Privacy Policy

    Last Updated: October 29, 2025

    We protect your healthcare data with privacy-first design. Your health data stays on your device, not in the cloud. We're PDPA, HIPAA, and GDPR compliant, and you have complete control over your data.

    What We Collect

    We only collect data necessary to help coordinate your care.

    Health Information: Assessment responses, medical history, medications, vital signs

    Personal Details: Name, email, phone, relationship to care recipient

    Technical Data: Device type, app usage (anonymized), error logs

    We NEVER collect: Precise GPS location, your contacts or messages, audio/video without consent, or data we don't need for care coordination.

    How We Use Your Data

    Your data helps coordinate care between you, family, and healthcare providers.

    Primary Uses (Required for Service):

    • Care Coordination: Connect caregivers with healthcare teams
    • AI Assessments: Generate clinical insights from your responses
    • Medication Reminders: Track and remind about medications
    • Health Monitoring: Visualize trends in health metrics

    Service Improvement (Optional): With your explicit consent only:

    • Improve AI model accuracy
    • Develop new features
    • Anonymized research (you can opt-out anytime)

    What We NEVER Do: Sell your data, use it for advertising, share with insurers without consent, or train AI models without your opt-in.

    How We Protect Your Data

    Healthcare-grade security that meets international standards.

    Encryption: AES-256 at rest, TLS 1.3 in transit

    Local Storage: Data stays on your device

    Access Control: Only authorized users can access

    Monitoring: 24/7 security monitoring

    If There's a Breach: We'll notify you within 72 hours and guide you on protective measures.

    Who We Share Data With

    We only share when you authorize it or when legally required.

    With Your Consent:

    • Healthcare Providers: Doctors, hospitals, clinics you authorize
    • Care Team: Family caregivers you designate
    • EMR Systems: Epic, Cerner, Singapore NEHR (when you approve)

    Service Providers (Secure): These companies process data on our behalf with signed agreements:

    • AWS (Singapore) - Cloud hosting
    • SendGrid - Email delivery
    • Zendesk - Customer support
    • Stripe - Payment processing

    All have HIPAA Business Associate Agreements and GDPR Data Processing Agreements.

    Without Consent (Legal Only): We may share without consent only when:

    • Medical emergency threatens life
    • Required by court order
    • Mandated by regulatory authorities
    • Serious public safety threat

    Your Rights

    You have complete control over your data.

    Access: Get a copy of all your data

    Correct: Fix inaccurate information

    Delete: Remove your account and data

    Export: Download in portable format

    Opt-Out: Withdraw consent anytime

    Restrict: Limit how we use your data

    How Long We Keep Data

    We only keep data as long as needed or required by law.

    Active Accounts: Health data retained while account is active for care coordination and longitudinal tracking.

    After Deletion:

    • Personal data: Deleted within 30 days
    • Healthcare records: May be retained by providers per law (7+ years)
    • Backups: Fully cleared within 90 days
    • De-identified data: May be kept for research (cannot be re-identified)

    Inactive Accounts:

    • After 24 months: Email reminder
    • After 36 months: Deletion notice (90 days advance)

    International Transfers & B2B

    Data primarily stays in Singapore with appropriate safeguards for transfers.

    Where Data Is Stored:

    • Primary: AWS Singapore region
    • Backup: AWS Sydney (encrypted)
    • Disaster Recovery: AWS US (encrypted, restricted access)

    All transfers use Standard Contractual Clauses (SCCs) and meet GDPR requirements.

    Who Controls Your Data:

    If you're a patient through a healthcare organization using Elderwise:

    • Your healthcare provider is the Data Controller
    • AJENTIK AI PTE. LTD. is the Data Processor
    • Contact your provider first for privacy requests

    If you're an individual user:

    Legal Compliance

    We comply with Singapore PDPA (primary), HIPAA, and GDPR standards.

    Singapore PDPA: As a Singapore company, we follow the Personal Data Protection Act:

    • Consent for data collection and use
    • Purpose limitation
    • Data accuracy and protection
    • Retention and disposal obligations
    • Breach notification (within 72 hours)

    Filing Complaints: You can file complaints with Singapore's Personal Data Protection Commission (PDPC) at www.pdpc.gov.sg

    HIPAA (US Healthcare Data): For US healthcare organizations, we maintain HIPAA-aligned practices:

    • Business Associate Agreements with all partners
    • Technical, administrative, and physical safeguards
    • Patient rights to access and amendment
    • Breach notification procedures

    GDPR (EU Users): For users in the European Economic Area:

    • Lawful basis for processing (consent, contract, legitimate interest)
    • Data subject rights (access, erasure, portability, etc.)
    • Standard Contractual Clauses for transfers
    • Right to lodge complaint with supervisory authority

    Cookies and Tracking

    Privacy-First Approach: Elderwise uses only essential cookies. We do not use any tracking, analytics, or advertising cookies.

    What We Use:

    • Authentication Cookie (sb-auth-token): Keeps you securely logged in to your account. This cookie is essential for the service to work and expires after 7 days.
    • Language Preference Cookie (i18next): Remembers your language preference (English, Chinese, Malay) so the site displays in your chosen language. Expires after 30 days.

    What We Don't Use:

    • No analytics or tracking cookies (Google Analytics, etc.)
    • No advertising or marketing cookies
    • No social media tracking pixels
    • No third-party cookies
    • No behavioral tracking

    Legal Basis: Essential cookies are necessary for contract performance under GDPR Article 6(1)(b) and do not require consent under PDPA, HIPAA, and GDPR regulations.

    For detailed information, see our Cookie Policy.

    Questions? Contact Us

    If you have any questions about this privacy policy, please contact us.

    Email: privacy@elderwise.ai