policy/. Updates are effective when posted to the published location, 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 and your consent to the collection, use, and disclosure of your personal information as reflected in the updated Policy.

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™.

2.2 Privacy Contact

The dedicated channel for all privacy-related inquiries, requests, and complaints is:

Email: privacy@lilohealth.care

LiLo Health’s Privacy Officer may be contacted through this email address.

2.3 Domain

LiLoHome™ operates from the domain lilohealth.care, including the corporate website, this Policy, customer-facing pages, application endpoints, and email communications.

3. Personal Information We Collect

3.1 Categories of Information Collected from the Resident’s Home

LiLoHome™ collects information relating to patterns of daily living through devices installed in the Resident’s home. Information collected from devices installed in the Resident’s home 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 LiLo Health’s 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 Member and to LiLo Health’s operations team.

3.2 Categories Collected About Account Owners and Care Team Members

We collect the following information 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 Agreement, the Care Team Member Terms of Use, and the version of each document accepted.
• Billing data: the deposit, hardware payment, and Monthly Platform Subscription history; payment method tokens (we do not store full credit card numbers; tokenization is performed by our payment processor); refund and adjustment records.
• Customer support records: correspondence with our support team and notes from sales calls.

3.3 Categories Collected About Residents

We collect the following information about Residents:

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

3.4 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.

3.5 Sources of Information

We may collect additional information directly from you (during the sales call, at installation, in the App, and through support interactions); from the LiLoHome™ devices in the Resident’s home; and from our service providers in the course of delivering the Service (for example, payment confirmations from our payment processor and signing events from our electronic-signature provider).

4. Why We Collect Personal Information

We use personal information for the following purposes:

• To provide the Service. Operate the LiLoHome™ system and Service, present the activity timeline in the App and other information and analysis generated from gathered information, generate the contextual summaries, and deliver awareness notifications to authorized Care Team Members.
• To set up and manage accounts. Create, activate, secure, and recover Account Owner, Care Team Member, and Resident accounts.
• To bill and process payments. Charge the deposit, the hardware total (one-time or financed), and the recurring Monthly Platform Subscription; process refunds; manage receipts and invoices.
• To provide support. Diagnose system issues, respond to support requests, dispatch service visits, and operate the runbooks our operations team uses to keep the system running.
• To safeguard the Service. Detect and respond to security incidents, fraud, abuse, misuse, and unauthorized access; preserve audit records that allow us to demonstrate consent and operational integrity.
• To improve the Service. Analyze the operational performance of the Service, identify defects, and improve the qualified device fleet, in a manner consistent with this Policy and applicable law.
• To comply with our legal obligations. Meet our 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. The Lawful Basis: Express 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 Agreement, where the Customer is required to give express, separate consent to this Policy (in addition to consenting to be bound by the Customer Agreement itself).
• Resident Participation Consent is signed by the Resident (or, where applicable, by a substitute decision-maker as described in §5.3 of this Policy) at installation. It authorizes the collection, processing, storage, and sharing of the categories of data described in §3.1 of this Policy with Care Team Members identified at install or subsequently authorized.
• Care Team Member consent is captured through the Care Team Member Terms of Use acknowledged at in-app sign-up. It authorizes the processing of the Care Team Member’s own personal information described in §3.2 of this Policy.

5.2 Consent Versioning

Consent forms and policies are versioned. The version each person accepted is recorded with the consent record so we can demonstrate which version each person signed.

5.3 Capacity to Consent and Substitute Decision-Makers

LiLo Health expects the Resident to have the legal capacity required to give informed consent to participate in the Service. Where a Resident does not have that capacity, an appropriate substitute decision-maker (including under a power of attorney, representation agreement, or similar authority) may sign the Resident Participation Consent on the Resident’s behalf.

6. Where Your Information Is Stored

6.1 Primary Data Location: Canada

The primary storage location for LiLoHome™ personal information is in Canada, hosted on Amazon Web Services (Canada) infrastructure. The canonical record store, the read-model tables, the consent records, and the audit logs reside in Canada only.

6.2 Cross-Border Transfers in the Ordinary Course of Operating LiLoHome™

Some categories of LiLoHome™ data pass through service providers located outside Canada before reaching, or as part of reaching, the Canadian primary store. These transfers are necessary to operate certain devices in the LiLoHome™ system. The named jurisdictions through which LiLoHome™ data may pass are:

• Finland
• United States

Data residing on systems and servers located outside Canada may be subject to the laws of the jurisdictions where those providers operate and/or where the systems and servers are located, and may differ from Canadian laws, including laws that may permit governmental access to collected and stored personal information in circumstances that differ from Canadian law.

The named providers operating in each jurisdiction are listed in §9.1 of this Policy, and the specific kinds of personal information sent to each provider are also listed in §9.1 of this Policy. If LiLo Health adds a new sub-processor whose processing introduces a new named jurisdiction, this Policy will be updated and Account Owners will be notified before the change takes effect, as described in §9.2 of this Policy.

6.3 Operational Logs

Operational logs that record system performance and error states are also stored in Canada, with retention as described in Section 7 of this Policy.

7. How Long We Keep Your Information

We will retain your information for as long as needed to provide you with our Service, for our valid business purposes, and as necessary to comply with our legal obligations, resolve disputes, defend our legal rights, and enforce our agreements. You can request that we delete personal information about you in our possession. If you would like us to delete some or all of your personal information, or delete your account (if applicable), please contact us at privacy@lilohealth.care.

Unless specified otherwise below, LiLoHome™ data is retained for a minimum of ten (10) years from the date of collection, subject to the deletion and de-identification rights described in Section 8. The categories of LiLoHome™ data and the retention period applied to each category of data are summarized below.

Retention periods are subject to the deletion and de-identification rights described in Section 8 of this Policy.

8. Your Rights and How to Exercise Them

8.1 Rights Available

Subject to applicable law, you have the following with respect to 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 personal 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 the architecture and legal constraints described in §8.4 of this Policy.

8.2 How to Make a Request

Send your request to privacy@lilohealth.care. We will acknowledge your request promptly and respond within thirty (30) days, subject to any extension permitted under PIPA or PIPEDA. We may need to verify your identity before fulfilling certain requests. Identity verification typically involves confirming personal or billing information already on file, or technical details of your installation. We generally do not request additional personal information in the course of verifying identity.

8.3 Effect of Withdrawing Consent

You may withdraw your consent at any time, by writing to us at privacy@lilohealth.care or, where a self-service mechanism is available in the App, through the App.

• Resident. Withdrawal of consent stops generating new insights for the Resident and blocks Care Team Member access to the Resident’s insights through the App. Withdrawal does not, by itself, terminate the Customer Agreement or the Account Owner’s billing obligations. See the Customer Agreement for relevant terms and conditions for termination.
• Care Team Member. Withdrawal ends the Care Team Member’s App access. Withdrawing Care Team Member consent does not by itself terminate other contractual relationships (for example, the Account Owner’s responsibility for fees under the Customer Agreement).
• Account Owner billing. Withdrawal of a Care Team Member consent or a Resident consent does not by itself terminate the Account Owner’s billing obligations.

8.4 Effect of a Deletion or De-Identification Request

LiLo Health uses a hybrid deletion model that reconciles your right to deletion with our truth-preservation architecture:

• Operational data is hard-deleted, where deletion of such data is requested and we accept your deletion request. This includes account profile, contact information, notification preferences, application use data tied to the user, and the user’s identity link.
• Audit records and signed consent evidence are de-identified, not hard-deleted, and remain under our 10-year retention floor as truthful evidence that consent was captured, that signatures were collected, and that the Service was operated lawfully. After de-identification, the direct identifiers linking these records to you are removed, and the records are retained only as anonymous audit evidence of consent and operational events. LiLo Health does not attempt to re-identify these records, and they remain subject to the security controls described in Section 11 of this Policy.
• A 30-day customer-recovery window applies between the time we accept your deletion request and the time the deletion cascade executes. Within that window, you may cancel the deletion request.
• A legal hold may pause deletion of specific records where required (for example, where the data is the subject of an active investigation, regulatory inquiry, or pending data-subject request). Where a legal hold applies, we will tell you that part of your request is paused, without disclosing any applicable privileged information about the nature of the hold.

8.5 Service Providers and Sub-Processors

When you exercise a right that affects information held by a sub-processor (for example, a payment processor token), we will instruct the sub-processor to give effect to your request to the extent the contract and applicable law permit.

9. Sub-Processors and Service Providers

We may share the categories of personal information described above with service providers that we partner with to assist us in various functions, including providing technological support and performing security and anti-fraud services, providing you with our services where applicable, and providing you with communications and marketing information on our behalf.

9.1 Named Sub-Processors

LiLo Health uses the following named sub-processors in the ordinary course of operating LiLoHome™. The list is published here so it can be updated as the Service evolves; the current published list governs.

LiLo Health relies on the standard data processing terms of each service provider listed below, rather than custom-negotiated Data Processing Agreements.

9.2 Adding or Changing Sub-Processors

We may engage new sub-processors or replace existing ones. Where a new sub-processor changes the cross-border posture (for example, introducing a new jurisdiction outside Canada) or materially expands the categories of personal information processed, we will update this Policy and notify Account Owners as described in §1.3 of this Policy before the change takes effect. Where a change materially affects how your personal information is processed, you may request changes to how your personal information is handled, and you have the right to cease use of the Service in response.

9.3 Third-Party Financiers

Where the Customer elects to finance the hardware total under §4.4 of the Customer Agreement, LiLo Health shares personal information with the third-party financier named in the Customer Agreement for the purposes of the financing application and the ongoing servicing of the financing arrangement.

The categories of personal information shared are limited to what the financier requires for those purposes: the Customer’s identity and contact information, the home address where LiLoHome™ is installed, and the hardware quote or invoice amount to be financed. LiLoHome™ sensor information, Resident insights, and the categories described in §3.1 and §3.3 of this Policy are never shared with any financier.

A third-party financier is an independent organization, not a sub-processor of LiLo Health. Once shared, the information is handled under the financier’s own privacy policy and applicable law, and the financier is responsible for its collection, use, retention, and disclosure practices, including any credit checks it performs.

No personal information is shared with any financier unless the Customer elects financing. Customers who pay the hardware total directly are not subject to this section. If LiLo Health replaces or adds a named financier, this Policy will be updated as described in §9.2.

10. 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 to your complaint, subject to applicable laws and regulations, you may escalate your complaint to:

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

11. Security

We strive to implement reasonable measures to protect your personal information against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and any other unauthorized access or use. We aim to ensure that the level of security and the measures adopted to protect your personal information are appropriate for the risks presented by the nature and use of your personal information. However, we cannot guarantee that your personal information will be secure from theft, loss, alteration, misuse, or unauthorized access, nor do we make any representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such information. We are not responsible for any attempt made by a third party to circumvent our privacy and security protocols. Please immediately contact us at privacy@lilohealth.care if you believe that the security of your personal information has been compromised.

We protect personal information using technical and organizational measures, including:

• Encryption at rest for the canonical record store, application data stores, and stored secrets.
• Encryption in transit for all communications between LiLoHome™ devices, the App, and our cloud, using current industry-standard transport encryption.
• Access controls at the application layer, including role-based, relationship-based, and attribute-based controls. Consent gates prevent disclosure of a Resident’s information to anyone who does not have current consent. Internal access by LiLo Health personnel is granted on a least-privilege basis.
• Logging and monitoring of operational events, with critical-severity alerts routed to the LiLo Health operations team in real time.
• Account-level security, including strong password requirements and multi-factor authentication where offered.

12. Breach Notification

If LiLo Health determines 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.

13. 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 who manage and view the resulting insights. The Service is not directed to children, and we do not knowingly collect personal information from children for any purpose other than the limited circumstance in which a child may incidentally appear on a sensor reading (for example, a grandchild visiting the Resident’s home, whose presence may be reflected in a motion event).

If you believe a child’s personal information has been collected outside the limited incidental circumstance described above, please contact us at privacy@lilohealth.care.

14. Effective Date and Versioning

This Policy is identified by a version number and an effective date on the cover page. The current version supersedes all earlier versions. Earlier versions of the Policy are retained internally as audit evidence under the retention rules described in Section 7 of this Policy.