Privacy Policy

Introduction

BoundaryCare LLC (“BoundaryCare”, “we”, “us” or “our) is headquartered in Saint Paul, Minnesota and conducts business in the United States. We are committed to protecting and respecting the privacy of our customers, visitors, suppliers, business partners, employees, end users, and other individuals (“you,” “your,” or “data subject”). We are committed to protecting and respecting your privacy.

This Privacy Policy (“Policy”) describes how BoundaryCare collects, uses, discloses, and protects information obtained through the website on which it is posted (“Site”) and any applications, events, newsletters, communications, or services provided by or on behalf of BoundaryCare that link or reference this Policy (collectively, the “Services”).

This Policy does not apply to third-party platforms or other BoundaryCare-operated websites where it is not linked or referenced.

This Policy may be supplemented by additional privacy notices (“Privacy Notices”) provided at the time we collect your information. In some cases, specific Privacy Notices may be required to comply with applicable privacy laws.

If you have a disability and need to access this Policy in an alternative format, please contact us at info@boundarycare.com.

APPENDIX A: California Residents

APPENDIX B: Additional States

Your Acknowledgment of This Policy

Please read this Policy carefully. By accessing or using the Site or Services, you acknowledge that you have read, understood, and agreed to the practices described in this Policy and any applicable Privacy Notices. If you do not agree with these practices, please do not use the Site or Services.

Where we rely on your consent as the legal basis for processing your information, you may withdraw your consent at any time by contacting us at the address provided below. Withdrawal of consent does not affect the lawfulness of processing conducted prior to the withdrawal.

Relationship to End User License Agreement

This Policy is incorporated into and forms part of the End User License Agreement (“EULA”) governing your use of the Site and Services. A link to the EULA is provided at the bottom of each page of the Site. Any capitalized terms used but not defined in this Policy have the meanings given to them in the EULA. In the event of a conflict between this Policy and the EULA regarding the treatment of your personal information, this Policy shall control.

Changes to This Policy

We may update or modify this Policy from time to time. When we make material changes, we will notify you by posting the revised Policy on the prominent new “Effective Date” and, where required by law, provide you with additional notice (such as by email or through a prominent notice on the Site). Changes are effective upon posting unless otherwise stated. We encourage you to review this Policy periodically.

What Is Personal Information?

“Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an identified or identifiable natural person. This includes information such as a name, identification number, location data, online identifier, or other factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of a person.

How We Collect Your Personal Information

We may collect Personal Information through the following means:

Directly from you when you provide it to us through the Site, our Services, or other interactions.
From third parties, including your health care provider, caregiver, or guardian in connection with the provision of our products and services.
From publicly available sources and commercially available databases.
Automatically when you interact with our Site or Services through cookies, log files, and similar technologies.

If you choose not to provide certain Personal Information, it may affect our ability to provide products and services to you.

Information We Collect

General Information

We may collect the following categories of Personal Information:

Identifiers: name, email address, mailing address, phone number, account credentials, IP address, and device identifiers.
Professional or employment-related information: company name, industry, role, qualifications, and professional affiliations.
Internet or other electronic network activity: browser type and version, operating system, access times, pages viewed, links clicked, referring URLs, and cookie data.
Commercial information: details of products and services inquired about or supplied, including transaction and order history.
Financial information: credit card, debit card, or bank account information for purchases, deposits, or refunds.
Information you voluntarily provide: responses to Surveys, interviews, case studies, and information submitted via contact forms.

End Users

If you are an end user of our Services, including a caregiver (“Caregiver”) or an individual monitored by our Services (“Care Recipient”), we collect information provided during account creation and information generated during your use of the Services. We may also receive information from third parties, such as your health care provider. Please keep your Personal Information accurate and current.

Caregiver Information: first and last name, email address, phone number, and mailing address.
Care Recipient Information: depending on your situation and the features enabled, we may collect:
Care Recipient identification number, gender, date of birth, and weight.
Medical history, conditions, and treatment information.
Geographic location data, including safe zone exit and entry information.
Device information, including battery and connection status.
Biometric and health data: heart rate, oxygen saturation, falls and gait analysis, sleep analysis, physical activity metrics, and VO2 max.
Responses to reminders and micro-surveys.
Other data associated with services that may be added or modified over time.

Important Note Regarding Protected Health Information.

Some information we collect regarding end users may constitute Protected Health Information (“PHI”) under the Health Insurance Portability and Accountability Act as amended (“HIPAA”). BoundaryCare processes such PHI as a business associate on behalf of your health care provider, and that processing is governed by a “Business Associate Agreement” and your health care provider’s Notice of Privacy Practices. In the event of any conflict between this Policy and HIPAA requirements regarding the handling of PHI, HIPAA requirements shall control. For more information, consult your health care provider.

To the extent BoundaryCare acts as a HIPAA business associate, we use and disclose PHI only as permitted or required by the applicable Business Associate Agreement, HIPAA, and other applicable law. We do not use PHI for our own independent purposes except as permitted by HIPAA and the applicable Business Associate Agreement, including, where permitted, for proper management and administration, data aggregation services, or to carry out our legal responsibilities.

Where permitted by HIPAA and applicable law, we may de-identify PHI so that it no longer identifies, and cannot reasonably be used to identify, an individual. We may use and disclose de-identified information for lawful purposes, including analytics, research, product development, service improvement, and business purposes.

When we de-identify PHI under HIPAA, we do so in accordance with HIPAA’s de-identification requirements, such as the Expert Determination method or Safe Harbor method, as applicable. De-identified information is not PHI under HIPAA, but we will not attempt to re-identify de-identified information except as permitted by law and applicable contractual obligations.

We do not use PHI for marketing, targeted advertising, or unrelated product development unless permitted by HIPAA, the applicable BAA, and/or valid authorization.

Important Note Regarding Consumer Health Data

Some health-related information we collect may be considered “consumer health data” under applicable state laws when it is not Protected Health Information governed by HIPAA. Consumer health data may include information about your health conditions, treatment, medications or reminders, biometric or physiological metrics, sleep, activity, falls or gait, precise location related to health or safety features, device-generated health information, Caregiver/Care Recipient relationships, and inferences derived from such information.

We collect consumer health data from you, your caregiver, your health care provider, your devices, our Services, and service providers or integrations you choose to connect. We use consumer health data to provide and improve the Services, enable caregiver or provider access, generate alerts and reminders, provide support, maintain security, comply with legal obligations, and for other purposes disclosed at the time of collection. We do not sell consumer health data, and we do not use consumer health data for targeted advertising unless permitted by applicable law and supported by any required consent or authorization.

We may share consumer health data with service providers, caregivers or health care providers you authorize, emergency contacts, cloud hosting providers, support vendors, analytics or security vendors, professional advisers, regulators, and other parties as

required by law or with your consent. Where required, we will identify the categories of consumer health data shared, the categories of recipients, and the specific affiliates with whom consumer health data is shared.

Consumer health data rights may be limited where:

The data is PHI governed by HIPAA and must be handled through the covered entity/provider’s HIPAA process.
We must retain data for legal, regulatory, safety, security, fraud-prevention, or contractual reasons.
Deletion would impair another person’s privacy or safety.
The request cannot be verified.
The data has been de-identified in accordance with applicable law.

Subject to applicable law, you may have the right to confirm whether we collect, share, or sell your consumer health data; access your consumer health data; obtain a list of third parties or affiliates with whom we have shared your consumer health data; delete your consumer health data; withdraw consent; appeal a denied request; and exercise these rights without discrimination. To exercise these rights, see the Contact Us section below. We may verify your identity and authority before fulfilling a request.

Suppliers, Customers, and Other External Stakeholders

If you are a supplier, customer, distributor, or health care professional, we may collect additional information including professional details, practice specialty, areas of interest, professional association memberships, product usage data, account credentials, and details of your interactions with us.

Employees, Contractors, and Applicants

If you are an employee, contractor, or applicant, we may collect additional information including gender, date of birth, contact details, tax identification numbers, employment records, resumes, reference check results, training records, immigration status, performance appraisals, disciplinary records, employment terms, and medical information. We may receive some of this information from third parties such as recruiters.

Information You Provide Directly Through the Site

We collect information you manually provide when using the Site, which may include:

Contact data: name, title, address, phone number, and email address.
Other identifiers: device ID, serial number, personal health information, and online identifiers.
Form submissions: information you submit through contact forms or similar features.
Demographic data: language, age, and gender.
Marketing preferences: email subscription and communication frequency preferences.

Information Collected Automatically

When you visit the Site, we automatically collect certain information from your browser or device, including:

Product use and application data, including date and time of your visit.
IP address and geolocation information.
Browser name and version, operating system, and device type.
Referring and exit URLs, pages viewed, links clicked, and time spent on pages.
Site usage data such as login information and technical diagnostics.

This automatically collected information may not be personally identifiable on its own but may become so when combined with other data we hold about you.

Information Collected by Cookies and Similar Technologies

We use cookies, pixels, web beacons, and similar technologies to collect information and support Site functionality. Specifically, we use these technologies to:

Analyze how visitors use the Site, including which pages are visited and how long visitors spend on them.
Support Site functionality, such as remembering your preferences and settings.
Personalize your experience on the Site.
Improve our marketing efforts, including through targeted advertising.

You may manage your cookie preferences through the cookie settings presented when you visit our Site or by adjusting your browser settings. Rejecting cookies may limit your ability to use certain Site features.

Third-Party Cookies and Tracking Technologies

Certain third parties may also place cookies on your device when you use our Site. These third parties may include analytics providers (such as Google Analytics) and advertising networks. Third-party cookies may be used to:

Help us understand how visitors engage with our Site.

Track browsing activities across websites for targeted advertising purposes.

You may opt out of Google Analytics by downloading the Google Analytics Opt-out Browser Add-on. You may also opt out of interest-based advertising through the Network Advertising Initiative or the Digital Advertising Alliance. Please note that opt-out mechanisms are device- and browser-specific.

Do Not Track

Some browsers offer a “Do Not Track” signal. There is not currently a uniform industry standard for responding to Do Not Track signals. Accordingly, we do not currently respond to Do Not Track signals. However, where required by applicable law, we will recognize legally required opt-out preference signals, including Global Privacy Control.

How We Use Your Information

Information Collected Through the Site

We may use the information collected through the Site for the following purposes:

Providing, maintaining, and improving the Site and your access to it.
Responding to your inquiries and requests.
Personalizing your experience on the Site.
Creating and maintaining records, including records of your Personal Information and consumer health data.
Communicating with you about products, clinical trials, safety information, and related offerings.
Conducting research, analytics, and product development.

De-identifying information for use as non-Personal Information.
Enforcing this Policy, our EULA, and other applicable terms.
Protecting the health, safety, or welfare of individuals.
Protecting our rights, property, or legitimate business interests.
Complying with applicable laws, regulations, court orders, and legal processes, including detecting and preventing security incidents and potentially prohibited activities.

Information Collected Through Our Services

Where permitted by law and our contractual obligations, we may use your Personal Information to:

Provide product support to you and your health care professionals.
Respond to and fulfill requests from you, your health care professional, or suppliers.
Administer, improve, and promote our products and services.
Analyze product performance and improve services of our third-party suppliers and distributors.
Monitor product safety; record, analyze, and respond to medical queries, complaints, and safety reports; and report to regulatory bodies as required.
Notify you of product safety matters as required by law or as we determine to be necessary.
Conduct market research and enable marketing activities by us or our distributors.
Administer Care Recipient support and health awareness programs.
Organize and administer conferences, seminars, and other events.
Maintain investor information and comply with legal reporting requirements.
Comply with applicable laws, regulations, product approvals, licensing requirements, and ethical obligations.

Legal Bases for Processing

We process your Personal Information on one or more of the following legal bases:

Consent: Where you have given us specific, informed consent for a particular processing activity.
Contract Performance: Where processing is necessary to perform a contract with you or to take steps at your request prior to entering into a contract.
Legal Obligation: Where processing is necessary to comply with a legal or regulatory obligation to which we are subject.
Legitimate Interests: Where processing is necessary for our legitimate business interests or those of a third party, provided that such interests are not overridden by your rights and interests. Our legitimate interests include operating and improving our Site and Services, marketing our products, and ensuring network and information security.
Vital Interests: Where processing is necessary to protect the vital interests of you or another individual.

How We Share Your Information

We may share your Personal Information with the following categories of recipients:

Affiliates and companies within our corporate group.
Service providers and business partners, including distributors, agents, suppliers, health care professionals, technology service providers, professional advisors, and auditors who support our business operations.
Government agencies, regulators, courts, and law enforcement authorities as required by law.
Third parties or individuals at your request (such as a caregiver or health care provider).
Parties involved in any actual or prospective corporate reorganization, merger, acquisition, or sale of all or substantially all of our assets.

We will not sell your Personal Information except as permitted by applicable law and disclosed in this Policy. We may disclose your information in the following additional circumstances:

To service providers supporting our business operations, subject to appropriate confidentiality and data protection obligations.
Where we have informed you at the time of collection or as expressly permitted under any agreement with you.
Where the information has been aggregated or de-identified such that it can no longer reasonably identify you.
Where disclosure is necessary to provide products or services you have requested.
In response to lawful demands or requests by governmental authorities or as required by law.

How We Protect Your Information

BoundaryCare implements administrative, technical, and physical safeguards designed to protect Personal Information against unauthorized access, use, alteration, and destruction. These measures are appropriate to the nature and sensitivity of the information we process. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security. We encourage you to take appropriate precautions, including safeguarding your account credentials and exercising caution when transmitting information electronically.

Transfer and Storage of Your Personal Information

The Site and our Services are primarily intended for use within the United States. If you access the Site or Services from outside the United States, your information may be transferred to, stored, and processed in the United States or other countries where our service providers operate. The data protection laws of these countries may differ from those in your country of residence. By using the Site or Services, you acknowledge and consent to such transfers. Where required by applicable law, we will implement appropriate safeguards for cross-border data transfers.

Retention of Your Information

We retain Personal Information for as long as reasonably necessary to fulfill the purposes for which it was collected, comply with applicable legal, regulatory, and contractual obligations, resolve disputes, and enforce our agreements. When Personal Information is no longer required, we will securely delete or de-identify it in accordance with our data retention policies and applicable law. Specific retention periods may vary depending on the nature of the information, the purposes for which it is processed, and applicable legal requirements.

Children’s Privacy

The Site is not directed to children under the age of 13, and we do not knowingly collect Personal Information from children under 13. If we become aware that we have inadvertently collected Personal Information from a child under 13, we will promptly delete that information. If you believe we may have collected information from a child under 13, please contact us immediately at info@boundarycare.com.

Your Rights

We will not discriminate against end users for exercising Personal Information and consumer health data rights. Depending on your jurisdiction, you may have certain rights with respect to your Personal Information and consumer health information, including:

Access: The right to request access to the Personal Information and consumer health information we hold about you.
Correction: The right to request that we correct inaccurate or incomplete Personal Information or consumer health data.
Deletion: The right to request that we delete your Personal Information or consumer health data, subject to certain exceptions.
Portability: The right to receive a copy of your Personal Information or consumer health information in a structured, commonly used, and machine-readable format.
Objection: The right to object to certain processing of your Personal Information or consumer health information.
Restriction: The right to request that we restrict the processing of your Personal Information or your consumer health information under certain circumstances.
Opt-Out: The right to opt out of the sale or sharing of your Personal Information or consumer health information, where applicable.
Non-Discrimination: We will not discriminate against you for exercising any of these rights.

To exercise any of these rights, please contact us using the information in the Contact Us section of this Policy. We will respond to requests within the time frames required by applicable law. We may need to verify your identity before fulfilling your request.

To opt out of marketing emails, you may use the “unsubscribe” link included in our emails. Please note that opting out of marketing emails will not affect transactional or legally required communications.

There may be circumstances where we cannot grant your request, such as where fulfilling the request would interfere with another person’s privacy rights or breach a confidentiality obligation. If we deny a request, we will provide a written explanation.

For state-specific privacy rights, including rights for California residents, please see the applicable addenda below.

Authorized Agent/Caregiver Requests

Where a request is submitted by an individual acting on behalf of a Care Recipient, BoundaryCare may require the requesting party to verify their identity, confirm their relationship to the Care Recipient, and demonstrate their authority to act on the Care Recipient’s behalf. Such verification may include, as applicable, either: (a) demonstrating control over an email address or telephone number associated with an existing BoundaryCare account connected to the Care Recipient; or (b) providing reasonable documentation sufficient to establish the party’s relationship to the Care Recipient and authority to submit the request.

Automated Decision-Making

We do not currently engage in automated decision-making, including profiling, that produces legal or similarly significant effects on individuals. If we implement such processing in the future, we will update this Policy and provide notice as required by applicable law.

Links to Other Websites

The Site may contain links to websites operated by third parties. These links are provided for convenience and do not imply endorsement. BoundaryCare is not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policy of every website you visit.

Contact Us

If you have any questions, concerns, or requests regarding this Policy or our privacy practices, please contact us:

Email: info@boundarycare.com

Mail: BoundaryCare LLC, 438 Portland Avenue #6, Saint Paul, MN 55102

We will endeavor to respond to all inquiries within a reasonable time frame and in accordance with applicable law.

APPENDIX A: CALIFORNIA RESIDENTS PRIVACY NOTICE

This Addendum supplements the Policy and applies solely to California residents. It is provided in accordance with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, “CCPA”), and other applicable California privacy laws.

A.1 Categories of Personal Information Collected

In the preceding twelve (12) months, we have collected the following categories of Personal Information (as defined by the CCPA) from consumers:

Identifiers (e.g., name, email address, IP address, account name).
Personal information categories listed in California Civil Code § 1798.80(e) (e.g., name, address, telephone number, financial information).
Protected classification characteristics (e.g., age, gender).
Internet or other similar network activity (e.g., browsing history, interaction with our Site).
Geolocation data.
Professional or employment-related information.
Sensitive personal information, including health-related data and precise geolocation, collected only as necessary to provide our Services.

A.2 Sources of Personal Information

We collect Personal Information from the categories of sources described in Section 6 of the Policy.

A.3 Purposes for Collection and Use

We collect and use Personal Information for the business and commercial purposes described in Section 8 of the Policy.

A.4 Sale and Sharing of Personal Information

We do not “sell” Personal Information as that term is traditionally understood. However, certain disclosures of Personal Information to third-party advertising partners for cross-context behavioral advertising purposes may constitute “selling” or “sharing” under the CCPA. To opt out, please contact us at info@boundarycare.com.

A.5 Your California Privacy Rights

As a California resident, you have the following rights under the CCPA:

Right to Know: You may request that we disclose the categories and specific pieces of Personal Information we have collected about you, the sources of collection, the purposes for collection, and the categories of third parties with whom we share your information.
Right to Delete: You may request that we delete your Personal Information, subject to certain exceptions.
Right to Correct: You may request correction of inaccurate Personal Information.
Right to Opt-Out: You may opt out of the sale or sharing of your Personal Information.
Right to Limit Use of Sensitive Personal Information: You may direct us to limit our use of your sensitive Personal Information to purposes permitted by the CCPA.
Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

To exercise your rights, contact us at info@boundarycare.com or by mail at the address in the Contact Us section above. We will verify your identity before processing your request. You may designate an authorized agent to submit a request on your behalf.

A.6 Do Not Track Signals

Our Site does not currently respond to “Do Not Track” browser signals. However, you may manage your tracking preferences using the opt-out tools described in the Contact Us section in the body of this Policy.

A.7 Shine the Light

Under California Civil Code § 1798.83, California residents with an established business relationship with us may request information about the categories of Personal Information shared with third parties for their direct marketing purposes during the preceding calendar year. To submit a request, contact us at the information provided in the Contact Us section in the body of this Policy.

A.8 California Minors

Under California Business and Professions Code § 22581, California residents under the age of 18 who are registered users may request removal of content or information they have publicly posted. To submit such a request, contact us at info@boundarycare.com and include the email address associated with your account. Please note that removal may not be complete or comprehensive in all circumstances as permitted by law.

APPENDIX B: ADDITIONAL STATE PRIVACY RIGHTS

Residents of Virginia, Minnesota, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and other states with comprehensive consumer privacy laws may have additional rights, including:

The right to confirm whether we are processing your Personal Information.
The right to access, correct, and delete your Personal Information.
The right to data portability.
The right to opt out of processing for targeted advertising, sale of personal data, or profiling with legal or similarly significant effects.
The right to appeal a denial of your request.

To exercise these rights or file an appeal, please contact us using the information provided in the Contact Us section above. We will respond within the time frames required by the applicable state law.

Effective Date: June 8, 2026

Last updated: June 8th, 2026