ELOVEE, INC. PRIVACY POLICY

Elovee, Inc. is a leading-edge conversation software designed to provide day-to-day support for seniors. Elovee, Inc.’s online application named Elovee (“Elovee”) is designed to offer seniors with dementia (“Seniors”) and their caregivers the ability to connect with a friend or family member at a moment's notice using a fully-responsive, interactive digital version of them (also known as their “digital persona”).

Purpose of the Privacy Policy

Your privacy is very important to us. As part of our commitment to respecting your privacy, we want you to be fully aware of what happens to the personal information we collect:

·      when you use Elovee, Inc.’s website located at www.elovee.com, and any subdomains and portals, (“Website”);

·      when you log into the Website or Elovee to:

o   as a friend or family member to provide information (including audio, video, photographs, images, and other relevant information), including for the creation of your digital persona;

o   in your capacity as care-givers, social workers and support workers of Seniors, including those located at the Senior’s senior living residence or assisted living facility (“Resident Caregiver”);

·      when a Resident Caregiver logs into the Website or Elovee on your behalf;

·      when you use Elovee on a portable electronic device such as an iPad, tablet or smart phone;

·      from your Resident Caregiver, family member or relative;

·      when you sign up or request Elovee, Inc.’s services;

·      when you take part in any research or testing that Elovee, Inc. is conducting, including of Elovee or Website; and

·      any other interactions you may have with us (by telephone, email, and in person).

Accordingly, this Privacy Policy (“Policy”) outlines the way Elovee, Inc. and its affiliates collect, use, disclose, and retain your personal information.

When you submit personal information to Elovee, Inc., including as an Senior or on a voluntary basis as part of your participation to support a Senior, or authorize us to obtain personal information from other sources (such as through your Resident Caregiver), you are agreeing to be bound by this Policy, in addition to any other applicable privacy policies, such as those provided by your senior residence facility. Additionally, by using Elovee, Website or any of Elovee, Inc.’s interactive services, you signify your acceptance of this Policy, and the Terms of Use posted on the Website.

What is Personal Information?

Personal information is any information that can be used to identify an individual or that we can link directly to an individual, such as name, contact information, date of birth, gender, health information, voice prints, and an individual’s picture/digital image.

This Policy is not intended to cover information other than personal information, such anonymous information.

Your Consent

Elovee, Inc. will obtain your consent (through this Policy or other means) to collect, use, and/or disclose personal information, except where we are authorized or required by law to do so without consent.

How We Collect Information

 Elovee, Inc.’s three primary sources of information are:

·      You, as a Senior;

·      You, as a family member or friend of a Senior; and

·      You, as a Resident Caregiver of a Senior.

We may also collect de-identified, non-personal and technical information from you, as described in more detail below.  In addition, we may collection information about you from affiliates/partners (such as from the senior living residences more broadly) and third parties.

What personal information does Elovee, Inc. collect?

Here is a little more detail on the types of personal information we may collect for each of the three main categories.

Senior:

·      Background information, such as: name, date of birth, gender, contact information, emergency contact information;

·      confirmation of your dementia diagnosis and your language preference. The senior living residence shall provide Elovee, Inc. with access to this information, but Elovee Inc. will not store or retain any such information;

·      Resident Caregiver’s understandings and observations of the Senior’s usage of Elovee, including changes in behavior and mood levels (before, during, and after using Elovee) as well as any other relevant Senior responses and reactions;

·      Family member or friend’s observations relating to relating to a Senior’s use of Elovee;

·      Recording of you interacting with Elovee, including audio and video; and

·      where the Senior has the requisite capacity, direct feedback from the Senior.

Family Members, Friends

·      Background information, such as: name, date of birth, gender, contact information, relationship with Senior;

·      Authentication information, including to authenticate relationship with the Senior;

·      Login information;

·      Recording of you interacting with Elovee, including audio and video;

·      Audio clips, video clips, photographs, images and other information required to create digital personas; and

·      Feedback relating to your experience, preferences and observations of the effect on the Senior.

Resident Caregiver

·      Background information, such as: name, position, employer;

·      Login information; and

·      Recording of you interacting with Elovee. For instance, while you observe or assist the Senior using Elovee your image may also be recorded;

·      Authentication information, including to choose the appropriate Senior from a list of Seniors at your senior residence facility;

·      Feedback relating to your experience, preferences and observations of the effect on the Senior. This may include observations, rankings, notes and opinions of the Senior’s interaction with Elovee, including changes in their behavior and moods as well as well as any other relevant Senior responses and reactions.

When does Elovee, Inc. collect personal information?

We collect personal information about you from your interactions with us and other sources, such Resident Caregivers. We may collect personal information:

·      when you request information about Elovee, Inc. or Elovee, Inc.’s products and services, including for demonstrations of Elovee;

·      when you request to enroll and/or take part in any research or testing that Elovee, Inc. is conducting, including of Elovee or Website;

·      when you sign-up or register:

o   to become a user as a Senior or on behalf of a Senior for the purposes of registering the Senior to use Elovee;

o   as a family member, relative, or friend of the Senior;

o   as a Resident Caregiver;

·      from your use of or interaction with Elovee, including audio and video recording(s) of you interacting with Elovee;

·      from the Resident Caregiver, who may observe and provide feedback to Elovee, Inc. on an Senior’s use of and interaction with Elovee;

·      when you, in your role Resident Caregiver, provide Elovee, Inc. with information about an Senior’s use of Elovee, Inc.’s products and services, including Elovee;

·      when you use the Website or Elovee to provide information (including audio, video, photographs, images) on behalf of the Senior or to assist the Senior in their use Elovee, Inc.’s products and services (such as Elovee), including for the creation of your digital persona;

·      when you are being trained to use Elovee, Inc.’s products and services, including Elovee;

·      when you request Elovee, Inc.’s assistance or support (technical, organizational etc.) in relation to Elovee, Inc.’s products and services. For example, to assist you in troubleshooting an issue you may have while using Elovee to create your digital persona or uploading information to the Website;

·      when you respond to one of our promotions, polls or surveys;

·      when subscribe to one of our online newsletters, or register to participate in an online forum; or

·      when you contact us (such as via email, telephone, and the internet) with an enquiry, comment or suggestion.

Elovee, Inc. will not collect information indiscriminately and will limit collection of personal information to that which is reasonable and necessary for the purposes it was collected or as authorized by law.

Optional Information

In some cases, it may be optional for you to provide certain personal information, but in other cases the information may be required to provide access to Elovee, Website or other services

Occasionally, we may request information about your interests and preferences. In most instances, you do not have to provide us with this information to receive the product or service you have requested. We use this optional demographic and preference information to tailor or improve our product and service offerings, as well as for internal marketing research purposes.

In all cases where you voluntarily provide personal information to Elovee, Inc., we only collect, use and disclose it in accordance with this Policy and applicable law.

 

Elovee Usage Tracking

Elovee, Inc. may automatically collect passive anonymous, non-personal and/or technical information relating to the use of and interaction with Elovee. We use this information to improve the design and content of Elovee, to develop other product and service offerings, and for our internal research and business purposes.

Device and Location Information

We may collect information from and about the devices you use. For example, we collect:

·      information about your hardware and software, such as the hardware model, operating system version, device memory, advertising identifiers, unique application identifiers, apps installed, unique device identifiers, browser type, language, battery level, and time zone;

·      information from device sensors, such as accelerometers, gyroscopes, compasses, microphones, and whether you have headphones connected; and

·      information about your wireless and mobile network connections, such as mobile phone number, service provider, and signal strength.

Collection Through Cookies

We may also obtain general anonymous information related to your use of our Website, through cookies and similar technologies. A cookie is a small data file that a website may write to your hard drive when you visit. A cookie file can contain information (such as a user ID) that the website can use to track the pages you have visited and to record your preferences for future visits.

We do not collect personal information that can identify you when browsing our Website. However, certain non-identifying information such as an IP address, device identifier, internet tags and navigational data may be collected to understand how, when, and for how long a user visits our Website. In addition, we may use third party cookies that track how you use the Website to target advertisements to you on other websites.

Information gathered from our Website via cookies may be used by Elovee, Inc. for statistical purposes, allowing it to evaluate and analyze the access frequency to its Website and related usage information, and understanding your preferences based on previous or current Website activity. We may also use such information to provide you with to offer you services & products, and to improve our products & services. We may also use cookies to help us compile aggregate data about Website traffic and Website interaction so that we can offer better Website experiences and tools in the future.

You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended on the Website. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser. For more information on blocking cookies visit http://www.allaboutcookies.org/.

Collection Through Google Analytics

Elovee, Inc. also uses Google Analytics, a web analytics tool from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses information obtained by the cookies to evaluate your use of the Website for us, to create reports on Website activities and to provide further services related to the Website and the internet usage for us. This information may be transmitted to a server in the USA and stored there. Please note that Google Analytics information may be disclosed to marketing agency partners that use the data to optimize marketing campaigns. Google will not associate your IP address with any other data held by Google. For more information on Google’s privacy policy in general and Google Analytics, please visit their website at <www.google.ca/policies/privacy/> and <www.google.com/analytics>. You can deactivate the Google Analytics function with a browser add-on, which you can download at <https://tools.google.com/dlpage/gaoptout>. To do this you must install that browser add-on. This will prevent the analysis information from being sent to Google.

How We Use Information

Elovee, Inc. may use personal information:

·      to deliver the services of Elovee;

·      to create, further develop, modify, update, troubleshoot, and monitor for quality control purposes your digital persona, including using artificial intelligence and machine learning algorithms to further develop your digital persona;

·      to communicate with you about your use of Elovee and Website, new features, and respond to your enquires, including to confirm and authenticate your identity and ensure that your information is correct and accurate;

·      to request feedback to find out if Elovee is working well for you and how you used it;

·      to tailor the content and information that we send or display, determine your preferences, and help personalize and provide instructions to improve your experience of Elovee;

·      to administer surveys, or request feedback to improve and manage our relationship with you;

·      to understand how you use our products, content and services, for analytics, internal business purposes, and product development purposes, developing new products and services and (where appropriate) to personalize offers that we make to you;

·      to market our products and services to you and to other prospective users;

·      for training and quality assurance purposes, including training Resident Caregivers, other Seniors, family members;

·      to assist us and such third parties in studying, evaluating, managing and improving our products and services, including Elovee and Website;

·      to enhance the safety and security of our products and services;

·      establish and maintain communication with employees, investors, and business partners;

·      to comply with our legal obligations; and

·      to fulfil other purposes related to any of the above.

We may also de-identify, aggregate or anonymize information to identify trends, manage the organization, develop statistical information, understand how we are performing, or develop relevant programs, initiatives, training, and events. Such information may also be shared with third parties for other analytical purposes but will not personally identify any individual; and therefore, is not personal information subject this Policy.

How We Share Information

Other than in connection with the use of personal information and de-identified/aggregate data as specified herein, Elovee, Inc. will never sell, rent, trade, exchange or barter your personal information to or with any third party for financial gain or marketing purposes.

Senior Care Facility Staff

Your personal information, including as a Senior or a family member or friend of the Senior, may be disclosed to a Resident Caregiver. For instance, a Resident Caregiver may be able to view your digital persona while assisting a Senior to use Elovee.

Other Family Members, Friends and Relatives

While Elovee, Inc. does not intentionally disclose or provide access to the personal information of family members or friends to individuals other than the Senior and their Resident Caregivers, such personal information, including digital personas and pre-recorded videos, may be disclosed to others depending on how the Senior uses Elovee. For example:

·      when an Senior is using Elovee while family members, friends or others who are visiting with or in the same room as the Senior; or

·      if a Senior shares their login information with others.

Service Providers and Third Parties

Elovee, Inc. only discloses your personal information to third party organizations, with the consent of the individual, that assist us in providing services or who perform functions on our behalf, or as required by law.

In all cases, the third-party is contractually bound to comply with Elovee, Inc.’s Policy and applicable privacy laws, and to maintain the confidentiality of all personal information that Elovee, Inc. provides to it.  The contracts with third parties also require them to take reasonable precautions to protect the personal information in its possession and to destroy such personal information upon completion.

Legal Reasons

We may share information about you if we reasonably believe that disclosing the information is needed to:

·      comply with any valid legal process, governmental request, or applicable law, rule, or regulation.

·      investigate, remedy, or enforce potential Terms of Use violations.

·      protect the rights, property, and safety of us, our users, or others.

·      detect and resolve any fraud or security concerns.

 

 

Mergers or Acquisitions

If Elovee, Inc. gets involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that organization before and after the transaction closes.

Minors

The permission from a parent or a guardian is required for any person under the age of eighteen (18) years or a minor as defined under applicable law (a “Minor”) to participate in Elovee, Inc.’s products and services and any activity organized by Elovee, Inc. If any activity specifically targets a Minor, the permission of a parent or a guardian will be expressly required.

We do not seek nor will we knowingly collect personal information from Minors. Our website content and services are intended for users over the age of 18. If we learn that a Minor has volunteered personal information on our Website or Elovee, or that an individual or user has volunteered information about an individual who is identified as a Minor, we will take measures to delete such information from our systems.

Safeguarding Information

We take precautions to protect personal information in our custody and control. Personal information is safeguarded by appropriate physical measures (i.e., restricted access to offices), organizational measures (i.e., limiting access on a need-to-know basis), and technological measures (i.e., passwords and other online security measures), commensurate to the sensitivity of the information. Unfortunately, no collection or transmission of information over the Internet or otherwise can be guaranteed to be 100% secure, and therefore, we cannot ensure or warrant the security of any such information.

Your online access to certain of your personal information may be protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or emails).

Retention of Personal Information

Elovee, Inc. retains personal information only for the amount of time needed to fulfil the purposes for which it was collected or as permitted by law, after which the personal information is destroyed or made anonymous.

Access to Your Personal Information

You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law.

You may request to access, update and correct inaccuracies in your personal information that we have in our custody or control by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of any individual seeking access to their personal information records.

Contact Us

If you have any questions or concerns about this Policy or about Elovee, Inc.’s handling of your personal information, please contact us in writing at:

Address:          10 Hudson Yards, 46th Floor

                         New York, NY 10001

Email:              support@elovee.com

Please note that we may need to confirm your identity or request additional details to process your request.

Changes to Our Policy

Elovee, Inc. reserves the right to change this Policy at any time, without notice, in its sole discretion. This Policy will be updated periodically to reflect changes to our personal information practices and services. The revised Policy will be made available on our Website. We will treat your personal information in accordance with the Policy in place at the time of collection of such information, or as you otherwise consent. Whenever you need to refer to this Policy you should refer to this Website to ensure you have the most up to date version.

This Policy was last updated in n, 2019