Privacy Policy

1. Introduction

This Privacy Policy explains how Holo Technologies Inc. (“Holo Connect,” “we,” “us,” or “our”) collects, uses, shares, and protects your personal information when you use the Holo Connect mobile application (the “App”).

Holo Connect is a personal safety and wellness app that helps people stay connected to their chosen “care circle” through daily check-ins, medication reminders, activity sharing, and an emergency (“SOS”) alert. By creating an account or using the App, you agree to the practices described in this policy.

Holo Connect is not a medical device and is not a substitute for emergency services. In a life-threatening emergency, always call your local emergency number (e.g., 911).

2. Information We Collect

We collect only the information needed to operate the App’s safety and wellness features. The categories below reflect what we actually collect.

2.1 Information you provide

• Account information: your email address and password (passwords are handled by our authentication provider and are never visible to us in readable form).
• Profile information: your name, phone number, role (the person being cared for, or a caregiver), and time zone.
• Care-circle contacts: when you add a contact (a family member or friend), you provide their name, phone number, and email address so we can notify them on your behalf. You are responsible for having permission to share a contact’s information with us.
• Health and wellness information: medications and dose schedules you enter, your daily check-in status, and activity information you choose to record. This information reflects your own wellness activity and is shared only with the care circle you choose.
• Content you create: optional photos (“moments”) you attach to a check-in or share with your circle, and short activity notes.
• Activity assistant conversations: if you use the activity assistant to record an outing or a rest, the text of that conversation and your first name are sent to our AI provider (Anthropic) to turn what you said into an activity your circle can see. Because the assistant asks where you are going, this text often contains a place name or address. Do not type anything into the assistant that you would not want processed this way.
• Voice input: if you speak to the activity assistant instead of typing, your speech is converted to text on your device wherever your device supports it. If it cannot, your device falls back to Apple’s speech recognition service, and the audio is processed by Apple under Apple’s privacy policy. We never receive, store, or retain the raw audio — only the resulting text, which is then handled as described above.

2.2 Information collected automatically

• Location information: if you enable location, we collect your device location at the moment you check in, start or end an activity, or send an SOS, and share it with your care circle. We do not track your location continuously or in the background. Where we can identify a nearby street address for that location, that address is included in the push notification and text message your care circle receives. On the free plan, we do not keep your most recent location after the alert has been sent.
• Device and push information: a push notification token and basic device identifiers used to deliver alerts and reminders to your device.
• Usage and diagnostics: app events (for example, completing a check-in, viewing a screen, or a subscription action), crash reports, and performance data. We use this to understand how the App is used and to fix problems (see Section 6). You can turn this off — see Section 8.
• Update checks: each time the App launches it checks our update service (Expo) for a new version, which involves sending your app version and basic device information.

2.3 Information we do not collect

• We do not collect health or fitness data from Apple Health, HealthKit, or your device’s motion and step sensors. The App has no access to them.
• We do not collect your device’s contact list. Care-circle contacts are only those you manually enter.
• We do not use advertising identifiers, and we do not track you across other companies’ apps or websites.
• We do not sell your personal information.

3. How We Use Your Information

We use your information to:

• Create and manage your account.
• Deliver the App’s core features: daily check-ins, medication reminders, activity sharing, and SOS alerts.
• Notify your care circle by push notification and, where enabled, by SMS text message about your check-ins, missed check-ins, medication doses, activities, and emergencies.
• Share your location with your care circle at the moments described in Section 2.2.
• Process and manage subscriptions and entitlements.
• Diagnose crashes, fix bugs, improve reliability, and understand which features are used and where people have difficulty.
• Communicate with you about the App, including service and security notices.
• Comply with legal obligations and enforce our terms.

We do not send you marketing or promotional messages through the App. Every push notification and text message the App sends is a service message about a check-in, a medication, an activity, a moment, or an emergency. (If you separately joined our website mailing list, that is a separate opt-in you can unsubscribe from at any time.)

We do not use your health, location, or contact information for advertising, and we do not use it to build profiles for any purpose other than providing the App’s features.

4. Legal Bases for Processing

In Canada, we rely on your consent and applicable exceptions under the Personal Information Protection and Electronic Documents Act (PIPEDA). Consent is express where you enable location, notifications, or health-related features, and can be withdrawn at any time as described in Section 8. We also process information as necessary to perform our agreement with you, to secure and maintain the App, and to meet legal obligations.

5. How We Share Your Information

We share information only as described here. We do not sell your personal information.

5.1 With your care circle

The people you add as contacts (or who are linked to your account) receive the check-in, medication, activity, location, and emergency information you enable — that is the purpose of the App.

5.2 With SMS recipients

If SMS alerts are enabled, the contacts you designate receive text messages about your check-ins, medications, activities, and emergencies. Message recipients can opt out at any time by replying STOP. Standard message and data rates may apply.

Important limitation: SMS alerts are a paid-plan feature. On the free plan, the App sends alerts only by push notification to contacts who have the App installed and linked to your account. A contact who does not use the App will not be notified — including for an SOS. If you rely on someone who does not use the App, you need a paid plan for them to receive anything.

5.3 With service providers (sub-processors)

We use trusted third parties to operate the App. They may process your information only to provide services to us, under contractual confidentiality and security obligations:

5.4 For legal and safety reasons

We may disclose information if required by law, subpoena, or legal process, or where we believe in good faith that disclosure is necessary to protect the safety, rights, or property of you, us, or others.

5.5 Business transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or use of your information.

6. Analytics, Crash Reporting, and Session Replay

To improve the App and fix problems, we use PostHog for product analytics and session replay, and Sentry for crash and error reporting. You can turn all of this off in the App — see Section 8.

• Product analytics records app events (such as completing a check-in or viewing a screen) tied to a random account identifier — not to your name, email, or phone number. Event details are filtered before they are sent so that names, contact details, addresses, locations, and free text are removed.
• Session replay captures recordings of how people move through the App’s screens so we can find where users get stuck. All text and all images are masked. Names, medications, messages, addresses, and photos appear as blocked-out shapes, never as readable content — this includes text already displayed on a screen, not only text you type. We also do not record which buttons you tap, because a button’s label could itself reveal masked content. What remains is the shape and timing of your journey through the screens. If you would rather not be recorded at all, turn off “Help improve the app” in Settings.
• Crash reporting captures technical diagnostics when the App encounters an error, so we can fix it. Crash reports are tied to your account identifier only; we do not send your IP address or the contents of your requests to our crash-reporting provider.

This information is used solely to operate, secure, and improve the App. It is not used for advertising, is not sold, and is not shared with data brokers.

7. Data Retention

We keep your personal information for as long as your account is active or as needed to provide the App.

• Photos (“moments”) are automatically deleted after 30 days, from both our file storage and our database.
• When you delete your account (Settings → Delete Account), we delete your profile, check-ins, medications, contacts, activities, photos, and push tokens from our active systems, and we ask our analytics provider to delete your analytics records.
• What we keep after deletion: records of subscription and payment events, which we retain as financial records (these contain subscription identifiers and amounts, not your name, contact details, health information, or location); and crash reports, which our crash-reporting provider does not allow us to delete per-user and which age out on their own retention schedule. Crash reports are keyed to an account identifier that is no longer linked to any account after deletion.
• Deleting your account does not cancel your subscription. Subscriptions are billed by Apple and must be cancelled in your Apple account settings.
• Diagnostic, analytics, and replay data are otherwise retained on a rolling basis according to our providers’ retention settings and are then deleted or de-identified.

8. Your Rights and Choices

Depending on where you live, you may have the right to access, correct, delete, or receive a copy of your personal information, to object to or restrict certain processing, and to withdraw consent. You may also have the right not to receive discriminatory treatment for exercising these rights.

You can exercise these choices in the following ways:

• Access and correction: view and update your profile and settings directly in the App.
• Account deletion: delete your account and associated data at any time from Settings → Delete Account in the App, or by contacting us at the email below.
• Analytics, crash reporting, and session replay: turn off Settings → Help improve the app in the App. This stops all analytics events, session recordings, and crash reports from that device immediately.
• Location, notifications, camera, microphone: enable or disable these permissions at any time in your device settings; the App works with reduced functionality if you decline.
• SMS alerts: a recipient can stop messages at any time by replying STOP.

To make a request, contact us at hello@holoconnect.ca. We will respond within the time required by applicable law. We may need to verify your identity before acting on a request.

9. Security

We use industry-standard safeguards to protect your information, including encryption in transit, authenticated access, and server-side security rules that restrict access so that your data is visible only to you and the care circle you have authorized.

A small number of our personnel can access stored data where necessary to operate, support, secure, and troubleshoot the App, and to meet legal obligations. Such access is limited to what is needed for those purposes.

No method of transmission or storage is completely secure, so we cannot guarantee absolute security, but we work to protect your information and to promptly address any issues.

10. Age Requirement

Holo Connect is intended for adults. You must be 18 or older to create an account. We do not knowingly collect personal information from anyone under 18. If you believe someone under 18 has provided us information, contact us and we will delete it.

11. Where Your Information Is Processed

Holo Connect is available in Canada and the United States, and this policy applies to you wherever you use the App in those countries.

We and our service providers process and store your information in Canada and the United States. This means:

• If you are in Canada, your information may be stored in or accessed from the United States, where it may be subject to lawful access requests by United States authorities.
• If you are in the United States, your information may be stored in or accessed from Canada, where it may be subject to lawful access requests by Canadian authorities.

Where required, we use appropriate safeguards for these transfers. Some features that depend on telecommunications carriers — in particular text-message alerts — may become available in a country later than the App itself; the App tells you which alerting features are active on your account.

12. Region-Specific Disclosures

Canada (PIPEDA): You have the right to access and correct your personal information and to withdraw consent, subject to legal and contractual restrictions. You may address unresolved concerns to the Office of the Privacy Commissioner of Canada.

California (CCPA/CPRA): In the past 12 months we have collected the categories of information described in Section 2 and disclosed them to the service providers in Section 5 for business purposes. We do not sell or “share” (for cross-context behavioral advertising) personal information. California residents may exercise the access, deletion, correction, and opt-out rights described in Section 8, and may designate an authorized agent.

Other U.S. states: A number of states — including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and Montana — have comprehensive privacy laws giving residents rights to access, correct, delete, and obtain a copy of their personal information, and to opt out of targeted advertising, the sale of personal information, and certain profiling.

We do not sell personal information, do not use it for targeted advertising, and do not use it for profiling that produces legal or similarly significant effects — so those particular opt-outs do not arise. You may exercise the access, correction, deletion, and copy rights described in Section 8 wherever in the United States you live, by writing to hello@holoconnect.ca.

Some of these laws treat health information as sensitive and require your consent before it is processed; in the App, health-related information is information you choose to enter, and you can delete it at any time. If we decline a request, you may appeal by replying to our response or writing to the same address, and we will tell you the outcome and, where your state requires it, how to contact your Attorney General.

13. Holo Connect and Emergency Services

Holo Connect is a standalone app. It is important that you understand what it does and does not do in an emergency:

• When you send an SOS, the App notifies only the care-circle contacts you have chosen, by push notification and (on a paid plan) by text message.
• The App does not contact 911, any emergency dispatcher, any ambulance or police service, or any monitoring centre. No one is dispatched to you.
• Holo Connect is not connected to our medical-alert device business. The monitoring centre and support staff who handle our monitored devices have no access to Holo Connect accounts or data, and are not alerted by anything you do in the App.
• Your Holo Connect data is not used to provide, and is not shared with, the monitored device service.

In a life-threatening emergency, call 911 yourself. Holo Connect is a way to let the people you trust know you need help — it is not an emergency response service.

14. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the “Last updated” date above and, where appropriate, notify you in the App. Your continued use of the App after an update means you accept the revised policy.

15. Contact Us

If you have questions or requests regarding this Privacy Policy or your personal information, contact us at:

Holo Technologies Inc. Email: hello@holoconnect.ca Address: Suite 3400 - 10180 101 Street NW, Edmonton AB T5J 3S4