Privacy Policy

1. Important Information About Warm-Hello

Warm-Hello is a communication and check-in service designed to help individuals maintain routine check-ins with designated personal contacts.

Warm-Hello is not a medical alert system, medical monitoring service, personal emergency response system (PERS), healthcare service, or emergency-response service.

Warm-Hello does not determine whether a person is safe, healthy, injured, ill, incapacitated, or experiencing an emergency.

A missed check-in does not mean that an emergency has occurred.

Warm-Hello does not contact 911, police, fire departments, ambulance services, hospitals, physicians, or other emergency-response organizations on behalf of users.

In an actual or suspected emergency, users should immediately contact 911 or the applicable local emergency service.

2. Information We Collect

The information we collect depends on how you interact with Warm-Hello.

2.1 Account Information

When you create an account, we may collect:

• Name;
• Email address;
• Password or authentication information;
• Telephone number;
• Account preferences;
• Subscription information;
• Billing status;
• Country or province/state;
• Time zone;
• Account creation date; and
• Other information necessary to establish and administer your account.

2.2 Senior Information

If you use Warm-Hello to enroll another person as a Senior, we may collect information such as:

• Senior’s name;
• Senior’s telephone number;
• Preferred check-in schedule;
• Check-in preferences;
• Time zone;
• Notification preferences;
• Check-in response status; and
• Other information necessary to provide the Service.

You are responsible for obtaining any consent or authorization required before providing another person’s personal information to Warm-Hello.

2.3 Emergency Contact Information

We may collect information about designated personal contacts, including:

• Name;
• Telephone number;
• Email address;
• Relationship to the Senior, if provided;
• Notification preferences; and
• Notification or communication status.

You must only provide emergency-contact information for individuals who have authorized you to provide their information to Warm-Hello and who have agreed to receive applicable notifications.

Warm-Hello does not verify whether an emergency contact is qualified, available, or capable of responding to a notification.

2.4 Check-In Information

Warm-Hello may collect information necessary to operate the check-in functionality, including:

• Date and time a check-in was scheduled;
• Date and time a check-in message was sent;
• Whether a response was received;
• Date and time a response was received;
• Whether a scheduled check-in was missed;
• Notification status;
• Delivery status where provided by telecommunications or messaging providers; and
• Related technical logs.

A check-in response or missed check-in is an operational event. It is not a medical, health, safety, or emergency determination.

2.5 Communications

We may collect and retain information concerning communications with Warm-Hello, including:

• Customer-support requests;
• Emails;
• Feedback;
• Communications with our support personnel;
• Requests to cancel an account;
• Billing inquiries; and
• Other communications you voluntarily provide.

Warm-Hello’s operational SMS functionality is intended to facilitate check-ins and notifications.

2.6 Payment Information

Payments may be processed by Stripe or another third-party payment processor.

Warm-Hello does not intentionally store complete payment-card numbers.

We may receive and retain information such as:

• Transaction amount;
• Currency;
• Subscription type;
• Billing status;
• Transaction date;
• Payment status;
• Last four digits of a payment card, where provided by the payment processor;
• Card brand;
• Billing country; and
• Other transaction information supplied by the payment processor.

Payment processors may separately collect and process payment information under their own privacy policies and terms.

2.7 Device and Technical Information

When you access the Service, we may automatically collect technical information, including:

• IP address;
• Browser type;
• Operating system;
• Device type;
• Device identifiers;
• Language settings;
• Time zone;
• Approximate geographic location derived from IP address;
• Pages or screens viewed;
• Referring website;
• Dates and times of access;
• Session information;
• Error logs;
• Diagnostic information;
• Security information; and
• Other technical information necessary to operate, secure, and improve the Service.

2.8 Cookies and Similar Technologies

We may use cookies, pixels, tags, SDKs, local storage, APIs, and similar technologies.

These technologies may be used for:

• Authentication;
• Security;
• Fraud prevention;
• Account functionality;
• Preferences;
• Analytics;
• Performance monitoring;
• Conversion measurement;
• Advertising;
• Retargeting;
• Campaign attribution; and
• Website and Service improvement.

Where applicable law requires consent before non-essential technologies are used, Warm-Hello will obtain the required consent.

3. How We Use Personal Information

We may use personal information for the following purposes:

3.1 Providing the Service

We use personal information to:

• Create and manage accounts;
• Enroll Seniors;
• Schedule check-ins;
• Send check-in prompts;
• Receive check-in responses;
• Identify missed check-ins;
• Send missed-check-in notifications;
• Send account communications;
• Provide customer support;
• Process subscriptions;
• Process payments;
• Maintain account security; and
• Otherwise provide functionality requested by the customer.

3.2 Security and Fraud Prevention

We may use information to:

• Detect and prevent fraud;
• Detect unauthorized access;
• Protect accounts;
• Investigate security incidents;
• Prevent abuse;
• Maintain system integrity; and
• Protect Warm-Hello, users, and third parties.

3.3 Analytics and Improvement

We may use information to:

• Understand how users interact with the Service;
• Identify technical problems;
• Improve features;
• Improve usability;
• Measure performance;
• Conduct internal analysis; and
• Develop and improve the Service.

3.4 Communications

We may use contact information to provide:

• Transactional communications;
• Operational communications;
• Security notifications;
• Account notices;
• Billing notices;
• Service announcements;
• Customer support; and
• Marketing communications where legally permitted.

3.5 Advertising and Marketing

Warm-Hello may use advertising and measurement services to:

• Advertise Warm-Hello;
• Measure advertising effectiveness;
• Measure website conversions;
• Understand campaign performance;
• Attribute registrations or purchases to advertising campaigns;
• Limit repetitive advertisements;
• Detect fraudulent advertising activity;
• Build or use permitted audience segments; and
• Improve advertising campaigns.

Warm-Hello may advertise through services operated by third parties, including Google and Meta.

Warm-Hello will operate advertising technologies in accordance with applicable privacy laws and applicable consent or opt-out requirements.

4. Advertising, Google, Meta, Analytics, and Retargeting

Warm-Hello may use third-party advertising and analytics technologies on its website and other digital properties.

These technologies may include cookies, pixels, tags, APIs, SDKs, conversion tracking, and similar technologies.

Depending on the technology and applicable law, information may include:

• IP address;
• Browser information;
• Device information;
• Cookie identifiers;
• Advertising identifiers;
• Pages visited;
• Website interactions;
• Advertisement interactions;
• Conversion events;
• Approximate location;
• Referring URL;
• Date and time of activity; and
• Other technical or usage information.

Warm-Hello may use this information to measure advertising campaigns, understand website traffic, and deliver or measure advertisements.

Warm-Hello may use Google Ads, Google Analytics, Meta advertising technologies, and comparable advertising or analytics services.

Third-party advertising providers may process information according to their own privacy policies.

Warm-Hello does not intentionally provide advertising platforms with:

• Senior check-in message contents;
• SMS opt-in or consent records for independent advertising purposes;
• Emergency-contact information for independent advertising purposes;
• Medical information; or
• Detailed health information

for those platforms’ independent advertising or behavioral-targeting purposes.

Warm-Hello will not intentionally use the contents of private Senior check-in communications to create advertising audiences.

Where applicable law requires consent before advertising or analytics technologies are activated, Warm-Hello will obtain the required consent.

Where applicable law provides a right to opt out of targeted advertising, sale, sharing, or similar processing, Warm-Hello will provide the applicable mechanism.

5. Cookies and Privacy Choices

Warm-Hello may use the following categories of technologies.

5.1 Strictly Necessary Technologies

These technologies may be necessary to:

• Authenticate users;
• Maintain account sessions;
• Protect accounts;
• Prevent fraud;
• Maintain security;
• Process transactions;
• Store required preferences; and
• Provide core Service functionality.

Where permitted by law, strictly necessary technologies may operate without consent because they are necessary to provide the Service requested by the user.

5.2 Analytics Technologies

Analytics technologies help us understand:

• Website traffic;
• Product usage;
• Technical performance;
• Conversion rates;
• User journeys; and
• Advertising effectiveness.

Where legally required, non-essential analytics technologies will only be activated after the required consent is obtained.

5.3 Advertising Technologies

Advertising technologies may be used for:

• Advertising;
• Retargeting;
• Conversion measurement;
• Campaign attribution;
• Audience measurement;
• Fraud prevention; and
• Advertising optimization.

Where required by applicable law, users will be given the ability to consent to or decline applicable technologies.

5.4 Your Privacy Choices

Depending on your jurisdiction, Warm-Hello may provide:

• A cookie consent banner;
• A privacy preference center;
• A “Your Privacy Choices” link (click Your Privacy Choices to open it now);
• An opt-out mechanism for targeted advertising;
• An opt-out mechanism for the sale or sharing of personal information where applicable; or
• Other legally required privacy controls.

You may also configure your browser to restrict certain cookies.

Disabling certain technologies may affect the functionality of the website or Service.

6. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients where reasonably necessary for the purposes described in this Privacy Policy.

6.1 Service Providers

We may disclose information to vendors and service providers that help us operate the Service, including providers for:

• Cloud hosting;
• Database infrastructure;
• SMS and telecommunications;
• Email delivery;
• Payment processing;
• Customer support;
• Security;
• Analytics;
• Advertising;
• Website infrastructure;
• Software development;
• Error monitoring;
• Fraud prevention; and
• Other business functions.

Service providers are expected to process personal information only for authorized purposes and in accordance with applicable contractual obligations.

6.2 Designated Contacts

Where the Service is configured to send a notification to a designated contact, the applicable information may be disclosed to that contact.

For example, a missed-check-in notification may disclose:

• The Senior’s name;
• The fact that a scheduled check-in response was not received; and
• Information necessary to identify or understand the notification.

Warm-Hello does not disclose medical diagnoses or detailed medical records through routine check-in notifications.

6.3 Payment Providers

Payment information may be disclosed to payment processors for purposes including:

• Processing transactions;
• Verifying payments;
• Preventing fraud;
• Managing subscriptions;
• Processing refunds; and
• Maintaining payment records.

6.4 Advertising and Analytics Providers

We may disclose technical, usage, and advertising-related information to analytics and advertising providers as described in this Privacy Policy.

We will not intentionally disclose Senior check-in message content, medical information, or emergency-contact information to advertising providers for their independent advertising purposes.

6.5 Legal and Regulatory Disclosure

We may disclose personal information where reasonably necessary to:

• Comply with applicable law;
• Respond to valid legal process;
• Respond to subpoenas, warrants, court orders, or governmental requests;
• Protect our legal rights;
• Investigate fraud or abuse;
• Protect the safety or security of users or the public; or
• Prevent or investigate suspected unlawful activity.

Where legally permitted, we may seek to limit requests to information reasonably necessary for the applicable legal purpose.

Where legally permitted and reasonably practicable, we may provide notice to affected individuals concerning certain government or legal requests.

6.6 Business Transfers

Personal information may be disclosed or transferred as part of:

• A merger;
• Acquisition;
• Corporate reorganization;
• Financing;
• Sale of assets;
• Sale of the company; or
• Similar business transaction.

Where required by applicable law, Warm-Hello will provide notice and/or obtain consent for such a transfer.

6.7 With Your Direction or Consent

We may disclose personal information when you direct us to do so or where you have provided applicable consent.

7. SMS and Text Messaging

Warm-Hello may use SMS messaging to provide check-in prompts, missed-check-in notifications, account communications, and other operational communications.

SMS delivery depends on third-party telecommunications carriers, networks, devices, and other infrastructure.

Warm-Hello does not guarantee that any SMS message will be:

• Delivered;
• Delivered on time;
• Received;
• Read;
• Heard;
• Understood; or
• Responded to.

Warm-Hello does not sell, rent, license, or provide SMS opt-in information or text-message consent records to third parties for their own marketing purposes.

Operational SMS messages are intended to contain service-related information.

Where applicable law requires consent, disclosures, or an opt-out mechanism for a particular communication, Warm-Hello will comply with those requirements.

Recipients may use available unsubscribe mechanisms, including STOP where applicable, to stop eligible SMS communications.

HELP may be used where supported to request assistance.

Stopping SMS communications may prevent Warm-Hello from functioning as intended.

Standard message and data rates may apply.

8. Health and Medical Information

Warm-Hello is not designed to collect, maintain, or process medical records or detailed health information.

Warm-Hello does not intentionally solicit:

• Diagnoses;
• Medical records;
• Treatment information;
• Medication information;
• Physician instructions;
• Insurance information;
• Detailed medical history; or
• Other sensitive medical or health information.

Users should not enter or transmit such information through the Service.

If health or medical information is voluntarily submitted despite these restrictions, Warm-Hello may delete or remove that information where reasonably practicable and may take other appropriate measures.

Warm-Hello does not intentionally use Senior health information for advertising or behavioral targeting.

Warm-Hello is not a HIPAA-covered entity or business associate solely by virtue of providing the Service. The Service should not be used to transmit information that is required to be handled through a HIPAA-compliant system.

Nothing in this section is intended to exclude any privacy or data-protection obligation that applies to Warm-Hello under applicable law.

9. Children’s Privacy

The Service is intended for adults.

Warm-Hello does not knowingly collect personal information from children under 13 in the United States or from children below the applicable age of consent in other jurisdictions where applicable law imposes a higher age requirement, without legally required parental or guardian consent.

If we learn that we have collected personal information from a child in circumstances where collection was not legally permitted, we will take reasonable steps to delete the information.

Parents or legal guardians who believe a child has provided personal information to Warm-Hello may contact us at:

sales@warm-hello.com

10. Data Retention

Warm-Hello retains personal information for as long as reasonably necessary to:

• Provide the Service;
• Maintain accounts;
• Process subscriptions;
• Maintain transaction records;
• Provide customer support;
• Meet legal and regulatory obligations;
• Resolve disputes;
• Enforce agreements;
• Prevent fraud;
• Maintain security; and
• Protect legitimate business interests.

Retention periods vary depending on the type of information and the purpose for which it was collected.

When personal information is no longer reasonably required, Warm-Hello will take reasonable steps to delete, anonymize, or securely dispose of it, subject to applicable legal, regulatory, security, backup, and recordkeeping requirements.

Backup copies may remain for a limited period after deletion in accordance with applicable backup and disaster-recovery procedures.

11. Security

Warm-Hello uses reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, loss, or destruction.

Depending on the circumstances, safeguards may include:

• Access controls;
• Authentication controls;
• Encryption in transit;
• Encryption or other protections for stored information where appropriate;
• Logging and monitoring;
• Security updates;
• Vendor controls;
• Least-privilege access;
• Backup and recovery procedures; and
• Incident-response procedures.

No method of transmission, storage, or electronic security is completely secure.

Accordingly, Warm-Hello cannot guarantee that personal information will never be accessed, disclosed, altered, lost, or destroyed through circumstances beyond our reasonable control.

12. Cross-Border Processing

Personal information may be stored or processed in Canada, the United States, or other jurisdictions where Warm-Hello or its service providers operate.

When personal information is transferred to a jurisdiction outside the individual’s home jurisdiction, Warm-Hello will take reasonable contractual, technical, and organizational measures appropriate to the circumstances to protect the information and comply with applicable privacy laws.

Personal information processed in the United States may be subject to lawful access by U.S. federal, state, or local authorities under applicable U.S. law.

Warm-Hello does not voluntarily disclose personal information to government authorities except where required or permitted by applicable law, valid legal process, or an applicable emergency or safety exception.

Where legally permitted, Warm-Hello will use reasonable efforts to limit government requests to the information legally required and to notify affected individuals when legally permitted and reasonably practicable.

Warm-Hello maintains written contractual privacy and security requirements for applicable service providers and limits provider access to personal information to purposes necessary to provide their contracted services.

13. Canadian Privacy Rights

Warm-Hello is committed to complying with applicable Canadian privacy legislation.

Depending on the circumstances and jurisdiction, Canadian individuals may have rights concerning their personal information, including:

• The right to request access to personal information;
• The right to request correction of inaccurate information;
• The right to withdraw consent where permitted by law;
• The right to request information about how personal information is collected, used, and disclosed;
• The right to make a privacy complaint; and
• Other rights provided by applicable federal, provincial, or territorial privacy legislation.

Warm-Hello will process privacy requests in accordance with the law applicable to the individual and the circumstances.

Certain information may be exempt from access, correction, deletion, or other requests where an applicable legal exception applies.

14. Quebec Privacy Rights

If you are located in Quebec, additional rights may apply under Quebec privacy legislation, including the Act respecting the protection of personal information in the private sector and other applicable laws.

Where applicable, individuals may have rights relating to:

• Access;
• Correction;
• Withdrawal of consent;
• Information concerning the use and disclosure of personal information;
• Data portability;
• Privacy impact assessments;
• Automated processing;
• Retention and destruction; and
• Other rights provided by Quebec law.

Warm-Hello will comply with mandatory Quebec privacy requirements applicable to its activities.

Nothing in this Privacy Policy is intended to waive or restrict a mandatory right provided by Quebec law.

15. United States Privacy Rights

Warm-Hello is committed to complying with applicable U.S. federal and state privacy laws.

Depending on your state of residence and whether the applicable law applies to Warm-Hello, you may have rights concerning your personal information.

These rights may include:

• The right to know or access personal information;
• The right to correct inaccurate personal information;
• The right to request deletion of personal information, subject to legal exceptions;
• The right to obtain a portable copy of certain personal information;
• The right to opt out of the sale of personal information;
• The right to opt out of sharing personal information for cross-context behavioral advertising or targeted advertising where applicable;
• The right to limit certain uses of sensitive personal information where applicable;
• The right to opt out of certain profiling or automated decision-making activities where applicable;
• The right to appeal certain privacy-request decisions where required;
• The right to use an authorized agent where permitted; and
• The right not to receive discriminatory treatment for exercising applicable privacy rights.

Not every right applies in every jurisdiction or to every individual.

16. California Residents

If you are a California resident and the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), applies to Warm-Hello, you may have rights including:

• The right to know and access personal information collected about you;
• The right to request deletion of personal information, subject to statutory exceptions;
• The right to correct inaccurate personal information;
• The right to obtain certain information in a portable format;
• The right to opt out of the sale of personal information;
• The right to opt out of the sharing of personal information for cross-context behavioral advertising;
• The right to limit certain uses of sensitive personal information, where applicable;
• The right to opt out of certain profiling or automated decision-making activities, where applicable;
• The right to appeal certain decisions concerning privacy requests; and
• The right not to be discriminated against for exercising CCPA rights.

16.1 Sale of Personal Information

Warm-Hello does not sell personal information for monetary consideration.

Warm-Hello does not sell, rent, license, or otherwise provide SMS opt-in information or text-message consent records to third parties for their own marketing purposes.

16.2 Sharing for Advertising

Certain uses of third-party advertising, analytics, pixels, cookies, or similar technologies may constitute “sharing” under the CCPA even where Warm-Hello does not receive monetary consideration for the disclosure.

If Warm-Hello engages in processing that constitutes “sharing” under the CCPA, Warm-Hello will provide the applicable opt-out mechanism.

California residents may use the “Your Privacy Choices” mechanism provided on the Warm-Hello website where applicable:

16.3 Sensitive Personal Information

Warm-Hello does not intentionally collect detailed health information through the Service.

Where sensitive personal information is collected or processed, Warm-Hello will handle that information in accordance with applicable California law.

16.4 Non-Discrimination

Warm-Hello will not discriminate against a California consumer for exercising rights protected by the CCPA.

16.5 Verification

Warm-Hello may require reasonable identity verification before completing certain privacy requests.

The verification process will be designed to protect personal information against unauthorized disclosure.

17. Other U.S. State Privacy Laws

Residents of states with comprehensive privacy legislation may have additional rights depending on:

• Their state of residence;
• The applicability of the relevant statute;
• The effective date of the statute;
• Applicable statutory thresholds; and
• The nature of Warm-Hello’s activities.

Warm-Hello will honor rights required by applicable state privacy laws.

These rights may include rights concerning:

• Access;
• Correction;
• Deletion;
• Portability;
• Sale;
• Sharing;
• Targeted advertising;
• Sensitive personal information;
• Profiling;
• Appeals;
• Authorized agents; and
• Other rights provided by applicable state law.

Where a state law provides a specific request deadline, verification procedure, appeal process, or other requirement, Warm-Hello will follow the applicable legal requirement.

18. Privacy Requests

To submit a privacy request, contact:

When permitted by law, we may request information reasonably necessary to verify your identity before fulfilling a privacy request.

If you use an authorized agent, we may require proof of authorization where permitted or required by applicable law.

We will respond to valid privacy requests within the time required by applicable law.

If additional time is legally permitted and reasonably necessary, we may extend the response period and provide the required notice.

19. Appeals

Where applicable law provides a right to appeal a decision concerning a privacy request, you may submit an appeal by contacting:

sales@warm-hello.com

The appeal should identify the original request and explain why you believe the decision should be reconsidered.

Warm-Hello will process the appeal in accordance with applicable law.

20. Do Not Track

Some browsers provide “Do Not Track” signals.

Because there is currently no universally accepted technical standard governing all Do Not Track signals, Warm-Hello may not respond to every such signal.

Where applicable law requires Warm-Hello to recognize a browser-based or device-based opt-out preference signal, Warm-Hello will take reasonable steps to recognize and process the signal as required by applicable law.

21. Third-Party Services and Websites

The Service may contain links to third-party websites, applications, or services.

Warm-Hello does not control third-party privacy practices.

Third-party services may collect, use, and disclose information under their own privacy policies.

This Privacy Policy does not apply to independent third-party websites or services.

You should review the privacy policies of third-party services before providing personal information to them.

22. Advertising Platforms

Warm-Hello may use third-party advertising platforms, including Google and Meta.

These companies may independently process certain information according to their own privacy policies and terms.

Warm-Hello does not control the independent privacy practices of third-party advertising platforms.

Warm-Hello’s use of advertising technologies is intended to comply with applicable law and the restrictions described in this Privacy Policy.

23. Business and Legal Records

Warm-Hello may retain certain information for legitimate business and legal purposes, including:

• Transaction records;
• Subscription records;
• Tax records;
• Consent records;
• Communications records;
• Security logs;
• Privacy requests;
• Legal correspondence;
• Fraud-prevention records; and
• Records necessary to establish, exercise, or defend legal claims.

Such information may be retained even after an account is closed where reasonably necessary for those purposes or where required by law.

24. Changes to This Privacy Policy

Warm-Hello may update this Privacy Policy from time to time.

Changes may be made to reflect:

• Changes in applicable law;
• Changes to the Service;
• Changes to our business practices;
• New features;
• New service providers;
• Changes to advertising or analytics technologies;
• Security improvements; or
• Other legitimate business requirements.

When we make material changes, we will provide notice through an appropriate method where required by applicable law.

The updated Privacy Policy will include a revised effective date.

Your continued use of the Service after the effective date of an updated Privacy Policy may constitute acknowledgment of the changes where permitted by applicable law.

Where applicable law requires affirmative consent to a material change, Warm-Hello will obtain the required consent.

25. Contact Us

For privacy questions, requests, complaints, or concerns, contact:

We encourage users to contact us first so that we can attempt to address privacy concerns directly.

Individuals may also have the right to file a complaint with the applicable privacy regulator or governmental authority in their jurisdiction.

26. Privacy Policy Summary

For clarity, the most important points are:

• Warm-Hello collects information necessary to provide its check-in and notification service.
• Warm-Hello does not intentionally collect detailed medical information.
• Warm-Hello is not an emergency or medical alert service.
• A missed check-in does not mean that an emergency has occurred.
• Warm-Hello does not contact 911 or emergency services.
• SMS delivery cannot be guaranteed.
• Personal information may be processed in Canada, the United States, and other jurisdictions where Warm-Hello or its service providers operate.
• Warm-Hello may use Google, Meta, analytics, advertising, and conversion-measurement technologies.
• Warm-Hello does not intentionally provide Senior check-in message contents, medical information, or emergency-contact information to advertising platforms for their independent advertising purposes.
• Warm-Hello does not sell personal information for monetary consideration.
• Warm-Hello does not sell, rent, license, or provide SMS opt-in information or text-message consent records to third parties for their own marketing purposes.
• Where applicable law provides privacy choices concerning targeted advertising, sale, sharing, or similar processing, Warm-Hello will provide the required mechanisms.
• Users may contact Warm-Hello at sales@warm-hello.com regarding privacy requests or concerns.