Privacy Policy

This Privacy Policy describes how Turtle AiP, Inc. (“Turtle AiP,” “we,” “us,” or “our”) handles personal information on our website and through any app, connected device, pilot, caregiver feature, or support service that links to this policy (together, the “Services”).

The website is hosted by Vercel and does not provide an onsite account, payment, or contact form. App- and device-related provisions apply when the relevant feature is offered and links to this policy.

People may use the Services for themselves or, when they have permission or other lawful authority, to support a family member or another person. If an organization, care provider, or other customer gives you separate privacy notices, those notices may also apply to its handling of your information.

Website. Vercel processes hosting and request data needed to deliver the site. The website does not load Google Analytics. YouTube receives request information when the Demo page loads its privacy-enhanced embeds. Email and phone links open the communication tools on your device.

Optional app, device, and pilot features. If those features are offered and enabled, the information involved may include:

If enabled in a future product, rules or automated systems may generate patterns, status indicators, or alerts from sensor and activity information. Those inferences can be sensitive and may qualify as consumer health data under applicable law.

• Directly from you when you register, configure a feature, or contact us.
• From a family member, caregiver, or organization that has authority to provide information and invite you to the Services.
• From connected devices and sensors that you choose to install or connect.
• From integrations you choose to use, such as identity, maps, notification, or care-coordination services.
• Automatically from the website, app, and supporting infrastructure when you use the Services.

• Provide, configure, maintain, and support requested features.
• Connect authorized family members or caregivers and deliver requested notifications, activity summaries, or alerts.
• Coordinate a service, appointment, or third-party provider when you ask us to do so.
• Authenticate users, manage linked-user access, and protect accounts and devices.
• Troubleshoot, measure reliability, prevent abuse, and improve the website or other features using information that is not consumer health data.
• Respond to questions, privacy requests, and other communications.
• Comply with law and establish, exercise, or defend legal claims.

We will not use consumer health data for an additional purpose without providing any notice and obtaining any consent required by law.

The website uses Vercel for hosting and YouTube for embedded videos. If future app, device, or pilot features launch, information may also need to be disclosed for the following purposes, subject to applicable notice and consent:

• People you authorize. Family members, caregivers, or other users you invite or direct us to contact.
• Service providers. Companies that help with hosting, cloud and device infrastructure, maps, authentication, notifications, email, video delivery, security, and support.
• Care or service organizations. A provider or organization you select or that provides a requested service, when sharing is needed for that request or otherwise authorized by you.
• Legal and safety recipients. Government authorities, professional advisers, or other parties when reasonably necessary to comply with law, protect rights and safety, investigate misuse, or respond to lawful process.
• Business transaction recipients. Parties involved in a financing, acquisition, reorganization, or sale, subject to appropriate confidentiality protections.

Turtle AiP does not sell personal information or consumer health data and does not use consumer health data for cross-context behavioral advertising. Website hosting and embedded media are described below.

Activity events, location, routines, symptoms, care requests, and insights derived from them may be treated as consumer health data. We apply additional restrictions where applicable, including consent requirements for certain collection or sharing and rights to access, withdraw consent, and request deletion.

Washington residents and people whose consumer health data is collected in Washington should read our separate Consumer Health Data Privacy Policy.

Not every health-related app or connected-device service is covered by the Health Insurance Portability and Accountability Act (HIPAA). HIPAA applies to protected health information handled by covered health care providers, health plans, clearinghouses, and their business associates.

If Turtle AiP's actual functions make it a covered entity or a business associate for a particular data flow, that information is governed by HIPAA and the applicable notice of privacy practices. A written agreement alone does not determine HIPAA status. Other health-related information handled directly for a consumer is governed by this policy and other applicable consumer-privacy laws, not automatically by HIPAA.

A Turtle AiP feature may use rules or other automated tools to identify patterns and create activity summaries or alerts. Outputs can be incomplete, delayed, or incorrect because they depend on device placement, connectivity, power, configuration, and the available data.

The Services are not a substitute for medical judgment or emergency services, and an automated output should not be used as the sole basis for a medical or safety decision. Call 911 or the appropriate local emergency number when someone may be in immediate danger.

Vercel processes request, device, and network information needed to deliver, secure, and maintain the website. The website does not load Google Analytics.

Demo pages embed videos using YouTube's privacy-enhanced domain. The embedded player contacts Google or YouTube when the Demo page loads, and further processing may occur when you play or interact with a video, under their own policies. Email and phone links open the communication tools on your device; the website does not currently operate a contact form.

Vercel and Google/YouTube retain website-related information under their applicable settings and policies.

We keep personal information only as long as reasonably necessary for the feature requested, security, support, legal obligations, and dispute resolution. When it is no longer needed, we delete or deidentify it, subject to lawful exceptions and limited backup retention.

We use administrative, technical, and physical safeguards appropriate to the active system and the sensitivity of its data. No security measure or transmission method is perfect. Do not send medical records, passwords, or similarly sensitive information through ordinary email.

Depending on where you live and how you use the Services, you may be able to:

• Confirm whether we process your information and access a copy.
• Correct inaccurate personal information.
• Delete information, subject to lawful exceptions.
• Withdraw consent for future processing where consent is the basis.
• Obtain information about certain third parties or categories of parties that receive your information.
• Appeal a decision on a privacy request.
• Opt out of sale, sharing for cross-context behavioral advertising, or qualifying automated decision-making if those activities occur and the law applies.

Submit a request through our data request instructions or email legal@turtleaip.com. We may need to verify your identity and authority. We will not discriminate against you for exercising a privacy right.

The Services are intended for adults and are not directed to children under 13. We do not knowingly collect personal information online directly from a child under 13 without the notices, parental controls, and verifiable consent required by law.

An adult who provides information about a child, dependent adult, or other person must have permission or other lawful authority to do so and must use the Services in that person's best interests.

We may update this policy to reflect changes to the Services, our practices, or the law. We will update the date above and provide additional notice when a change is material. When law requires consent before a new category or use of consumer health data, updating the policy alone is not enough; we will seek that consent before the new collection, use, or sharing begins.