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Sengira Health Technology
Privacy Policy

PRIVACY POLICY (HIPAA / PHIPA / PIPEDA)

Sengira complies with applicable privacy laws including, HIPAA (USA), PHIPA (Ontario), and PIPEDA (Canada) when dealing with your personal information and sensitive information.

We may while providing our services (“Services”) to you be required to collect your personal information or sensitive information. This Privacy Policy is intended to explain how we and our related entities will collect and protect your privacy.

Personal Information

Personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable. All personal information received in connection with Sengira Health Technologies is subject to strict rules of confidentiality.

Common examples include your name, signature, address, telephone number, date of birth, bank account details, billing and credit card details, photos of you and commentary or opinion about you. For the purposes of this Policy, there is no meaningful distinction between the terms “personal information” and “personal data”.

Sensitive Information

Throughout the course of collecting your personal information, we may collect sensitive information about you.

Sensitive information includes:

1. information or an opinion about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices or criminal record that is also personal information; or

2. health information about an individual, genetic information about an individual that is not otherwise health information, biometric information that is to be used for the purpose of providing the Services, automated biometric verification or biometric identification or a biometric template.

Collection & Usage

If we do collect any of your sensitive information, we will only collect it in accordance with Canadian Privacy Principles. This means that we will only collect this information with your consent and for reasons that are reasonably necessary or otherwise related to the provision of our Services.

Where you consent to our collection of sensitive information, we use it for the purposes explained in this policy. Sending care recipient information to a third-party AI service for the Enhanced Daily Digest requires a separate affirmative choice, as explained below.

Personal information that we may collect from you

We may collect some or all the following types of personal information and sensitive information:

Collected Information

1. information that you give us through your dealings with us.

2. information that we may collect from you including from any Sengira Health Technology device.

3. information that we may receive from you from other third-party sources.

Consent

This policy explains our collection, use and disclosure of personal and sensitive information. Agreeing to this policy alone does not give Sengira permission to send care recipient information to a third-party AI service; we ask for that permission separately.

How personal information is collected

You may choose not to provide some of the personal information and sensitive information described above. Please note, however, that some of our Services require some personal information and sensitive information to operate, so if you choose not to provide the personal information and sensitive information necessary to operate and provide you with a particular Service or feature of that Service, you may not be able to use that Service or feature.

Information that you give us

We may collect your personal information and sensitive information directly from our contact with you. This may include by you using the Services or our devices, completing forms or parts of our application, or by you contacting us via email, telephone, through social media and other similar functions either directly through our site or through third-party host sites, in person, through various marketing channels or competitions either directly through our site or through third-party host sites, and surveys.

You understand that any personal information that you provide to us must be accurate and up to date. We will assume this to be the case.

Where you provide us with other people’s personal information, for example where you provide us with the details of a nominated contact for the purposes of providing the Services, you acknowledge that you have obtained that person’s consent to the collection of their personal information.

If you choose to add a meal photo through the mobile app, we collect that image to provide the meal logging feature.

Information that we collect about you

In this Privacy Policy “Social Media” means social media networking sites of any kind or nature including but not limited to web or internet based or mobile telephonic devices or medium such as Meta, twitter, Instagram and LinkedIn which enable the creation and exchange of user generated content.

Our website, social media and/or mobile applications may automatically collect the following information about you each time you visit our website, social media and/or mobile applications:

1. Technical information including but not limited to the Internet Protocol Address used to connect your computer to the internet, the internet browser and version that you are using when accessing our website, social media and/or mobile applications, any additional plug-ins that you are using, and your computer’s operating system and platform.

2. Information about the time and date you accessed our site and social media, and what you accessed on our site and social media. This includes links that you clicked on, what content you accessed, how long you accessed that content for, whether you downloaded any content, whether supplied by us or downloaded from a third-party host, and how you navigated to and from our website, Social Media and/or mobile applications to other sites or other pages hosted by us.

How we use your personal information

We use personal information to provide and support the Services and for the purposes described below. We may disclose information to related entities and service providers where needed for those purposes, subject to applicable law. Third-party AI processing for the Enhanced Daily Digest requires the separate permission described below.

This may include:

1. Using your personal information to provide you with information that you have requested from us.

2. Authenticating your credit or debit card account information.

3. Using your contact information for Sengira's own marketing, where permitted by law, such as news, events, offers, and updates about our services. You can opt out of these communications.

4. To notify you about any changes to our products, website and/or mobile applications, brand or services offered.

5. To seek your opinion and feedback on any of our services, including for the purposes of product improvement and customisation, website improvement and personalisation and other general services.

6. For customer support, including responding to service questions and troubleshooting reported problems.

7. For other general services such as website security, maintenance, identification of fraud or errors, internal accounting and administration, and for any other purpose that we are required or permitted to do by law; and

8. To manage our relationships with you and our other customers.

Sensitive Information Usage

We use sensitive information to provide the Services and disclose it to service providers only where needed for the purposes explained in this policy and permitted by applicable law. We require separate permission before sending it to a third-party AI service for the Enhanced Daily Digest.

This may include reviewing information needed to investigate service quality or support requests, subject to our access controls.

AI-Assisted Insights

Sengira uses AI-assisted technology to support the analysis of home activity and wellbeing data, identify meaningful patterns, and provide clear, easy-to-understand insights.

Our proprietary Sengira Fusion Engine™ remains the core intelligence system responsible for processing sensor data, establishing individual baselines, detecting changes in daily routines, and generating wellbeing assessments. AI complements the Fusion Engine by assisting with the interpretation of relevant activity summaries and translating findings into natural, human-friendly language. Today, AI-assisted insights are delivered as the Enhanced Daily Digest.

What Information Is Shared?

With separate permission from the care recipient, Sengira securely sends limited information without direct personal identifiers to Amazon Web Services (AWS), through Amazon Bedrock, using Anthropic’s Claude AI model. AWS receives and processes the request on Sengira’s behalf. According to AWS, model providers such as Anthropic cannot access customer prompts or responses processed through Amazon Bedrock.

This may include:

• Activity summaries: Relevant information about sleep and rest, bed and wake times, bathroom visits, movement around the home, and front-door openings.

• Supporting context: Comparisons with the person’s usual patterns, needed to explain the insights accurately.

• Safety summaries: Counts of safety check-ins and escalations to the care team.

• Basic context: The care recipient’s approximate age, if available, and the digest date.

Only information reasonably necessary for the intended AI-assisted insight is shared. Although direct identifiers are removed, this information may still be personal or sensitive.

What We Don't Share

We do not intentionally send your name, email address, phone number, home address, account credentials, or other direct personal identifiers to the AI service. Before a request leaves Sengira, the care recipient’s first name is replaced with a generic label; Sengira adds the name back to the digest in its own systems before showing it to authorized users.

How AI Is Used

AI works alongside the Sengira Fusion Engine to:

• Support the interpretation of wellbeing trends and unusual activity patterns.

• Help explain the factors contributing to wellbeing insights.

• Translate technical findings into clear, meaningful daily summaries and easy-to-understand explanations for users and caregivers.

The Sengira Fusion Engine remains the primary system for sensor processing, baseline management, wellbeing scoring, and safety event detection. AI provides supplementary language interpretation capabilities and does not independently calculate wellbeing scores, detect emergencies, or make medical or care decisions.

Your Permission

We ask for an affirmative choice in the app before sending this information to AWS Bedrock. If permission is not given or is withdrawn, future digests use a standard summary without this third-party AI processing. You can change this choice in the app’s Settings or contact support@sengira.com for help. Withdrawing permission stops future Enhanced Daily Digest requests; it does not automatically erase digests already generated. You can request deletion of your information as described under Your rights.

AWS processes this information under its applicable service terms and Data Processing Addendum. We require service providers processing this information on our behalf to give it protection equivalent to the safeguards described in this policy and required by applicable law. Sengira remains responsible for choosing the information sent to AWS and for protecting information in its own systems.

Legal obligations to disclose

We may be required to disclose your personal information and sensitive information for the purposes for which it was collected and subject to our legal obligations:

Disclosure Conditions

1. As required by law.

2. To any person where necessary or desirable in connection with our provision of Services; and

3. On a confidential basis to our external service providers and advisors.

Third Party Sharing

We may disclose personal information to business partners, suppliers, subcontractors, analytics providers and other service providers where needed for the purposes described in this policy and permitted by applicable law. Sending care recipient information to AWS Bedrock for the Enhanced Daily Digest is subject to the separate permission described above.

We do not share information collected through your use of the Services with online advertisers or advertising technology companies for targeted advertising or their own marketing.

Overseas Recipients

Your information may be processed outside Canada. We use contractual and security safeguards appropriate to the information and applicable privacy law when working with service providers in other countries.

You can contact us at support@sengira.com with questions about international processing or your privacy choices.

How we store your personal information and sensitive information

Sengira Health Technology maintains commercially reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

When your credit or debit card account information is being transmitted to our Services or through our Services, it will be protected by cryptographic protocols.

To be clear, Sengira Health Technology does not itself store your credit or debit card account information, and we do not have direct control over or responsibility for your credit or debit card account information.

We use third party payment processors that are the controllers of your credit card information. Our contracts with third parties that receive your credit or debit card account information require them to keep it secure and confidential.

Data Retention

We will only keep your information for as long as reasonably necessary to fulfil the purposes for which your personal information was originally collected.

You may request deletion of your information through the app or by contacting support@sengira.com, and we will delete your information.

You may be required to re-enter your personal information if it has been deleted.

Sensor-derived information and generated digests may remain linked to a care recipient or home account so that authorized users can use the Services. We do not describe this linked information as anonymous.

International Transfers

You agree and acknowledge that your personal information and sensitive information may be stored at or transferred within Canada or a destination outside of Canada.

This will allow staff operating outside of Canada (whether employed by us or by a third-party engaged by us or otherwise authorised under this Privacy Policy to access your personal information) to process your information for the purposes of providing you with our Services.

Collections of your information using cookies and other tracking technologies

Our website and/or mobile applications use “cookies”. Cookies are small pieces of data sent from a website and stored in your web browser.

These pieces of data will allow our website and/or mobile applications to remember who you are and to obtain information from you which allows us to deliver you a better and more customised service.

As a result of our website and/or mobile applications’ use of cookies, we may collect information such as your IP address, online activity and your web browser details.

Cookies do not store your account password. Sensitive information collected through our Services is described in the sections above.

If you enabled cookies when accessing our website and/or mobile applications, we will take this as consent to our use of cookies and other technologies mentioned in our Privacy Policy.

Please note that you should also refer to our website’s Terms of Use for further information on this issue.

Your rights

You have the right to request access to the personal information we hold about you by contacting us or our Privacy Officer by emailing support@sengira.com.

If we cannot provide you with access, we will write to you and provide you with the reasons why we are unable to provide you with access.

If any personal information that we hold about you is inaccurate, incomplete or not up to date, you may write to us or our Privacy Officer and request that we correct the information at the above address.

You can opt out of Sengira's direct marketing communications by contacting us at support@sengira.com.

You can change your Enhanced Daily Digest choice in the app’s Settings. For other privacy requests, including access, correction or deletion, contact us at the address above.

You may choose to opt out of receiving any further correspondence from us by writing to us at the above address or emailing us at support@sengira.com.

Complaints

If you are concerned about a possible interference with your privacy or about the potential misuse of your personal information, please contact us at support@sengira.com.

We take all complaints very seriously. It is our policy to handle complaints in a timely, effective, fair and consistent manner.

If you are not satisfied with our response, you may contact the privacy regulator with jurisdiction over your complaint, such as the Office of the Privacy Commissioner of Canada or the Information and Privacy Commissioner of Ontario.

Canadian Anti-Spam Compliance

Sengira Health Technology Inc. is committed to complying with Canada’s Anti-Spam Legislation (CASL).

When you voluntarily provide your contact information through our website, you may receive electronic communications from Sengira related to our products, services, updates, events, educational content, and other information relevant to our business.

You may withdraw your consent and unsubscribe from marketing communications at any time by following the unsubscribe instructions included in our emails or by contacting us directly.

Sengira does not send unsolicited commercial electronic messages and respects your communication preferences. We are committed to protecting your personal information and handling it in accordance with applicable privacy laws.

For questions regarding our communications practices, please contact Sengira Health Technology Inc. at info@sengira.com.

Privacy Policy updates

This Privacy Policy was last updated in October 2026.

We reserve the right to make changes to this Privacy Policy at any time.

We encourage you to regularly review this Privacy Policy to make sure you are aware of any changes and how your information may be used.

For privacy inquiries, please contact us at support@sengira.com