Privacy Policy

1. Introduction

Keen Companions LLC ("Keen Companions," "Company," "we," "us," or "our") respects your privacy and is committed to protecting it. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you access or use KeenCompanions.com, our related websites, subdomains, application tools (including mobile apps), software, and other services (collectively, the "Platform"), whether as a guest or a registered user.

This Privacy Policy is incorporated by reference into, and should be read together with, our Terms of Use. Capitalized terms not defined here have the meaning given to them in the Terms of Use. If you do not agree with this Privacy Policy, you must not access or use the Platform.

2. Scope & Eligibility

The Platform is intended solely for individuals who are 18 years of age or older, of sound mind, and legally capable of making their own healthcare and personal decisions. It is not directed at or intended for use by minors.

Many of our users are family members or caregivers who set up Keen Companions for a senior loved one (a "Care Recipient"). Here is how that works:

• The Care Recipient decides. When a Care Recipient first logs in, we ask them to confirm two things: that they understand their companion is a synthetic avatar and not a real person or medical professional, and that they give permission for their named loved one or caregiver to see their information in the Keen Companions family portal. We do not give a caregiver portal access to a Care Recipient's conversations, life story, or reminders until the Care Recipient has given that permission.
• What a caregiver can see. With permission, a caregiver can view the Care Recipient's conversations, biography, and reminders, and can set reminders, through the family portal.
• Caregiver responsibilities. If you are setting up an account for a Care Recipient, you confirm that you have the authority to do so and that the Care Recipient knows about it and is willing to take part. If you are a caregiver using the portal, you agree to use the information only to support the Care Recipient's care and wellbeing, and to keep it private.
• Changing or withdrawing permission. A Care Recipient may withdraw their permission at any time by contacting us at info@keencompanions.com, and we'll end the caregiver's access. Because we're a small team, please allow a few business days.
• Your rights apply to both. This Privacy Policy covers information about the Care Recipient as well as information about the caregiver.

3. Information We Collect

Information you provide to us. This includes:

• Registration and account information (e.g., name, email, phone number, mailing address, and similar identifiers you provide when creating an account).
• Profile information about you and, where applicable, a Care Recipient.
• User Contributions - documents, videos, audio recordings, life-story and "biographer" content, and other materials you input, post, record, submit, publish, display, store, or transmit on or through the Platform.
• Communications you send us, including feedback, support requests, and messages to info@keencompanions.com.

Information we collect automatically. When you use the Platform, we may automatically collect device information, log data, and usage/analytics information (such as features used, session activity, and general performance data) to operate and improve the Platform.

Information from third parties. The Platform may include content or information provided by other users, caregivers, doctors and healthcare providers, family members, or other third parties who interact with your account or a shared Care Recipient profile.

What we do not want you to submit - Protected Health Information (PHI). The Platform is not designed or intended to collect, store, or transmit Protected Health Information as defined under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), and Keen Companions is not a HIPAA-covered entity. Please do not input or share PHI, including personal medical records, treatment details, or health information that identifies a specific individual's medical history or care plan. Features like medication reminders are meant to hold general, non-identifiable information (for example, a reminder label and a time) rather than clinical or diagnostic detail - please keep any health-related entries general in nature. By using the Platform, you acknowledge that it does not offer HIPAA-compliant safeguards for PHI.

4. How We Use Information

We use the information we collect to:

• Provide, operate, and maintain the Platform, including medication and wellness reminders and caregiver escalation notifications;
• Personalize your experience and support features such as life-story and biographer content;
• Process User Contributions using artificial intelligence and large language models, as described in Section 5 below;
• Compile aggregate or anonymized statistical and performance information about use of the Platform ("Data," as defined in the Terms of Use);
• Improve, test, and develop new features and services;
• Communicate with you, including responding to support requests and sending administrative or service-related messages;
• Comply with legal obligations and enforce our Terms of Use; and
• Protect the safety, rights, and property of Keen Companions, our users, and the public, including cooperating with law enforcement or court orders as described in our Terms of Use.

5. AI Processing Disclosure

Some of the content you contribute to the Platform - including life-story and biographer content, and other User Contributions - may be processed using artificial intelligence and large language model ("AI/LLM") technologies, whether operated by Keen Companions or by third-party service providers. This processing may be used to generate summaries, prompts, memorial videos, or other derivative works based on your User Contributions, consistent with the license you grant us under the Terms of Use.

6. How We Share Information

We may share information:

• With service providers and processors who help us operate the Platform (e.g., hosting, analytics, communications, and AI/LLM providers);
• With a Care Recipient's designated caregiver or family circle, so that authorized caregivers and family members can view relevant account and wellness information;
• With our affiliates;
• In connection with a merger, acquisition, reorganization, or sale of assets, consistent with the assignment rights described in our Terms of Use;
• With law enforcement, regulators, or courts when required by law, legal process, or a court order, or when we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Keen Companions, our users, or others; and
• With your consent or at your direction.

We do not sell your personal information to third parties for their own independent marketing purposes.

7. Your Choices & Rights

You may typically access, update, or request correction of your account information by logging into the Platform or contacting us at info@keencompanions.com. You may also request deletion of your information, subject to legal retention requirements.

Your Privacy Rights

We're a small team, and we take your privacy seriously. We offer the rights below to all users in the United States, wherever you live. We'll do our best to honor every request, and if your state's privacy law gives you additional rights, we'll follow it.

You may ask us to:

• Access the personal information we hold about you
• Correct information that is inaccurate
• Delete your personal information
• Provide a copy of your information in a portable format
• Stop selling your information, using it for targeted advertising, or using it for certain automated profiling
• Withdraw your consent at any time for sensitive information you've shared with us, such as responses to wellness check-ins

How to make a request. Email us at info@keencompanions.com. We'll verify your identity before acting on your request. A caregiver or family member may submit a request for a Care Recipient if they can show they're authorized to do so.

How quickly we respond. We aim to respond in a reasonable timeline. If we need more time, we'll tell you why.

If we can't fulfill a request. Because we're a small team, some requests may not be possible to complete in full, for example if they're technically unworkable or if we're required by law to keep certain information. When that happens, we'll explain why. If you disagree with our decision, reply and tell us, and we'll review it again and respond in writing.

8. Data Retention

We retain information for as long as your account is active or as needed to provide the Platform, comply with our legal obligations, resolve disputes, and enforce our agreements.

9. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect your information. However, as explained in our Terms of Use, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining appropriate safeguards on your own devices and for maintaining backups of any information important to you.

10. Children's Privacy

The Platform is intended solely for use by individuals 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected information from a minor, we will take steps to delete it. Email us at info@keencompanions.com.

11. International Users

The Platform is intended for use within the United States.

12. Third-Party Links

The Platform may contain links to third-party websites or resources, including those provided by caregivers, healthcare providers, or advertisers. These links are provided for your convenience only. We do not control and are not responsible for the content, privacy practices, or terms of any third-party sites. Accessing a linked third-party site is entirely at your own risk and subject to that site's own privacy policy and terms.

13. Changes to This Policy

We may revise and update this Privacy Policy from time to time in our sole discretion. All changes are effective immediately when posted. Your continued use of the Platform after a revised Privacy Policy is posted means you accept and agree to the changes. We encourage you to review this page periodically.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your information, please contact us at:

For disputes, this Privacy Policy is subject to the Informal Resolution and Binding Individual Arbitration provisions set out in our Terms of Use.