Privacy Policy.

KeeperPal, LLC ("KeeperPal", "we", or "us") respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect or that you may provide when you register with, access, or use the KeeperPal mobile app (the "App"); and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies only to information we collect in this App and other electronic communications sent through this App.

KeeperPal is a consumer health and wellness tracking app. It is not a medical device, it does not provide medical diagnosis or treatment, and it is not a substitute for professional medical advice. This policy does not apply to information that we collect offline or on any other KeeperPal apps or websites, including websites you may access through this App; or that you provide to or that is collected by any third party. These other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this privacy policy. This policy may change from time to time. Your continued use of this App after we revise this policy means you accept those changes, so please check the policy periodically for updates.

Information We Collect

We collect information from and about you directly from you when you provide it to us, and automatically when you use the App. When you download, register with, or use this App, we may ask you provide information by which you may be personally identified, such as name, postal address, email address, telephone number ("personal information").

When you download, access, and use the App, it may use technology to automatically collect usage details including traffic data, logs, and the features that you access and use on or through the App; and device information including a unique device identifier, IP address, operating system, and mobile network information. With your permission, the App also accesses your device camera and photo library so you can attach images to your logs, your microphone so you can log entries by voice, and your location while a workout is in progress. We do not access your contacts or address book, and we do not collect your telephone number.

Service Providers and Third Parties

We use a small number of outside services to run the App, and we describe each one by the job it does rather than by brand name. Suppliers change over time, and a policy naming a company we no longer work with would mislead you rather than inform you. Whichever supplier is in place, the commitments in this policy apply to it, because we require them in writing before any of your information reaches it. Vetting these companies is our job, not yours.

Providers that act only on our instructions

These providers process information solely to deliver a feature you have asked for. They are bound by contract to use it only for that purpose, and they may not mine, profile, resell, or repurpose it for their own ends:

• Our artificial intelligence provider, which powers the in-app AI assistant, AI report analysis, meal photo recognition, and medication label recognition. This is the only service that receives health information in order to process it, and it is contractually barred from using anything it receives to train models.
• Our push notification provider, which delivers reminders and alerts to your device. Because notification text is one of the few places where health information leaves our servers, we describe this separately under "Push notifications" below.
• Nutrition reference providers, which return nutrition facts for a food you search for or a barcode you scan. They receive the food name or barcode only, and never your personal or health information.
• Hosting, database, and file storage providers, which run our servers and hold the files and photos you upload.
• Mapping and weather providers, which draw maps and supply local conditions for outdoor activity features. They receive approximate coordinates and nothing else.

Providers that also act for their own purposes

The following services collect information for their own purposes as well as ours, under their own privacy policies. None of them ever receives your health or fitness data.

• Our advertising and measurement partners, including social media platforms. The App reports only three account lifecycle events to them: that an install occurred, that a registration was completed, and that a subscription or trial was started, together with the advertising identifier assigned to your device. They use this for their own advertising measurement and targeting. They never receive your logs, your health data, or the contents of your account.
• Our subscription and payment providers, which record an anonymous account identifier, your device details, and your purchase history in order to manage your plan.
• Our sign-in providers, if you choose to create or access your account using an existing third-party account rather than an email address and password.
• Our place-search provider, if you search for a location, for example when planning a route.

Your mobile device manufacturer, operating system vendor, and mobile network provider may also collect information about your device independently of us. We do not control those collection practices.

Push notifications

Reminders and alerts are delivered by a specialist push notification provider, which receives your device push token, your IP address, and the text of each message we send you. That provider is contractually forbidden from selling or sharing your information or using it outside its work for us, and it holds SOC 2 Type II certification and certification under the EU-US Data Privacy Framework. Almost every reminder names only the tracker it belongs to, such as "Time for Water" or "Workout Reminder", and carries none of your recorded values.

Medication reminders are the exception, and we want to be direct about it. So that a reminder is actually useful at the moment you receive it, the notification tells you which medication is due, and a refill alert states how much of it you have left. This means two things. That text passes through our push notification provider on its way to your device. It also appears on your lock screen, where somebody standing near your phone may be able to read it.

Our push provider's retention of message history also differs from ours. Delivery and interface records are held for about 30 days, but the message history in its administrative dashboard is retained for as long as KeeperPal remains a customer of that provider. Deleting your KeeperPal account erases your data from our systems on the schedule set out below and removes your subscriber record from the push provider, but it does not retroactively erase notification text that has already been sent.

You are in control of this. If you would rather no medication name ever leave our servers, turn medication reminders off in Settings. Your medication list, doses, and schedules will all keep working; you simply will not be pushed a reminder. You can also hide notification contents on the lock screen using your device's own notification settings.

Voice dictation

If you log an entry by speaking instead of typing, the App uses the speech recognition service built into your device. Depending on your device and its settings, your operating system vendor may transmit that audio to its own servers to convert it to text, under its privacy policy rather than ours. If you would rather no voice recording leave your device, type your entries instead, or enable on-device dictation in your device settings where your platform offers it.

Health and Fitness Data

KeeperPal is a health and wellness tracking app, so we access, collect, use, store, and process health and fitness data. Health and fitness data is sensitive personal information. We process it only on the basis of your explicit consent, which you give when you grant health permissions or enter data yourself, and you may withdraw that consent at any time.

Health and fitness data you enter yourself

• Body metrics: height, weight, BMI, body measurements, and body progress photos.
• Demographic details used for health calculations: date of birth and sex.
• Allergies, dietary preferences, and workout preferences.
• Vital signs: blood pressure, heart rate, body temperature, respiratory rate, blood oxygen saturation, blood glucose, and cholesterol.
• Sleep sessions, sleep stages, and responses to sleep quality questionnaires.
• Meals and nutrition, including calories, macronutrients, and micronutrients.
• Water intake and fasting periods.
• Workouts and exercises, including sets, repetitions, distance, pace, duration, and calories burned.
• Medications, including dosage, schedule, prescription number, purpose, side effects, and known interactions.
• Health conditions, symptoms, and condition-specific measurements.
• Peptide and GLP-1 therapy logs, including dose, injection site, weight, fasting glucose, A1C, mood, and reported side effects.
• Custom trackers you create, which may include menstrual cycle, mood, and mental wellbeing entries.
• Healthcare provider, pharmacy, and insurance contact details you choose to save.
• Photographs of meals, medication labels, and body progress that you choose to upload.

Health and fitness data collected from your device

• Step counts from your device's pedometer and activity recognition sensors.
• Location data recorded during a workout, used to calculate your route, distance, and pace. Location is only collected while a workout is active.

Health Connect (Android)

With your separate and explicit permission, KeeperPal reads the following record types from Health Connect: Steps, Distance, Total Calories Burned, Exercise, Sleep, Heart Rate, Oxygen Saturation, Body Temperature, Respiratory Rate, Blood Glucose, Blood Pressure, Hydration, and Nutrition.

KeeperPal only reads from Health Connect. We do not write any data back to Health Connect. We use Health Connect data solely to display your logs, charts, trends, and reports inside the App, to calculate your goals and daily progress, and to generate the personalized insights you have asked for. We never use Health Connect data for advertising or marketing, we never sell it, and we never transfer it to data brokers, credit agencies, insurers, or employers.

You can revoke KeeperPal's access at any time in the Health Connect app on your device, or from Settings in KeeperPal. Revoking permission immediately stops any further reading of Health Connect data.

Apple Health (iOS)

On iOS, and with your permission, KeeperPal reads the same categories of data from Apple Health. This access is read-only; we do not write data back to Apple Health. You can revoke it at any time in the Health app on your device, or from Settings in KeeperPal.

Your data is never used to train AI models

We do not use your data to train, fine-tune, or improve any artificial intelligence or machine learning model, and neither does any AI service we use inside the App. This applies to everything you put into KeeperPal: your logs, your health and fitness data, your photographs, your voice entries, and your conversations with the AI assistant.

The AI features in the App are delivered by a specialist artificial intelligence provider. That provider contractually commits that it will never use customer data for model training, encrypts data in transit and at rest to the AES-256 standard, and is independently certified under SOC 2 for security, availability, and confidentiality. We call it through a direct interface in which your conversation content is not retained; only anonymized operational records of the call itself, such as timing and status, are kept for billing and reliability. We will not move to a provider that offers weaker terms than these.

We build no models of our own on your data. We do not licence, sell, rent, or otherwise make your data available to anyone building models. If we ever wished to use your data to develop a model, we would first ask for your separate, express, opt-in consent, and you would remain free to refuse without losing access to any feature you pay for.

How health and fitness data is shared

When you use the AI assistant, AI report analysis, meal photo recognition, or medication label recognition, the health data relevant to your request and any photo you submit are transmitted to our artificial intelligence provider in order to generate your answer, and are used for nothing else. This may include your age, sex, height, weight, BMI, allergies, medical conditions, and the specific logs your question relates to. We send the minimum needed to answer you, and we strip our internal record identifiers before the request leaves our servers.

Beyond that, and beyond the medication reminder text described under "Push notifications", your health and fitness data stays with us. It is never sent to our advertising, attribution, subscription, or analytics partners. It is never used to build advertising profiles or audiences. It is never sold, rented, or disclosed to data brokers, credit agencies, insurers, or employers. We do not share it with any third party for that party's own purposes, and the providers that do handle it may not read it for their own benefit.

Retention and deletion of health and fitness data

Health and fitness data is encrypted in transit and at rest. Photos and other files you upload are held in private storage and are only reachable through short-lived signed links.

You can delete any individual entry at any time from within the App, and you can delete your entire account from Settings. When you delete an entry or your account, the data is marked for deletion and then permanently erased from our systems on the following schedule: activity, sleep, nutrition, water, vital sign, medication, and health condition logs within 30 days; medications, goals, sleep profiles, recipes, and tracked conditions within 60 days; weight, height, BMI, profile data, and uploaded files within 90 days. Data obtained from Health Connect or Apple Health is deleted on the same schedule.

One thing sits outside that schedule, and we would rather say so plainly than let you assume otherwise. Notifications we have already sent you remain in our push provider's message history, as explained under "Push notifications", and are not erased by deleting your account. For medication reminders, that history includes the medication name. If this matters to you, turn medication reminders off, and write to us at the address at the end of this policy if you would like us to ask our provider to purge the message history associated with your device.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to provide you with the App and its contents, and any other information, products, or services that you request from us; fulfill any other purpose for which you provide it; and notify you when App updates are available, and of changes to any products or services we offer or provide though it. The usage information we collect helps us to improve our App and to deliver a better and more personalized experience.

We never sell your health and fitness data, and we never use it for advertising or marketing. We do not sell personal information of any kind for money. We do report the three account lifecycle events described above to our advertising and measurement partners so that we can gauge how well our advertising works, and under some state privacy laws that reporting counts as "sharing" personal information for cross-context behavioral advertising. You can stop it at any time by turning off app tracking in your device privacy settings, or by writing to us at the address at the end of this policy.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction. In addition, we may disclose personal information that we collect or you provide to our subsidiaries and affiliates; to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them; to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide the information; with your consent; and to comply with any court order, law, or legal process, including to respond to any government or regulatory request.

Health and fitness data is treated more strictly than the paragraph above. We disclose it only to the providers named under "Providers that act only on our instructions", only to deliver a feature you have asked for, and otherwise only with your consent or where a court order or law compels us. It is never included in any disclosure made for advertising, marketing, business development, or the benefit of an affiliate.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Specifically, we use technical controls and safeguards to protect the privacy, security, integrity, and availability of your personal information; we use encryption for secure communication between servers; we maintain internal policies and processes that limit access to your information to our staff who need to know the information to perform their jobs; and we maintain internal data retention and deletion policies to help us ensure we only store information about your use of our mobile apps as we describe in this policy.

The safety and security of your information also depends on you. There are steps you can take to further protect your information, including not sharing the username and password you use with the App; changing your password immediately if you believe any unauthorized access has occurred; using the security tools on devices you use with the App; and not rooting or jailbreaking devices you use with the App as doing so can create security risks by removing your devices' built-in security measures and exposing sensitive information on your device.

The transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Your Rights and Choices

You may cancel your App account (the "Account") at any time from the "Manage Account" section of the App, under "Settings", or by contacting us using the details at the end of this policy. When you cancel your Account, your data is immediately withdrawn from the App and scheduled for permanent erasure on the retention schedule described under "Health and Fitness Data" above. There is a short window before erasure completes during which you may contact us to restore your Account; once the retention period has elapsed, the data is gone and cannot be recovered.

After erasure, information that can no longer identify you may persist in aggregated or anonymized form, and may be used for our internal support, administrative, and record-keeping purposes, including improving our services through research, evaluation, and analytics as permitted by applicable law. We may also retain specific records where we are legally required to do so. Health and fitness data is never retained in identifiable form beyond the periods described above.

Data you have shared through public social features, such as posts and club activity, remains visible to other members after your Account is deleted unless you remove it first. Please keep in mind that a request to delete information may lead to cancellation of your Account or the inability to use certain services and features.

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the App. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, or to register a complaint or concern, contact us by email at support@keeperpal.com, by mail at KeeperPal, LLC, PO Box 103, Medfield MA 02052, or by phone at 617-413-8888.