Privacy Policy

Aithora, LLC ("Aithora," "we," "us," "our") provides an AI-assisted care and safety platform for senior-living communities (assisted living, memory care and nursing facilities) and for older adults living at home ("Aithora Home"). This Privacy Policy explains what information we collect, how we use it, who we share it with, how long we keep it, and the choices and rights you have.

It covers:

• our website, aithoracare.com, and the Aithora web console at app.aithoracare.com;
• the Aithora mobile app for iPhone and Android. There is one app, named "Aithora," for facility staff, family members, residents and Aithora Home members; what it shows depends on the role of the account that signs in. The app is free to download and use; facilities pay Aithora directly;
• the Aithora Companion, the voice and text assistant for residents and Aithora Home members;
• our text message (SMS/MMS) and voice alert program; and
• our communications with facility operators and other business contacts.

1. Two different roles: facility data and Aithora Home data

How we handle your information depends on how you came to use Aithora.

If you live in, work at, or have a family member in a facility that uses Aithora. The facility (or its operator) is our customer. When we handle residents' health information for a facility, we do so as that facility's HIPAA Business Associate, under a written Business Associate Agreement ("BAA"). In that role:

• The facility, not Aithora, decides why and how residents' protected health information ("PHI") is used. We use and disclose PHI only as our BAA with the facility allows, or as the law requires.
• The facility's own Notice of Privacy Practices explains residents' HIPAA rights. Requests to see, copy, correct, or get an accounting of disclosures of a resident's health record should go to the facility. If you send such a request to us, we will pass it to the facility and help it respond.
• We limit our use and disclosure of PHI to the minimum necessary for the purpose.
• Where this Policy and our BAA with a facility differ about PHI, the BAA controls.

If you use Aithora Home directly with Aithora. Aithora decides how this information is used, and this Policy and applicable state laws govern it. See also Section 12.

Business contacts (for example facility operators we talk to about our service) and website visitors are covered by Sections 2.6 and 2.7.

2. What we collect

We collect only what we need to run the service. Below is what we collect, grouped by who you are.

2.1 Everyone who signs in

• Account information: name, username or email, role (for example caregiver, nurse, facility administrator, family member, resident, Aithora Home member), the facility or household you belong to, and your password (stored only as a one-way hash).
• Sign-in security information: two-factor authentication settings (the secret is stored encrypted), passkeys, trusted-device records, session records, and failed sign-in attempts, including the IP address and time.
• Device information for alerts: if you allow notifications, a push notification token for your phone and whether it is an iPhone or Android phone. We use it only to deliver alerts to you.
• Activity records: what you did in the service and when (for example, acknowledging an alert, signing a note, approving a request, opening a resident record). We keep this audit trail for security and because health-care law requires a record of who accessed and changed health information. We do not use it for advertising or analytics.

Accounts are created by Aithora or by a facility. Family members join through an invitation from the facility, or by entering a code from the care team, which the facility then approves. No resident information is shown until one of those is done.

2.2 Facility staff (caregivers, nurses, facility administrators)

• Contact details your facility gives us, such as work email and mobile phone number, so we can send you care and safety alerts.
• Your on-call shifts and assignments.
• What you enter about residents: observations, notes, vital signs, task completions, incident reports, and dictated notes. Dictation is turned into text on your phone; Aithora receives the text, never the audio. See Section 4.3.

2.3 Residents of facilities

This is PHI that we handle for the facility under our BAA. It comes from the facility, from the resident, or is created by the service:

• Identity and profile: name, preferred name, room, date of birth, photo if provided, communication style, interests and life story the resident shares, and family and care-team contacts.
• Health information: conditions, medications and administration records, allergies, care plans, assessments (for example cognitive, pain, mobility, and fall-risk assessments), vital signs, weights, fluid intake, incidents and falls, hospital transfers, clinician notes, and immunizations.
• Information from connected systems: if the facility connects its electronic health record or pharmacy system, the data the facility authorizes us to receive.
• Device and sensor readings: if the facility or resident connects a wearable or sensor, readings such as heart rate, oxygen saturation, sleep, activity, and fall alerts.
• Companion conversations: what the resident says to the Companion by voice or text, the Companion's replies, and information drawn from them (for example reminders, mood, things the resident wants the care team to know, and a "memory" of people and events the resident mentions, so the Companion can recall them later). The Companion stores conversations only for residents whose consent to AI interaction is on record.
• Scores and alerts the service produces: wellness scores, risk scores (for example fall or deterioration risk), and the alerts and escalations they trigger.
• Billing information for the facility: where the facility uses Aithora to document care time or prepare insurance claims, the codes, dates, and payer details needed.

2.4 Family members

• Your name, email, mobile number, and relationship to the resident, provided by you or the facility.
• Messages you exchange with the care team.
• Moments: photos and voice notes you choose to share with your family member, and their captions. A photo comes from your camera or photo library only when you choose one. A voice note is recorded only while you hold the record button. Moment files are stored encrypted; if encrypted storage is not available, the Moment is saved without its file and the file is not kept.
• Important dates you add (for example birthdays or visits).
• Your notification and contact preferences.

2.5 Aithora Home members and their families

• The same kinds of information as Sections 2.3 and 2.4: profile, health information, Companion conversations, device readings, alerts, and family contacts.
• Household subscription details (plan and status). If card payments are taken, card details are collected and held by our payment processor, not by Aithora.

2.6 Website visitors

• Our website does not use advertising or analytics cookies or trackers.
• Our hosting and security provider processes standard technical information, such as your IP address and browser type, to deliver and protect the site.
• If you sign in on the website, your browser stores your session so you stay signed in.
• Our contact form opens your own email program with your message addressed to us; we receive what you send in that email (for example your name, email, organization, role, and message).

2.7 Business contacts (facility operators and prospects)

To offer our service to senior-living operators, we keep business contact information about facilities and the people who run them: names, job titles, work emails and phone numbers, and notes from our conversations. We get this from public sources (for example the Centers for Medicare and Medicaid Services and the national provider registry), from the contacts themselves, and from business-contact databases. If an Aithora team member connects their work Gmail account to our sales tools, we read and send email in that account only to manage business conversations with these contacts (see Section 6.3). You can ask us to stop contacting you or to delete your business contact information at any time.

3. How we use information

We use information to:

1. Provide the service: show the right information to the right people, run the Companion, prepare care notes, schedule reminders, and keep family members connected.
2. Keep residents safe: detect and escalate emergencies and urgent changes (for example falls, a resident asking for help, signs of distress or self-harm, or out-of-range vital signs) to staff, family, and where configured, emergency services.
3. Send notifications: in-app, push, SMS, and voice alerts to people who are set up to receive them.
4. Secure the service: authenticate users, prevent fraud and misuse, keep audit records, and investigate security events.
5. Measure and improve accuracy and safety: check whether our scores and alerts are accurate (for example, whether a risk score anticipated a hospital transfer), and adjust them. For facility data, we do this only as our agreement with the facility permits.
6. Support facilities: billing, documentation, reporting, and customer support.
7. Meet legal obligations: comply with law, respond to lawful requests, and enforce our agreements.

We do not use personal information for advertising, we do not sell it, and we do not use health information for marketing.

4. Artificial intelligence (AI)

Aithora uses AI to help care teams and residents.

4.1 What the AI does

• The Companion talks with residents and Aithora Home members, remembers what they share so conversations feel continuous, reminds them of things, and tells the care team when someone needs help.
• Safety screening: every message a resident sends to the Companion is checked automatically for signs of crisis or self-harm. A possible crisis is escalated to people, not handled by the AI alone.
• Atlas helps staff and the Aithora team: it answers questions about residents and operations, drafts care notes from dictation, and summarizes shift handoffs and doctor visits. A person reviews and signs drafted notes before they become part of the record.
• Scores: statistical models produce wellness and risk scores to help staff prioritize. They support, and never replace, the judgment of care professionals.

4.2 Who provides the AI

To do this, we send the information needed for each task to AI service providers that process it on our behalf: large-language-model providers (for the Companion, the safety screen, Atlas, and note and summary drafting) and a search-indexing provider (so the Companion can find relevant memories). A web research AI provider is used only by Aithora's internal team for market research about facilities; it is not part of any care feature.

We use only AI providers that are bound by contract to protect the information and to use it only to provide their service to us. Before any provider receives PHI, it must also have signed a business associate agreement with us.

4.3 Speech and voice

• Hold to talk: when you hold the talk button, your phone turns your speech into text on the phone itself. The audio never leaves your phone, and Aithora receives only the text. If your phone cannot recognize speech on the device, the app does not offer the talk button and you can type instead. (If you choose to use your phone keyboard's own dictation key, that is a feature of your phone, under its maker's terms.)
• Reading aloud: the Companion's replies are spoken by your phone's own voice. No audio is sent anywhere.
• Voice notes (family Moments) are recordings you choose to make and send; see Section 2.4.
• Face ID and fingerprint: if you turn on biometric unlock, your phone checks your face or fingerprint. Aithora never receives your biometric data.

4.4 Do we use your data to train AI?

• We do not use your information to train AI models. If we ever want to, we will update this Policy first, and we will use a person's information only with that person's separate, explicit consent (agreeing to use the Companion does not count) and, for facility data, only where our BAA permits it.
• We use service data to check and calibrate our statistical scores, as described in Section 3, item 5.

4.5 Limits

AI can make mistakes. Aithora does not diagnose, treat, or prevent any disease, and is not offered as a medical device. The Companion is not a doctor, nurse, or emergency service, and Aithora is not a substitute for professional care. In an emergency, call 911.

5. Who we share information with

We share information only as described here. We do not sell it.

5.1 Within the care circle

The service shows information to the people the facility or household has authorized: staff see residents in their facility according to their role; family members see the resident they are linked to, after the facility approves the link; residents and Aithora Home members see their own information. When you send a message or a Moment, the people it is addressed to receive it.

5.2 Service providers (processors)

We use service providers that process information on our behalf, under contracts that require them to protect it and use it only to provide services to us. Any provider that handles PHI must first sign a business associate agreement with us. The categories are:

• Cloud hosting, database, file storage, logging and key management (in the United States): all service data, including PHI.
• Push notification services (Google Firebase Cloud Messaging, and Apple Push Notification service for iPhones): your phone's push token and the generic notification text (see Section 5.4).
• SMS, voice and phone-verification provider: phone numbers and alert message text.
• AI service providers: the information needed for each AI task (see Section 4.2).
• Website and console hosting and security: IP address and browser information.
• Sign-in and business email (Google): sign-in identity; Aithora team business email (Section 6.3).
• Payment processor (Aithora Home subscriptions, if card payments are taken): payment details and subscription status.

If we add a provider that would receive a new kind of personal information, or connect a new kind of service (for example email alerts, wearable and sensor services, symptom-checking services, insurance claim clearinghouses, or error monitoring), we will update this Policy first.

5.3 Systems a facility connects

If a facility connects its electronic health record, pharmacy, or other systems, we exchange data with those systems at the facility's direction. Sending information back into a facility's record requires the facility's opt-in and a signed BAA.

5.4 Notifications

Push notifications do not show resident names or health details. The lock screen shows only "Aithora" and a generic line such as "New alert. Open Aithora to view." The details appear only inside the app. Push notifications pass through Google's and (for iPhones) Apple's notification services, which receive only that generic text, your push token, and internal reference numbers. Staff should still protect their phones with a passcode.

5.5 Emergencies

When an emergency is detected, we notify the people set up to respond, and, where the facility or household has turned it on, emergency services.

5.6 Legal and safety reasons

We may disclose information if the law requires it, to respond to valid legal process, to protect someone's life or safety, or to protect our rights and users. For PHI, we do this only as HIPAA and our BAA allow, and we notify the facility as our BAA requires.

5.7 Business transfers

If Aithora is involved in a merger, acquisition, or sale of assets, information may transfer to the successor, which must honor this Policy and our BAAs. SMS opt-in data will not be transferred for marketing purposes.

6. Text messages, voice alerts, and email

6.1 Text messaging (SMS/MMS)

Our care-alert texts are sent under the name "Aithora Care." Recipients opt in to receive operational care-alert messages during onboarding (web form, paper form, or verbal consent). Message frequency varies based on care events and is not on a fixed schedule. Message and data rates may apply. Reply STOP at any time to unsubscribe and HELP for assistance. Consent to receive text messages is not a condition of any purchase.

• Mobile numbers are never shared. We do not sell, rent, or share mobile phone numbers or SMS opt-in information with third parties or affiliates for their marketing or promotional purposes. Mobile information is used only to deliver the care and safety notifications you have opted in to receive. We never share mobile numbers or SMS opt-in data with third parties for marketing.
• Our text messaging provider processes your number only to deliver our messages.
• Alert texts do not include resident names or clinical details. A text may state the type and urgency of an alert (for example, "a high fall alert needs attention") and ask you to sign in to see more.
• We also send one-time verification codes by text when you confirm a phone number.
• After you reply STOP, you receive one confirmation and no further texts. Reply START to opt back in.

6.2 Voice alerts

Urgent alerts may also be delivered as automated phone calls, using the same short content as texts.

6.3 Email and Google data (Aithora team only)

If an Aithora team member connects their Gmail account to our sales tools, we access their messages only to show and manage business conversations with facility contacts, and to send email they write. Aithora's use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. We do not use Gmail data for advertising, do not sell it, and do not let people read it except with the account holder's permission, for security, or as the law requires.

7. How long we keep information

We keep information only as long as needed for the purposes in this Policy, our contracts with facilities, and the law.

• Facility data (PHI): kept for the term of our agreement with the facility. When the agreement ends, we return or destroy the facility's PHI as the BAA requires, except where the BAA allows us to keep it (for example where return or destruction is not feasible), in which case we keep protecting it.
• Audit and security records: kept for at least six years, because health-care law requires an audit trail of who accessed and changed health information. These records hold identifiers and the type of action, not the health content itself.
• Consent records: kept as proof of consent and of any withdrawal or deletion request.
• Billing and claims records: kept as long as accounting and insurance rules require.
• Aithora Home and family data: kept while the account is active, and deleted when you delete your account (Section 9.2).
• Backups: deleted information may remain in encrypted backups until those backups expire on their regular schedule.
• Business contacts: until you ask us to delete them or they are no longer useful to us.

8. Security

We use safeguards appropriate to health information, including:

• encryption of all traffic between your device and Aithora (HTTPS/TLS);
• storage in United States data centers that encrypt stored data;
• an additional layer of application encryption (AES-256) for the most sensitive items, including Companion conversations, clinical notes, two-factor secrets, and family photos and voice notes;
• on your phone, your sign-in session and any actions saved while offline are kept in the phone's secure keychain or keystore and are erased when you sign out;
• role-based access controls that keep each facility's and household's data separate, and two-factor authentication;
• an audit log that the database locks against changes, and a hash-chained ledger of actions taken in the service, so any change would be detectable; and
• keeping health information out of application logs.

No system is perfectly secure. If we learn of a breach affecting PHI, we notify the affected facility without unreasonable delay and no later than our BAA and HIPAA require (at most 60 days after discovery), so it can notify residents. If a breach affects information we control (for example Aithora Home data), we notify affected people and regulators, including the Federal Trade Commission where the Health Breach Notification Rule applies, as the law requires.

9. Your choices and rights

9.1 Choices everyone has

• Notifications: turn push notifications on or off in your phone's settings, and adjust alert preferences in the app. Turning off alerts may mean you miss an emergency.
• Text messages: reply STOP to stop and HELP for help.
• Camera, photos, and microphone: the app asks before using them, and you can turn access off in your phone's settings at any time.
• Biometric unlock: optional; turn it on or off in the app.
• Companion consent: a resident (or their legal representative) can withdraw consent to AI interaction. We then stop storing their Companion conversations.

9.2 Deleting your account

You can delete your account, or ask us to, in three ways:

• In the app: Me, then Delete my account. In the web console, open your account menu and choose Delete my account. Before you confirm, the app shows what will be deleted and what will be kept, and asks you to type DELETE.
• On the web: app.aithoracare.com/delete-account. Signed in, it works the same way as in the app. Signed out, you can send a request with the email address of your account.
• By email: write to [email protected] from the email address on your account, with the subject "Delete my account."

For requests made on the web while signed out, or by email, we first confirm that you control the account's email address, then carry out the deletion within 30 days. To protect your privacy, the web form gives the same answer whether or not an account exists for that email.

What happens depends on the kind of account:

• Family members and Aithora Home members: your account is deleted immediately when you confirm in the app or on the web while signed in. We delete your sign-in (password, two-factor, passkeys, and every session, so you are signed out everywhere), your push tokens, your settings, and your phone number and email, and your name is replaced with "Deleted account."
  • For a family member, we also delete the messages you sent the care team, the photos and voice notes you shared (including their stored files), and the dates, reminders, tasks, and requests you added, and we remove your connection to your loved one.
  • For an Aithora Home member, we also delete everything Aithora holds about you: Companion conversations and memories, check-ins, medications, health readings and wearable data, notes, and alerts. Deleting an Aithora Home account cancels its subscription.
• Facility staff: your login is deleted immediately: your sign-in, push tokens, settings, phone number and email, and your place on on-call rotas and current or future shift assignments (that work goes back to your team). Care records you wrote or signed, such as notes, vital signs, medication passes, and incident steps, belong to your facility and stay in its records under your name, as health records must. A facility's only administrator must make someone else an administrator before deleting their own account.
• Residents of a facility: a resident's health record belongs to the facility, which is the HIPAA covered entity. A deletion request from a resident (in the app, on the web, or by email) goes to the facility, and the facility decides. If it approves, the resident's sign-in, devices, conversations, and the care records Aithora holds for the facility are deleted, except records the law requires the facility to keep.
• Aithora team accounts are removed by Aithora's owner; a request from a team member goes to the owner.

What we keep, and why:

• The audit log and the Truth Ledger. These append-only records show who did what and when, and health-care law requires an access trail. We never edit or delete them. A deletion adds one entry recording that the account was deleted; it holds counts and identifiers, not your content.
• Records the facility keeps about a resident, including that it notified family about events (federal law requires it) and its visitor log. After a family member's account is deleted, these no longer show the family member's name or contact details.
• Consent records, including the record of your deletion request, as proof. The request's copy of your email and name is cleared once it is completed.
• Billing records, as accounting and insurance law requires.
• Records the law requires us to keep, such as an emergency and how it was answered (with its details cleared).
• Information in backups, until the backup expires.

9.3 State privacy rights

Depending on where you live, you may have the right to: confirm whether we process your personal data and access it; correct it; delete it; get a portable copy; and opt out of the sale of personal data, targeted advertising, and certain profiling. We do not sell personal data or use it for targeted advertising or for profiling that produces legal or similarly significant effects.

• How to ask: email [email protected]. We respond within 45 days, and may extend once by 45 days if needed, telling you why. Requests are free at least twice a year.
• Appeals: if we decline your request, you may appeal by replying to our decision with the subject "Appeal." We will respond within 60 days. If you are not satisfied, you may contact your state Attorney General (in Texas, at texasattorneygeneral.gov).
• Authorized agents: a legal representative may make a request for you, with proof of authority.
• No discrimination: we will not treat you differently for exercising your rights.
• PHI: many state privacy laws exempt PHI handled under HIPAA. For residents of a facility, the facility's Notice of Privacy Practices explains your rights.

10. Children

Aithora is not intended for anyone under 18, and we do not knowingly collect information from children. If you believe a child has given us information, contact us and we will delete it.

11. Where information is stored, and people in the EU, UK and Switzerland

We store and process information in the United States. If you are in the European Union, the United Kingdom or Switzerland, the GDPR (and the UK GDPR or Swiss data protection law) gives you the protections below.

• Who decides. For information a facility puts into Aithora, the facility is the controller and Aithora processes it on the facility's behalf under a Data Processing Agreement; please contact the facility first. For Aithora Home accounts and business contacts, Aithora, LLC is the controller.
• Why we may use it (legal basis). To provide the service you asked for; with your consent, which you can withdraw at any time; for our legitimate interest in keeping the service secure and working, weighed against your rights; and to meet legal obligations. We use health information only with your explicit consent or, in a facility, under the facility's basis for providing health or social care.
• Your rights. You can ask to access, correct or delete your information, restrict or object to how we use it, receive it in a portable format, and withdraw consent. Aithora's AI does not make decisions with legal or similarly significant effects about you on its own; a person decides.
• Transfers. When information moves from your country to the United States, we protect it with the European Commission's Standard Contractual Clauses (and the UK and Swiss equivalents).
• Breaches. Where the law requires, we notify the data protection authority within 72 hours of learning of a breach, and you without undue delay if your rights are at high risk.
• Complaints. You can complain to the data protection authority where you live or work. We would like the chance to help first: write to [email protected].

12. Consumer health data (Aithora Home)

If you use Aithora Home outside of a facility's HIPAA-covered care, the health information we hold about you is consumer health data. We collect it only as needed to provide the service you asked for or with your consent, we share it only with our service providers to provide that service or with your consent, and we never sell it. You can withdraw consent and delete your data at any time by deleting your account (Section 9.2), and you can use the rights in Section 9.3.

13. Changes to this Policy

We may update this Policy. We will post the new version here with a new "Last updated" date, and for material changes we will notify you in the app or by email before the change takes effect. We will not use previously collected information in a materially different way without your consent where the law requires it.

14. Contact us

Aithora, LLC
721 N Ware Rd
McAllen, TX 78501
[email protected]

For a resident's HIPAA rights, please also contact the facility.