XO Care Privacy Policy

This policy covers the XO Care app and the XO Ring. What this website itself collects when you visit is covered by the separate website privacy policy. If you access XO through a care facility, additional terms provided by that facility may also apply.

XO Care is offered by XO Technology Inc. ("XO", "we", "us"), 1345 Norma Eddy Ln, 3rd Floor, Halifax, NS B3J 0H6, Canada. This policy explains what personal information the XO Care app and the XO Ring collect, how we use and protect it, who we share it with, and the choices and rights you have. We build XO Care as a wellness product, and we treat your health-related information as sensitive. If you do not agree with this policy, please do not use XO Care.

1. Information we collect

Information you provide

• Account information: name, email address, password, and (optionally) preferred name, date of birth, and profile details.
• Preferences and content: your activity interests, goals, personal notes, communication preferences, and self-assessment responses (activities of daily living and cognitive check-ins).
• Sharing choices: the people you invite or connect with, and what you choose to share with them.

Information from the XO Ring and connected devices

• Wellness metrics: heart rate, blood-oxygen (SpO₂), skin temperature, heart-rate variability, and — where supported — blood-pressure and blood-glucose trends.
• Activity data: steps, active time, movement and rest patterns, and derived stress indicators.
• Device information: ring identifier (hardware address / serial number), firmware version, battery level, and sync times.

Information generated by the service

• Wellness insights and narratives produced from your data, your activity plans and goals, and wellness alerts when a metric drifts from your personal baseline.
• Usage and technical information: app version, device/OS type, log and diagnostic data, and similar information needed to operate and secure the service. We do not include your health details in operational logs.

We do not knowingly collect information from children (see Section 10).

2. How we use your information

We use your information to:

• provide XO Care — display your wellness data, generate insights, plans, goals, and wellness alerts, and power features you choose to use;
• enable the sharing and family features you set up, limited to what you approve;
• keep the service secure, prevent misuse, troubleshoot, and provide support;
• improve XO Care's features and reliability; and
• comply with legal obligations.

Where you have given your express consent — for example, as part of a beta program agreement — we may also use your information in de-identified form, with anything that could reasonably identify you removed, to develop, test, and improve the features and models behind XO products.

Wellness, not medical care. XO Care provides general wellness information for your own awareness. It is not a medical device and is not intended to diagnose, treat, cure, or prevent any disease. It does not replace professional medical advice.

Consent. We collect and use your personal information with your consent, which you give by creating an account and using the features you choose. You can withdraw consent as described in Section 8; withdrawing consent may mean some features no longer work.

3. When we share information

We do not sell your personal information, and we do not share your health data for advertising. We share information only in these situations:

• People you choose. When you share your wellness with a family member or loved one, they see only the specific information you grant, enforced by our sharing controls. You can change or revoke this at any time.
• AI assistants you connect — see Section 4.
• Service providers. Vendors that host and operate XO on our behalf (for example, our cloud infrastructure provider) under agreements that require them to protect your information and use it only to provide services to us.
• Care facilities. If you link your account to a care facility, information is shared with that facility consistent with your linking choices and the facility's own agreements.
• Legal and safety. Where required by law, to enforce our terms, or to protect the rights, safety, and security of users, the public, or XO.
• Business transfers. In connection with a merger, acquisition, or sale of assets, subject to this policy.

4. Connecting an AI assistant

XO Care offers an optional connection that lets you link your XO Care account to an AI assistant you choose — for example ChatGPT (OpenAI) or Claude (Anthropic) — so you can ask questions about your own wellness data in plain language.

• It is off by default. Nothing is shared unless you connect an assistant yourself and ask it a question.
• What is shared, and when. When you ask the connected assistant a question that needs your data, only the specific information required to answer — for example your daily vitals, activity plan, goals, wellness insights, or alerts — is sent to that assistant's provider to generate a response. Data is sent only in response to your request; XO does not push your data to the assistant in the background.
• The provider processes it under its own terms. OpenAI, Anthropic, or whichever assistant you connect is a separate company and an independent processor; once your data reaches them, it is subject to their privacy terms. These providers are generally based in the United States, so using the connection involves a transfer of your information outside Canada (see Section 5).
• Only what you could already do yourself. The connection is a plain-language way to use the permissions your XO Care account already has — it can do the things you could already do in the app, and only when you ask. Depending on the features you have turned on, that can include viewing your wellness data to answer questions; acting on your own plan and goals (add or update an activity or goal, mark one completed, skipped, or moved, accept or decline a suggestion — the same actions as the buttons in the app); and helping manage the plan of someone you have been authorized to support as their operator (for example under a power of attorney, as a substitute decision-maker, or with that person's consent), with every such action recorded as done by you. It cannot delete your data, cannot do anything your account isn't already permitted to do, and only ever touches data you're entitled to — your own, the data of a person you're authorized to support, or (for a view-only family connection) the specific data that person chose to share with you, which stays strictly view-only.
• Your credentials stay private. You sign in with your own XO Care credentials entered directly with our identity provider; the AI assistant never sees them.
• You're in control. You can disconnect the assistant at any time from that assistant's settings, which stops further access.

5. Data location and cross-border transfers

We store and process XO Care data in Canada (Canadian cloud regions). Some of our service providers may process limited information elsewhere under agreements that require appropriate protection.

Separately, if you connect an AI assistant (Section 4), the provider you choose receives the data needed to answer your question and typically processes it in the United States. By connecting an assistant, you consent to that transfer. Connect only an assistant you trust with your wellness information.

6. How we protect your information

We use technical and organizational safeguards designed to protect your information, including encryption in transit and at rest, access controls, and monitoring. Sensitive on-device processing (for example, voice transcription) is performed on your device where feasible. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7. How long we keep your information

We keep your information for as long as your account is active and as needed to provide the service, and afterward only as long as required to meet legal, regulatory, and legitimate business needs — certain audit and consent records are retained for up to seven years. You can ask us to delete your information as described below.

8. Your choices and rights

Subject to applicable law, you can:

• access and get a copy of your personal information;
• correct information that is inaccurate;
• export your data;
• delete your account and associated data (in-app, or by contacting us);
• withdraw consent or change what you share, including revoking family access; and
• disconnect any AI assistant you have connected.

To exercise these rights, use the controls in the app or contact us (Section 11). You also have the right to complain to a privacy regulator, including the Office of the Privacy Commissioner of Canada and, where applicable, your provincial privacy regulator.

9. Third-party services

XO Care relies on third-party services (for example, cloud hosting and, if you choose, the AI assistant you connect). Their handling of your information is governed by their own privacy policies. We are not responsible for the practices of third parties you choose to connect.

10. Children's privacy

XO Care is not directed to children and is intended for adults. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact us and we will take appropriate steps.

11. How to contact us

For privacy questions or to exercise your rights, contact support@xotechnology.ai, or write to XO Technology Inc., 1345 Norma Eddy Ln, 3rd Floor, Halifax, NS B3J 0H6, Canada.

12. Changes to this policy

We may update this policy from time to time. We will post the updated version here and change the "Last updated" date; material changes will be communicated as required by law.