Privacy Policy for myCARI

Introduction

MLPipes LLC (“we,” “our,” or “us”) operates the myCARI mobile application (the “App”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App.

We take your privacy seriously, especially given the sensitive nature of health information. Please read this Privacy Policy carefully. By using myCARI, you agree to the collection and use of information in accordance with this policy.

Related Documents:

• Terms of Service
• HIPAA Authorization Notice
• Care Team Member Agreement

Information We Collect

Personal Information

When you create an account, we collect:

• Account Information: Name, email address, phone number, date of birth
• Profile Information: Profile photo, height, weight, sex, blood type
• Authentication Data: Encrypted passwords, biometric authentication preferences

Health and Medical Information

With your explicit consent, we collect:

From Apple HealthKit

• Heart rate and resting heart rate
• Blood pressure readings
• Blood glucose levels (including continuous glucose monitor data)
• Oxygen saturation (SpO2)
• Respiratory rate
• Body measurements (weight, BMI)
• Sleep data (duration, stages, quality)
• Step count and activity data
• Workout and exercise data
• Electrocardiogram (ECG) data
• Hydration data (if tracking enabled)

Manually Entered Health Data

• Health reading measurements
• Medication information (names, dosages, schedules)
• Medical appointments
• Medical history and conditions
• Allergy information

AI-Analyzed Data

myCARI uses Google Gemini AI (provided by Google LLC via Google Cloud) to generate personalized health insights. The following data is sent to Google Gemini AI for processing:

• Meal Photos: Images you photograph are sent to Google Gemini AI to identify foods, estimate portion sizes, and calculate nutritional content (calories, protein, carbohydrates, fats, fiber). Nutritional estimates reference the USDA FoodData Central database. Meal photos are stored securely in Google Cloud Storage.
• Health Insights: Your vitals, activity, sleep, and medication data are sent to Google Gemini AI to generate personalized daily health coaching and goal recommendations
• Pattern Detection: AI identifies trends, anomalies, and correlations in your health data

The following features send data to Google Gemini AI and require your in-app consent before first use:

The following features are computed entirely on your device and do NOT send data to Google Gemini AI:

You will be asked to consent to AI data processing before using any AI-powered feature for the first time. You can withdraw consent at any time in Settings > AI Data Processing, which will disable all AI features listed above until consent is re-granted. On-device features continue to work regardless of AI consent status.

Healthcare Provider Data (FHIR Integration)

When you connect your healthcare provider accounts (Epic MyChart, Cerner, athenahealth, etc.), we import:

• Laboratory results and reference ranges
• Medication lists and prescriptions
• Diagnoses and problem lists
• Immunization records
• Allergy and intolerance information
• Clinical notes and visit summaries
• Imaging and procedure reports

This data is imported via secure SMART on FHIR protocols with OAuth 2.0 authentication.

Care Team Information

If you use care team features:

• Care team member relationships and permission levels
• Shared health data (as configured by you)
• Messages between care team members (individual and group)
• Invitation and acceptance records
• Care team member consent acknowledgments

Message Retention

• Messages are stored securely for care coordination purposes
• You can delete messages from your view at any time
• Important: For HIPAA compliance and care continuity, original message content may be retained in audit logs even after deletion from your view
• “Unsent” messages preserve original content in secure audit storage
• Message audit logs are retained for a minimum of 6 years as required by law

Device and Usage Information

• Device type and operating system
• App usage patterns and features accessed
• Crash logs and performance data
• Push notification tokens
• Device identifier: Apple's Identifier for Vendor (IDFV), a per-app, per-device identifier assigned by iOS. It is sent with requests to our servers and used to detect repeated free-trial signups from the same device, to record which device accepted a legal agreement, and to log which device authorized Apple Health access. This identifier is reset by Apple when you delete myCARI from your device. It is not Apple's Advertising Identifier (IDFA); we do not collect the IDFA and we do not use any identifier for advertising.
• Feature experiment assignment: which variant of an in-app experiment your installation received, so we can measure whether a change improves the experience

Location Information

With your consent, we may collect:

• Location data for safety features
• Location for emergency response services

SOS and Safety Feature Data

When you use SOS and safety features, we collect:

• SOS button activation timestamps
• Fall detection sensor data and events
• Emergency contact notification records
• Location data at time of alert (if enabled)
• Care team notification delivery status
• Response acknowledgment records

How We Use Your Information

We use your information to:

Provide Core Services

• Display and track your health metrics
• Manage medications and send reminders
• Schedule and track medical appointments
• Generate personalized health insights
• Enable care team collaboration and communication

Improve Our Services

• Analyze app usage to improve features
• Develop new health tracking capabilities
• Fix bugs and improve performance
• Run A/B experiments, in which different installations of the App receive different versions of a feature so we can compare which works better. Experiment assignment uses your device's app-instance identifier and does not use your health data.

Safety and Security

• Enable emergency response features
• Detect and prevent fraud
• Ensure account security

Communications

• Send medication reminders and health alerts
• Notify you of appointment reminders
• Send care team messages and notifications
• Provide customer support

SOS and Safety Alerts

• Deliver SOS notifications to your designated care team members
• Send fall detection alerts to care team members
• Transmit location data during emergency alerts (if enabled)

Apple HealthKit Data

We handle Apple HealthKit data with special care in compliance with Apple's HealthKit guidelines:

We DO NOT:

• Advertise or market using HealthKit data
• Sell HealthKit data to any third party, including advertising platforms, data brokers, or information resellers
• Share HealthKit data with third parties for their advertising or marketing purposes
• Use HealthKit data for credit scoring, insurance underwriting, or similar eligibility determinations
• Disclose HealthKit data to third parties without your explicit, informed consent

We DO:

• Use HealthKit data only to provide health tracking features within the App
• Share HealthKit data with care team members only with your explicit consent and at permission levels you control
• Protect HealthKit data with encryption at rest (AES-256) and in transit (TLS 1.3)
• Request access only to HealthKit data types necessary for app functionality

HealthKit Data Types We Access

You can revoke HealthKit access at any time in iOS Settings > Privacy & Security > Health > myCARI.

How We Share Your Information

Care Team Sharing

You control what health information is shared with your care team members:

• Basic View: Medications, appointments, emergency alerts
• Full View: Above plus vitals, medical records
• Professional Caregiver: Professional access with audit logging

You can modify or revoke care team permissions at any time.

Service Providers

We share information with third-party service providers who assist in operating our App:

These providers are bound by contractual obligations to protect your data.

Legal Requirements

We may disclose your information if required by law or in response to:

• Valid legal process (subpoenas, court orders)
• Government requests
• Protection of our legal rights
• Emergency situations involving potential harm

With Your Consent

We may share your information with third parties when you explicitly consent to such sharing.

Data Storage and Security

Storage Location

• Your data is stored on secure servers in the United States
• We use Google Cloud Platform with encryption at rest and in transit

Security Measures

• AES-256 encryption for data at rest
• TLS 1.3 encryption for data in transit
• Secure authentication with Firebase
• Biometric authentication support (Face ID, Touch ID)
• Regular security audits and updates

Data Retention

• Active account data is retained while your account is active
• You can request deletion of your data at any time
• Upon account deletion, data is removed from active systems within 30 days
• Backup copies may be retained for up to 90 days before permanent removal
• HIPAA audit logs and compliance records are retained for 6 years as required by law

Your Rights and Choices

Access and Portability

• View all your health data within the App
• Export your data in standard formats
• Request a copy of all data we hold about you

Correction

• Update your profile and health information at any time
• Correct inaccurate health records

Deletion

• Delete individual health records
• Delete your account using Profile > Delete Account in the App, or by emailing support@mlpipes.ai
• Upon account deletion, we permanently remove your account and all associated data — including vitals, medications, appointments, meals, workouts, sleep data, AI Health Coach analyses, and care team memberships — from active systems within 30 days
• Backup copies may be retained for up to 90 days before permanent removal
• HIPAA audit logs are retained for 6 years as required by law
• Important: Deleting your myCARI account does not cancel your Apple subscription. You must separately cancel in your device's Settings > Subscriptions to stop future charges.

Analytics Opt-Out

• You can disable usage analytics in Settings > Privacy within the App
• When analytics is disabled, we stop collecting feature usage data on your device
• Previously collected analytics data is anonymized and cannot be linked back to you

Consent Withdrawal

• Revoke HealthKit permissions in iOS Settings
• Disable care team data sharing
• Opt out of non-essential communications
• Disable analytics data collection (see Analytics Opt-Out above)

Manage Permissions

• Control which care team members can view your data
• Modify permission levels at any time
• Remove care team members

Children's Privacy

myCARI is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you believe we have collected information from a child under 13, please contact us immediately.

International Data Transfers

Your personal data is stored and processed in the United States using Google Cloud Platform infrastructure. If you access myCARI from outside the United States, your information is transferred to and processed in the United States by the following service providers:

• Google Cloud Platform (Google LLC) — Backend infrastructure and data storage (US regions)
• Firebase (Google LLC) — Authentication, messaging, and analytics (US)
• Google Gemini AI (Google LLC) — AI-powered meal analysis and health insights (US)

These transfers are governed by contractual safeguards, including Google's Data Processing Amendment and Standard Contractual Clauses, to ensure your data receives adequate protection regardless of where it is processed.

By using the App, you consent to the transfer of your data to the United States for processing as described in this Privacy Policy.

Usage Analytics

To improve myCARI, we collect anonymized feature usage data such as which screens you visit and which actions you take (for example, logging a meal or marking a medication as taken). This data does not include your health measurements, personal identifiers, names, or contact information — only action types, feature names, and structural metadata.

Analytics data is collected via Firebase Analytics (Google LLC) and retained for 14 months. You may opt out of analytics at any time in Settings > Privacy within the App.

Your Rights by Region

For Users in the Philippines

Your personal data is protected under Republic Act No. 10173 (Data Privacy Act of 2012). MLPipes LLC is registered with the National Privacy Commission (NPC) of the Philippines.

• NPC Registration Number: PIC-007-775-2026
• Company Name: MLPipes LLC
• Company Address: 5725 S Valley View Blvd Ste 5 PMB 471045, Las Vegas, Nevada 89118-3122 US

Your Data Protection Rights Under RA 10173

In addition to the rights listed in the “Your Rights and Choices” section above, you have the following rights:

1. Right to be Informed — You have the right to be informed that your personal data is being collected, processed, or transferred, including the identity of the data controller, purposes of processing, and recipients of your data.
2. Right to Object — You have the right to object to the processing of your personal data, including for direct marketing or automated decision-making. To exercise this right, email dpo@mlpipes.ai with subject “Right to Object.”
3. Right to Access — You have the right to access all personal data we hold about you and to obtain information about how it is processed. You can access most data directly in the App, or request a full copy from our DPO.
4. Right to Correct — You have the right to correct, update, or complete your personal data if it is inaccurate, incomplete, or outdated. You can update data directly in the App or contact our DPO.
5. Right to Erase or Block — You have the right to erase or block your personal data when the data is no longer necessary for its purpose, you withdraw consent, or processing is unlawful. Delete individual records or your entire account via Profile > Delete Account, or email support@mlpipes.ai.
6. Right to Data Portability — You have the right to obtain your personal data in a structured, commonly used, machine-readable format. Contact our DPO to request an export.
7. Right to Damages (Indemnification) — You have the right to demand indemnification for damages sustained due to inaccurate, incomplete, outdated, or unauthorized processing of your personal data.
8. Right to Lodge a Complaint with the NPC — You have the right to file a complaint with the National Privacy Commission if you believe your data is being processed in violation of RA 10173.
   • NPC Website: privacy.gov.ph
   • NPC Address: National Privacy Commission, 3rd Floor, Postal Services Building, 101 Juan Luna Street, Binondo, Manila 1006, Philippines
   • NPC Hotline: +63-2-8631-7386

Legal Basis for Data Processing

We process your personal data on the following lawful bases under RA 10173 Section 12:

1. Your Explicit Consent — For processing health information, AI analysis, care team sharing, and international data transfers. You may withdraw consent at any time by disabling features in Settings, revoking HealthKit permissions, or contacting dpo@mlpipes.ai. Withdrawal does not affect processing that occurred before withdrawal.
2. Contractual Necessity — For providing myCARI services and fulfilling our service agreement with you (account management, health tracking, medication reminders, care team coordination, subscription processing).
3. Legal Obligation — To comply with HIPAA audit logging requirements, valid court orders, and mandatory incident reporting.
4. Legitimate Interests — For detecting and preventing fraud, improving App features, and enforcing our Terms of Service, where such interests do not override your rights.

Data Retention by Category

After the retention period expires, we permanently delete or anonymize your data, except where retention is required by law. You may request deletion of any data category at any time, subject to legal retention requirements, by contacting dpo@mlpipes.ai.

Breach Notification

In the event of a data breach affecting your personal data, we will:

1. Notify the NPC within 72 hours of discovering the breach, including the nature and scope of the breach, types of data affected, estimated number of users affected, and measures taken to address the breach.
2. Notify you within 72 hours (or as soon as practicable) via email to your registered address and in-app notification, including what happened, what data was affected, what actions we have taken, and what steps you should take to protect yourself.
3. Coordinate with law enforcement if the breach involves criminal activity.

International Data Transfers

Your personal data is transferred to and processed in the United States. By using myCARI, you explicitly consent to the transfer of your personal data from the Philippines to the United States and processing by Google Cloud Platform, Firebase, and Google Gemini AI (all US-based services). These transfers are protected by Google's Data Processing Amendment (DPA) and Standard Contractual Clauses (SCCs) with data protection obligations equivalent to RA 10173 standards. You may revoke this consent at any time by deleting your account.

Data Protection Officer

• Name: Al Sabay
• Title: CEO & Data Protection Officer
• Email: dpo@mlpipes.ai
• Response Time: Acknowledgment within 5 business days; substantive response within 30 days

To exercise any of your rights under RA 10173, email dpo@mlpipes.ai with subject line starting with “RA 10173 Request:” and include your full name, email, and the nature of your request.

For Users in the European Union / European Economic Area

If we expand to EU/EEA regions in the future, additional GDPR-specific rights and disclosures will apply, including the legal basis for processing, explicit opt-in consent for analytics, and enhanced cross-border transfer mechanisms. These will be added before any EU/EEA distribution.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of changes by:

• Posting the new Privacy Policy in the App
• Updating the “Last Updated” date
• Sending a notification for material changes

Your continued use of the App after changes constitutes acceptance of the updated policy.

California Privacy Rights (CCPA)

California residents have additional rights:

• Right to Know: Request what personal information we collect
• Right to Delete: Request deletion of your personal information
• Right to Opt-Out: We do not sell personal information
• Non-Discrimination: We will not discriminate against you for exercising your rights

HIPAA Compliance

While myCARI is not a “covered entity” under HIPAA (as we are not a healthcare provider, health plan, or healthcare clearinghouse), we recognize the sensitive nature of health information and voluntarily implement security practices consistent with HIPAA standards.

We provide a separate HIPAA Authorization Notice that details:

• The specific Protected Health Information (PHI) we collect
• How we use and disclose your PHI
• Your rights regarding your health information
• Our security measures for protecting PHI
• How to revoke your authorization

By using myCARI, you acknowledge and consent to the practices described in both this Privacy Policy and the HIPAA Authorization Notice.

Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us:

ML Pipes LLC

• Email: privacy@mlpipes.ai
• Website: https://carihealth.ai
• Address: 5725 S Valley View Blvd Ste 5 PMB 471045, Las Vegas, Nevada 89118-3122 US

Data Protection Officer:

• Email: dpo@mlpipes.ai

For privacy-related requests, please email privacy@mlpipes.ai with the subject line “Privacy Request.”

For data protection inquiries or to exercise your rights under applicable data privacy laws (including RA 10173 for Philippine users), please contact our Data Protection Officer at dpo@mlpipes.ai.

Electronic Signatures and Consent Records

When you accept this Privacy Policy, the Terms of Service, and the HIPAA Authorization Notice during account creation, you are providing your electronic signature pursuant to the Electronic Signatures in Global and National Commerce Act (E-SIGN Act) and the Uniform Electronic Transactions Act (UETA).

What We Record

Your consent record includes:

• Your email address
• Your unique user ID
• Timestamp of consent (ISO 8601 format)
• Version numbers of documents you accepted
• Your IP address and device identifier (for verification)

Re-Consent for Material Changes

If we make material changes to this Privacy Policy:

• We will notify you via in-app notification and/or email
• You may be required to review and accept the updated policy
• Your continued use after notification constitutes acceptance
• You may delete your account if you do not agree to changes

Consent

By using myCARI, you consent to:

• The collection and use of your information as described in this Privacy Policy
• The sharing of health data with care team members you authorize
• The processing of your data in the United States
• The use of Google Gemini AI to analyze your health data and meal photos (in-app consent is also required before first use of AI features)
• The import of medical records from connected healthcare providers
• The SOS feature limitations, including that it does NOT contact emergency services
• The notification delivery limitations described in this policy
• Your responsibility for data accuracy as described above

This Privacy Policy was last updated on August 21, 2026.