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SILVIE PRIVACY POLICY 

A Pontosense Inc. Brand

Pontosense Inc. and its affiliates ("Pontosense", "we", "us", or "our") are committed to protecting the privacy of our customers and users ("you" or "your"). Silvie is a consumer-facing brand and product line developed by Pontosense, designed to help individuals and families in their everyday lives. This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information when you interact with our website (the “Website”) or use Silvie products and services as defined below.

This Privacy Policy is available at: http://www.silvie.com/privacy-policy

1. PURPOSE AND SCOPE.

This Privacy Policy applies to all Silvie solutions and services (collectively, the "Products"), including:

Because Silvie is a consumer-facing brand, this policy is written with you, the individual user, in mind. You may use Silvie Products directly as an individual, or a family member or caregiver may set up and manage the Product on your behalf. In either case, this policy describes how your personal information is handled.

Silvie Products may integrate with third-party services or platforms. Those services have their own privacy policies, and we encourage you to review them. Pontosense is not responsible for the privacy practices of third parties.

If you access our Products or Services from outside Canada, you acknowledge and agree that your personal data may be transferred to, processed in, and stored in Canada, the United Kingdom, the European Union or other jurisdictions where Pontosense or its service providers operate as applicable. Local data protection laws in these jurisdictions may differ from those in your country of residence.

2. INFORMATION WE COLLECT.

We may collect the following categories of personal information ("Personal Information") depending on your interactions with us:

  1. When you use our Website:
    • Device identifiers (via cookies, pixels, analytics tools, log files, etc.)
    • Usage data (browser type, access time, pages viewed, access location, IP address)
    • Website interaction data captured by third-party analytics and session-replay tools (such as Mixpanel), including page navigation, clicks, scrolling, and mouse movement, used in aggregate to understand and improve the Website. Sensitive form fields are masked and we do not use this data to identify you personally.
    • Form data, as listed below in Section 2(b)
  2. When you contact us:
    • Full name
    • Email Address
    • Phone number
    • Country
    • Any additional information you voluntarily provide
  3. When you use Silvie Products:
    • Hardware Status and Performance Data
      • Firmware version
      • Product activation date and time
      • Power status
      • Connectivity status (e.g., RSSI)
      • Angle of installation
      • Diagnostic or error codes
    • Network and Hardware Identifiers
      • Wi-Fi network credentials, such as network name (SSID)
      • Hardware serial number
    • User Account and Authentication Information
      • Username, email address, password, and session tokens
      • Optional personal data provided for enhanced services, such as names, phone numbers, addresses, and relationship details
    • Location and Configuration Data
      • Home and room identifiers, as configured by you (e.g., room names, floor levels)
      • Room zones and positions in the room, as configured by you (e.g., bed zones, sofa zones, toilet and shower areas, etc.)
      • Installation settings, including installation height and room calibration parameters
      • (Optional) Customer labels or tags you apply to devices and/or locations
    • Sensor and Event Data
      • Occupancy status, including timestamps (e.g., whether a room or home is currently occupied or vacant)
      • User registration status
      • Zone occupancy – (bed, couch, shower, toilet, doors), including time stamps
      • Zone exit and or entry alerts – bed, couch, toilet, door entry or exit notifications, including timestamps
      • Sensor-generated event data, including timestamps for motion, location, and fall detection
      • Breathing rate trends
      • (Optional) Phone Number, emergency contact number
      • Review status of event data, indicating whether an event has been acknowledged and reviewed
    • User-Provided Input
      • Any additional information you voluntarily submit through the App (e.g., in-app notes, feedback)
    • Customer Content
      • Information submitted to or processed within the App at the direction of a customer (including resident/patient-related information).

3. DATA SECURITY.

We use physical, organizational, and technological safeguards to protect your Personal Information against unauthorized access, use, or disclosure. However, no system is completely secure. You are responsible for maintaining the security of your own login, devices, and networks when interacting with our Products.

If we become aware of a security incident affecting your data (including PHI where applicable), we will notify you in accordance with applicable laws.

4. HOW WE USE YOUR INFORMATION.

  1. Website interactions:
    • Analyze usage patterns and performance
    • Conduct market research
    • Improve website functionality and user experience
  2. Customer inquiries:
    • Respond to your questions and requests
    • Provide customized product or service information
    • Customize and improve your experience
  3. Product use:
    • Provide and secure the Products and Services
    • Troubleshoot, support, and respond to inquiries or incidents
    • Maintain service reliability, performance, and safety
    • De-identified/aggregated improvement: we may use de-identified and/or aggregated data to improve our Products

5. DATA RETENTION.

We retain your Personal Information only as long as necessary to provide you with our Products and Services, or as required by law. Retention periods depend on:

When your account is closed or you request deletion of your data, we will delete or anonymize your Personal Information in accordance with our retention schedule and applicable laws.

6. DISCLOSURE OF PERSONAL INFORMATION.

7. YOUR RIGHTS.

Please note that certain rights may be limited by applicable laws or may require identity verification.

8. CHILDREN’S PRIVACY.

Silvie Products are not intended for children under the age of 13 (or the applicable age in your jurisdiction). We do not knowingly collect Personal Information from children. If you believe we have inadvertently collected information about a child, please contact us immediately at silvie@pontosense.com and we will take steps to delete the information.

Silvie Products designed to support the safety of older adults may involve family members or caregivers in account setup. In such cases, all users and account holders are expected to be adults.

9. CHANGES TO THIS PRIVACY POLICY.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or applicable law. When we make material changes, we will notify you by:

Your continued use of Silvie Products after any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this page periodically.

10. CONTACT US.

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