Privacy Policy

This Privacy Policy describes how ActivoCare LLC ("ActivoCare," "we," "our," or "us") collects, uses, processes, stores, shares, protects, and deletes information obtained through the ActivoCare Wellness App (ActivoCare Wellness App).

ActivoCare Wellness App is a wellness application designed to help individuals make informed lifestyle, nutrition, wellness, and preventive health decisions through personalized recommendations, health insights, physiological assessments, artificial intelligence ("AI") assisted features, progress tracking, and optional premium subscription services.

This Privacy Policy applies to all users of the Application regardless of whether the Application is accessed through Apple's App Store, Google Play Store, or any other authorized distribution platform.

By downloading, installing, accessing, registering for, or otherwise using the Application, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, processing, use, storage, disclosure, and protection of your information as described herein.

If you do not agree with this Privacy Policy, you should not install or use the Application.

This Privacy Policy applies to:

This Privacy Policy does not apply to third-party websites, applications, devices, or services that are not owned or controlled by ActivoCare.

Apple App Store Users

If you downloaded the Application through Apple's App Store, your use of the Application is also governed by Apple's Standard Licensed Application End User License Agreement ("Apple Standard EULA"), available at: apple.com/legal/internet-services/itunes/dev/stdeula

In the event of any conflict between this Privacy Policy and the Apple Standard EULA regarding privacy matters, this Privacy Policy shall govern the processing of your personal information by ActivoCare.

Google Play Users

If you downloaded the Application through Google Play, your use of the Application is also subject to Google's applicable terms and policies in addition to this Privacy Policy.

Personal Information means information that identifies, relates to, describes, or can reasonably be associated with an identifiable individual.

Health Information means wellness, nutrition, physiological, lifestyle, fitness, biometric, and health-related information that you voluntarily provide or authorize the Application to access.

Face Data means any information obtained from images or video captured through your device camera during physiological measurements, including facial images, facial landmarks, facial geometry, or any derived facial characteristics used solely for physiological signal extraction.

Physiological Measurements means wellness-related measurements estimated through the Application using approved technologies, including but not limited to heart rate estimation, respiratory rate estimation, stress indicators, wellness trends, and similar physiological metrics.

Artificial Intelligence ("AI") Services means machine learning and large language model technologies used to generate personalized wellness recommendations, educational content, nutritional guidance, and other Application functionality.

Third-Party Service Provider means a vendor engaged by ActivoCare to provide services necessary for operation of the Application, including cloud hosting, authentication, analytics, AI processing, physiological measurement technologies, subscription verification, customer support, and application security.

ActivoCare Wellness App is intended exclusively as a wellness and lifestyle support application. The Application is not a medical device, unless expressly stated otherwise under applicable regulatory approvals.

The Application does not provide medical advice, medical diagnosis, clinical treatment, emergency medical services, or replace consultation with qualified healthcare professionals. Any physiological measurements, wellness insights, AI-generated recommendations, nutritional guidance, or educational content provided through the Application are intended solely to support general wellness and healthy lifestyle decisions.

Users should always seek the advice of a qualified physician or other licensed healthcare provider regarding any medical condition or before making healthcare decisions. Never disregard professional medical advice or delay seeking treatment because of information obtained through the Application.

If you believe you are experiencing a medical emergency, immediately contact your physician or local emergency services.

What personal information do we process? When you visit, use, or navigate our Services, we process personal information depending on how you interact with us, the choices you make, and the features you use.

Do we process sensitive personal information? Yes. With your explicit consent or as permitted by law, we may process sensitive categories such as health data, biometric data, genetic data, and precise geolocation.

Do we collect information from third parties? We may collect data from public databases, marketing partners, social media platforms, connected health/fitness platforms, and other outside sources.

How do we process your information? We process your information to provide, improve, and administer our Services, deliver personalized longevity insights, process transactions, communicate with you, ensure security and fraud prevention, and comply with applicable laws.

When and with whom do we share personal information? We share information in specific situations and with vetted service providers (e.g., cloud hosts, AI providers, payment processors) bound by strict confidentiality obligations.

How do we keep your information safe? We maintain technical and organizational safeguards to protect your personal data. However, no internet transmission or electronic storage is 100% secure.

What are your rights? Depending on your geographical location, applicable privacy laws grant you specific rights to access, correct, delete, or limit the processing of your personal data.

How do you exercise your rights? You can submit a data subject access request or contact us directly at contactus@activocare.com.

1.1 Personal Information You Disclose to Us

We collect personal data that you provide when registering on the Services, expressing interest in our products, participating in activities, or contacting us. This includes:

1.2 Mobile Application Access & Device Data

If you use the ActivoCare App, we may request permission to access specific features on your mobile device:

Note: You may adjust these permissions at any time within your mobile device's settings menu.

1.3 Information Collected Automatically

When you interact with our Services, our systems automatically collect:

1.4 Information from Other Sources

We may receive data from external sources, including:

1.5 Health and Wellness Information

With your permission, ActivoCare Wellness App collects wellness-related information necessary to provide personalized wellness features. Depending on how you use the Application, this information may include:

Physiological Measurements

If you choose to use the physiological assessment feature, the Application may display wellness-related measurements generated using the Shen.AI SDK, including where supported:

These measurements are intended solely for general wellness purposes and should not be relied upon for medical diagnosis, treatment, or emergency medical decisions.

1.6 Camera and Face Data

Certain wellness assessment features require temporary access to your device camera. Camera access is requested only after you provide permission through your device's operating system. The camera is used solely to enable contactless physiological measurements through the Shen.AI SDK.

During these assessments, the following categories of face-related information may be processed by the Shen.AI SDK:

ActivoCare does not use this information for:

ActivoCare does not create biometric templates or maintain facial recognition databases. Raw facial images, facial recordings, facial landmarks, and other temporary facial processing data are not stored by ActivoCare after processing is completed. ActivoCare receives only the physiological measurement values produced by the Shen.AI SDK that are necessary to provide wellness reports and historical trends.

Facial Scan's Wellness SDK is a software development kit designed to analyze real-time video data from a device camera to provide informational physiological metrics for general wellness, self-awareness, and lifestyle purposes, including heart rate (HR), heart rate variability (HRV), breathing rate (BR), and blood pressure (BP).

Key Characteristics

1.7 HealthKit Information

If you choose to enable Apple HealthKit integration, the Application may access only the HealthKit data categories that you explicitly authorize through Apple's HealthKit permission system. ActivoCare Wellness App never accesses HealthKit information without your permission. You may revoke HealthKit access at any time through the Apple Health application or your device settings.

HealthKit information is used exclusively to:

HealthKit data is never sold, used for advertising, or shared with data brokers.

1.8 Wearable Device Information

If you connect supported wearable devices, the Application may receive wellness information through authorized integrations, including the Spike SDK or other supported wearable providers. Examples include:

Only the measurement values required to provide Application functionality are stored.

1.9 Artificial Intelligence (AI) Data

When you use AI-powered features, the information necessary to generate responses may be transmitted securely to our AI service providers. Depending on the feature used, this information may include:

This information is transmitted only after you provide your explicit consent within the Application. AI processing is performed solely for the purpose of generating personalized wellness guidance, educational information, nutritional recommendations, and Application functionality. The Application does not use your personal information to train public AI models without your consent.

1.10 Information We Do Not Collect

ActivoCare does not knowingly collect:

Payments are processed directly by Apple, Google, or their authorized payment processors.

We process your personal information for specific legitimate business purposes:

2.1 Providing the Application

2.2 Personalized Wellness Services

Information you voluntarily provide allows the Application to generate personalized wellness experiences. Depending on the features you use, your information may be used to:

These recommendations are intended solely for general wellness purposes and are not medical advice.

2.3 Physiological Measurements

If you choose to use the physiological assessment feature, information processed through the Shen.AI SDK is used solely to:

The physiological measurements displayed within the Application are intended only for wellness monitoring and educational purposes. They are not intended to diagnose, treat, cure, monitor, or prevent any disease or medical condition and should not be relied upon as a substitute for professional medical advice or medical-grade equipment.

2.4 Artificial Intelligence Services

ActivoCare Wellness App includes optional Artificial Intelligence ("AI") features that help users better understand wellness information and provide educational guidance. When you voluntarily use an AI feature, certain information necessary to generate a response may be securely transmitted to our AI service provider(s). Depending on your request, this may include:

No information is transmitted to an AI service until you have been informed of the processing and provided your explicit consent within the Application. AI services are used exclusively to generate educational wellness information, provide nutrition guidance, explain wellness measurements, answer wellness-related questions, provide lifestyle recommendations, and improve user experience.

AI-generated responses are intended solely for informational and educational purposes. They do not constitute medical advice, diagnosis, treatment, or emergency healthcare. Users should consult qualified healthcare professionals before making medical decisions.

Medical Disclaimer: The AI chat provides non-clinical information intended solely for data compilation and general wellness insights. It is not a substitute for professional medical advice, diagnosis, or health analysis. Users should not rely on this information for clinical decision-making; always consult a healthcare professional for medical concerns. To enhance wellness monitoring, anonymized (non-identifiable) data is processed using AI models referenced against trusted medical sources, including PubMed, the WHO, the CDC, the American Heart Association, and the NIH.

2.5 Camera and Face Data Processing

Certain features require temporary camera access to perform contactless physiological assessments. Face-related information is processed solely for physiological signal extraction and wellness measurement generation. Face data is never processed for:

ActivoCare does not build or maintain facial recognition databases. We do not identify individuals from facial images. We do not sell face data. We do not license face data. We do not use face data to train facial recognition models.

2.6 HealthKit Information

If you authorize Apple HealthKit access, HealthKit information is used only to:

HealthKit information is never used for advertising, marketing, sale to third parties, or data broker activities. HealthKit data is accessed only after you grant permission through Apple's HealthKit authorization system. You may revoke access at any time through Apple Health settings.

2.7 Wearable Device Information

Where supported, wearable device information received through authorized integrations is used solely to:

Wearable information is processed only after you authorize the connection.

2.8 Customer Support

If you contact our support team, we may use information you provide to:

2.9 Application Improvement

We may use aggregated and de-identified information to:

Aggregated or de-identified information does not identify individual users.

2.10 Legal Compliance

Information may be processed where reasonably necessary to:

2.11 Information We Never Use For

Unless expressly required by law, ActivoCare does not use your information for:

2.12 User Consent

ActivoCare Wellness App respects your privacy choices. Where required by applicable law or platform requirements, the Application requests your consent before:

You may withdraw previously granted permissions at any time through your device settings or by discontinuing use of the applicable feature. Withdrawal of consent will not affect processing that occurred before consent was withdrawn but may limit the availability of certain Application features.

We may share your personal data with third parties in the following circumstances:

3.1 Third-Party Service Providers

ActivoCare Wellness App utilizes trusted third-party service providers to operate and improve the Application. Depending on the features you choose to use, your information may be processed by one or more of the following categories of providers.

3.1.a Shen.AI SDK (Physiological Measurements)

ActivoCare Wellness App integrates the Shen.AI SDK to enable contactless physiological assessments using your device camera. When you voluntarily initiate a physiological assessment, the SDK temporarily processes live camera frames; facial regions and facial landmarks necessary for physiological signal extraction may be processed; remote photoplethysmography (rPPG) signals may be analyzed; and signal quality may be evaluated. This processing occurs solely to generate wellness-related physiological measurements.

ActivoCare does not receive or store:

ActivoCare receives only the physiological measurement values generated by the SDK that are necessary to display wellness information within the Application. Shen.AI processes information solely for the purpose of generating the requested physiological measurements and may not use the information for advertising, profiling, facial recognition, or any independent commercial purpose on behalf of ActivoCare.

3.1.b Artificial Intelligence Service Providers

ActivoCare Wellness App includes optional AI-powered features that generate educational wellness information and personalized responses. When you voluntarily use AI features and provide your consent, information necessary to generate the requested response may be securely transmitted to our AI service provider(s). Depending on your request, this may include:

Information is shared solely for the purpose of generating the response you requested. AI service providers are not authorized to use your information for advertising, marketing, profiling, or any unrelated purpose on behalf of ActivoCare. Where required by applicable agreements, ActivoCare requires AI service providers to maintain privacy and security protections that are equal to or greater than those described in this Privacy Policy.

3.2 Cloud Infrastructure Providers

We use secure cloud infrastructure providers to support application hosting, secure storage, database management, backup services, disaster recovery, and system monitoring. These providers process information only as necessary to provide hosting and infrastructure services.

3.3 Authentication Providers

Authentication providers help users securely access their accounts. Depending on the login method selected, authentication providers may process email address, encrypted authentication credentials, authentication tokens, and account identifiers. Authentication providers do not receive your wellness history except where technically required to authenticate your account.

3.4 Analytics Providers

ActivoCare Wellness App may use analytics services to understand how users interact with the Application. Analytics information may include application version, device type, operating system, feature usage, session duration, crash reports, and performance metrics. Analytics providers do not receive your personal wellness history unless necessary to investigate a technical issue. Where possible, analytics information is aggregated or de-identified before analysis.

3.5 Customer Support Providers

If you contact customer support, service providers assisting with customer support may process your contact information, support messages, diagnostic information, and account identifiers. This information is used solely to resolve your inquiry.

3.6 Subscription and Payment Providers

Subscription purchases are processed exclusively through the Apple App Store and Google Play Store. ActivoCare does not receive or store credit card numbers, debit card numbers, banking information, or payment card security codes. ActivoCare receives only limited purchase verification information necessary to verify subscriptions, enable premium features, restore purchases, and prevent fraud.

We collectively refer to web cookies, clear GIFs/pixels, and mobile software development kits (SDKs) as "Cookies."

Categories of Cookies Used

Managing Your Cookie Preferences

Our Services integrate AI-powered tools ("AI Products") provided by trusted third-party artificial intelligence platform vendors (such as OpenAI).

We retain personal information for active account maintenance, legal compliance, financial auditing, and resolving disputes. Unless a longer retention period is required by applicable law (such as tax or legal hold requirements), we will not retain your personal information for longer than six (6) months following the deactivation or termination of your account.

When data is no longer needed, we securely delete, anonymize, or isolate it in encrypted backup archives until permanent erasure is feasible.

Express Consent for Third-Party Disclosures

Where you request that ActivoCare LLC share your health, biometric, or genetic data with a designated external party (e.g., a personal physician or health consultant), we will do so only upon receiving your explicit, written, affirmative consent. You may revoke this consent at any time by contacting contactus@activocare.com.

Receipt of Returned Clinical / Third-Party Data

If you authorize an external health provider or clinical service to transmit records (e.g., lab data, medication entries, treatment observations) back to our platform, we process this "Returned Clinical Data" as heightened sensitive information solely to personalize your longevity insights and care support.

Data Security Safeguards

We maintain reasonable and appropriate physical, technical, and administrative safeguards designed to protect your data. However, please note that no internet-connected platform or electronic database is completely secure. Transmission of personal information to and from our Services is at your own risk, and you should access the Services within a secure network environment.

Our Services are intended exclusively for adults aged 18 and older. By using the Services, you represent that you are at least 18 years of age. If we learn that personal information from users under 18 years of age has been collected without verified parental consent, we will deactivate the account and promptly delete the data. If you believe we hold data from a minor under 18, please contact us immediately at contactus@activocare.com.

Depending on your geographic location (e.g., US states, UK, EEA), you hold specific statutory privacy rights:

To exercise any of these rights, please submit a request by emailing contactus@activocare.com.

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference. Because no uniform industry standard for recognizing DNT signals has been universally adopted, our systems do not currently respond to automated DNT browser signals. If a binding legal standard is established in the future, we will update this Privacy Notice accordingly.

If ActivoCare is involved in a merger, acquisition, corporate restructuring, financing, sale of assets, or similar transaction, personal information may be transferred as part of that transaction. If such a transfer materially affects your privacy rights, we will provide notice where required by applicable law.

Face data receives enhanced protection within ActivoCare Wellness App. Accordingly:

Raw facial images and temporary facial processing data are not retained by ActivoCare after physiological processing is complete. Only the physiological measurement values necessary to provide requested wellness features may be stored within your account.

ActivoCare requires every third-party service provider that processes personal information, health information, physiological measurements, or face data on our behalf to maintain privacy and security protections that are equal to or greater than those described in this Privacy Policy. Third-party service providers are contractually prohibited from:

Your information may be processed or stored in countries outside your country of residence. Where international transfers occur, ActivoCare implements appropriate safeguards designed to protect your information in accordance with applicable privacy laws.

ActivoCare LLC is headquartered in the United States, and we process and store data within the U.S. and other international jurisdictions. If you access the Services from outside the United States (e.g., EEA, UK, Middle East, Asia-Pacific), your data will be transferred across international borders. We utilize standard contractual clauses and appropriate regulatory safeguards to ensure your personal information receives equivalent protection regardless of where it is processed.

ActivoCare does not share personal information, health information, or face data for:

You control many aspects of information sharing through the Application and your device settings. You may choose whether to:

Disabling certain permissions may limit the availability or functionality of specific features, but you may continue using other parts of the Application where possible.

Residents of U.S. states with comprehensive privacy statutes (including Pennsylvania, California, Colorado, Connecticut, Virginia, Texas, and others) possess specific data management rights.

Summary of Collected Categories (Past 12 Months)

Disclosures, "Sales", and Targeted Advertising

ActivoCare LLC does not sell your personal data or health information for monetary payment. However, engaging third-party advertising or analytics cookies may be categorized as a "sale" or "sharing" for targeted advertising under certain state privacy statutes.

You may opt out of cross-context behavioral advertising and tracking by emailing contactus@activocare.com or disabling non-essential cookies in your app settings.

This Privacy Policy and any disputes or claims arising out of or in connection with it or its subject matter shall be governed by, construed, and enforced in accordance with the laws of the Commonwealth of Pennsylvania, United States of America, without regard to its conflict of law principles.

Yes. We update this notice periodically to maintain legal and operational compliance and to reflect changes in applicable laws, updates to the Application, introduction of new features, changes to third-party service providers, and improvements to privacy practices.

The revised version will be indicated by an updated "Last Updated" date at the top of this page. If material changes are made, we will notify you via a prominent in-app notice, website banner, or direct email notification, where required by applicable law.

Continued use of the Application after changes become effective constitutes acceptance of the revised Privacy Policy.