1. Information We Collect

1.1 Information You Provide to Us

• Account Information: When you create an account, we collect your name, email address, phone number, and organization details.
• Contact Information: When you contact us for support or inquiries, we collect the information you provide in your communications.
• Resident Information: Information about residents or individuals being monitored, including names, room assignments, and care-related notes (where applicable and with proper consent).
• Payment Information: Billing and payment details necessary to process your subscription (processed securely through third-party payment processors).

1.2 Information Collected Automatically

• Motion and Activity Data: Our WiFi sensing technology collects anonymized motion patterns, activity levels, and movement data within monitored spaces.
• Device Information: Information about the devices and hardware used to access our Service, including device identifiers, operating system, and browser type.
• Usage Information: Details about how you use our Service, including login times, features accessed, and user interactions.
• Log Data: Server logs that may include IP addresses, access times, and system events.

1.3 Information from Third Parties

We may receive information from third-party integrations, such as electronic health record (EHR) systems or other healthcare platforms, when you choose to connect these services to our platform.

2. How We Use Your Information

We use the information we collect for the following purposes:

• To provide, operate, and maintain our Service
• To process transactions and manage your account
• To send you technical notices, updates, and support messages
• To respond to your comments, questions, and customer service requests
• To monitor and analyze usage patterns to improve our Service
• To detect, prevent, and address technical issues and security vulnerabilities
• To comply with legal obligations and protect our rights
• To develop new features and improve existing functionality
• To provide wellness insights and safety alerts as part of our core service

3. How We Share Your Information

We do not sell, trade, or otherwise transfer your personal information to third parties except as described below:

3.1 Service Providers

We may share information with trusted third-party service providers who assist us in operating our Service, conducting our business, or serving our users, provided they agree to keep this information confidential.

3.2 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the business transaction.

3.3 Legal Requirements

We may disclose your information when required by law, court order, or government regulation, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

3.4 Aggregated Data

We may share aggregated, anonymized data that cannot be used to identify you or any individual for research, analytics, or business purposes.

4. Data Security

We implement appropriate technical and organizational security measures to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and authentication mechanisms
• Employee training on data protection and privacy
• Secure data centers with physical and digital safeguards

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

5. HIPAA Compliance

For customers who are "Covered Entities" under the Health Insurance Portability and Accountability Act (HIPAA), we serve as a Business Associate and will enter into a separate Business Associate Agreement (BAA). Under the BAA:

• We will use and disclose Protected Health Information (PHI) only as permitted by the BAA
• We implement appropriate safeguards to protect PHI
• We will report any unauthorized use or disclosure of PHI
• We will return or destroy PHI upon termination of the agreement

6. Data Retention

We retain your information for as long as necessary to provide our Service and fulfill the purposes outlined in this Privacy Policy. Specifically:

• Account information is retained for the duration of your subscription and for a reasonable period thereafter
• Motion and activity data is typically retained for up to 2 years for trend analysis and service improvement
• Aggregated, anonymized data may be retained indefinitely for research and development purposes
• We may retain certain information longer if required by law or for legitimate business purposes

7. Your Rights and Choices

Depending on your location and applicable laws, you may have the following rights regarding your personal information:

• Access: Request access to the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal and contractual obligations)
• Portability: Request a copy of your data in a structured, machine-readable format
• Restriction: Request restriction of processing under certain circumstances
• Objection: Object to processing based on legitimate interests

To exercise these rights, please contact us using the information provided in the "Contact Us" section below.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. When we transfer your information internationally, we implement appropriate safeguards to ensure your information receives adequate protection.

9. Children's Privacy

Our Service is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information promptly.

10. Changes to This Privacy Policy

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

• Posting the updated Privacy Policy on our website
• Sending you an email notification (if you have provided your email address)
• Providing notice through our Service

Your continued use of the Service after any changes indicates your acceptance of the updated Privacy Policy.

11. Contact Us

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

• By email: privacy@dar.win
• By visiting our contact page: dar.win/contact
• By mail: DARWIN Software Systems, Inc., New York, NY 10001

We will respond to your inquiry within a reasonable timeframe, typically within 30 days.

12. State-Specific Privacy Rights

California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information we collect, use, disclose, and sell
• Right to delete personal information we have collected
• Right to opt-out of the sale of personal information (we do not sell personal information)
• Right to non-discrimination for exercising your privacy rights

Other State Residents

Residents of other states may have additional privacy rights under applicable state laws. Please contact us to learn more about your specific rights.