ConSoul Privacy Policy

Last Updated: January 2026

At ConSoul Inc. (“ConSoul,” “we,” “our,” or “us”), we respect your privacy and are committed to protecting the information you share with us. This Privacy Policy explains what information we collect, why we collect it, how we use and protect it, and your rights regarding your personal information.

ConSoul operates from Toronto, Ontario, Canada and is designed for users in Canada and the United States. We comply with applicable Canadian privacy laws (including PIPEDA and PHIPA), apply GDPR-aligned privacy principles, implement HIPAA-aligned safeguards where applicable, and meet Apple App Store privacy and AI transparency requirements.

1. Definitions

Account
A unique profile created to access the ConSoul service.

Company
ConSoul Inc., Toronto, Ontario, Canada.

Device
Any device capable of using our service (computer, phone, tablet).

Personal Data
Information that identifies, or can reasonably identify, an individual.

Service
The ConSoul website (https://www.consoulapp.com) and the ConSoul mobile application.

Service Provider
Any trusted third party supporting delivery of our service, including hosting, analytics, messaging, payment processing, and technical providers.

Usage Data
Information collected automatically from interactions with the Service.

You / User
The individual using the Service, including individuals acting on behalf of another person with appropriate authority.

2. Information We Collect and Why We Collect It

We collect the minimum information necessary to operate ConSoul, personalize your experience, and improve the platform. Many categories are optional and collected only with your consent.

A. Account & Identity Information

What we collect:

• Name

• Email address

• Phone number (optional)

• Password or authentication tokens

Why:
To create and maintain your account, authenticate access, and communicate important service updates.

B. Caregiver & Care Recipient Information

What we collect:

• Care recipient name or nickname

• Relationship to the caregiver

• Care schedules, tasks, and routines

• Care preferences or instructions

• Notes and caregiving details entered by you

• Uploaded documents (e.g., care plans, benefit documents)

Why:
To support scheduling, reminders, coordination, care-circle organization, and personalized navigation.

C. Emotional Check-Ins & Wellbeing Inputs (Optional)

What we collect:

• Short written reflections

• Self-reported stress or wellbeing notes

Why:
To tailor insights, identify patterns, and provide supportive recommendations. These features are optional and require explicit consent.

D. Communications & Contact Information

What we collect:

• Messages sent within the app

• Invitations to care-circle members (with permission)

• Support requests or emails sent to us

Why:
To enable communication and provide customer support.

E. Device & Technical Data

What we collect:

• IP address

• Device type and operating system

• Browser type

• App version

• Crash logs and diagnostics

• Device identifiers (IDFV or IDFA where permitted)

Why:
To maintain security, ensure performance, troubleshoot issues, and support analytics.

F. Usage & Interaction Data

What we collect:

• Screens viewed

• Features used

• Time spent in the app

• Navigation patterns

• Session duration and frequency

Why:
To understand how the Service is used and improve user experience.

G. Cookies & Local Storage

What we collect:

• Session cookies

• Authentication tokens

• Preference settings

Why:
To keep you logged in and enhance functionality.
We do not use third-party advertising cookies.

H. Employer or Benefits Program Information (If Applicable)

What we collect:

• Employer name or program eligibility details

• Access status

• Aggregated, non-identifying usage statistics

Why:
To validate eligibility and provide organizations with high-level insights.
We never share your personal caregiving information with your employer.

I. Payment Information (For Paid Plans)

What we collect:

• Billing name

• Payment confirmation

• Subscription details

Payments are processed by secure third-party providers. ConSoul does not store full credit card numbers.

J. Optional Uploads & Integrations (With Explicit Consent)

What we collect:

• Files or documents uploaded

• Calendar access or syncing (if enabled)

Why:
To support care planning, reminders, and documentation features.

K. System-Generated & AI Interaction Data

What we collect:

• Summaries of interactions with ConSoul’s digital Copilots

• Workflow routing or automation logs

• Task and reminder metadata

Why:
To deliver contextual assistance, improve reliability, ensure safety, and enhance platform performance.

L. Sensitive Health-Related Information (Voluntary)

You may choose to enter health-related information, including conditions, symptoms, functional needs, accessibility requirements, or care details.

Why:
To support personalized navigation and planning. Where applicable, this information is handled in accordance with PHIPA (Canada) and HIPAA-aligned safeguards (United States).

3. AI-Powered Features & Limitations

ConSoul includes AI-powered tools (“Copilots”) designed to support care coordination, navigation, organization, and information synthesis.

AI-generated responses:

• Are informational and organizational in nature

• Are not medical, clinical, legal, or financial advice

• Do not replace professional judgment or care

AI interaction data may be reviewed in anonymized or aggregated form for quality assurance and safety. AI interaction data is never sold and is never used to train external or third-party models.

4. No Automated Decision-Making

ConSoul does not use AI to make automated decisions that produce legal or similarly significant effects. AI features support human decision-making; they do not replace it.

5. HIPAA & U.S. Health Information (U.S. Users)

ConSoul is not a healthcare provider and does not deliver medical care.

Where information may qualify as Protected Health Information (PHI) under U.S. law, ConSoul applies administrative, technical, and physical safeguards aligned with HIPAA standards, including encryption, access controls, and audit logging. PHI is not used for advertising or unauthorized purposes.

6. How We Use Your Information

We process information for the following purposes:

• Service provision (contractual necessity)

• Personalization (with consent)

• Communication (with opt-out options)

• Platform improvement and safety (legitimate interest)

• Legal and regulatory compliance

7. No Reliance & User Responsibility

ConSoul provides tools for information, organization, and navigation only. Users are responsible for evaluating information provided through the Service and for making their own decisions.

ConSoul is not responsible for actions taken based on platform content, AI-generated information, or third-party resources.

8. Third-Party Services & Vendors

ConSoul may help users identify or coordinate third-party services (such as home care, transportation, or meal delivery). These services are provided by independent third parties.

ConSoul does not control, endorse, or guarantee third-party services and is not responsible for their acts, omissions, or outcomes.

9. No Professional Relationship

Use of ConSoul does not create a medical, legal, financial, therapeutic, fiduciary, or professional relationship between users and ConSoul or its representatives.

10. Authority to Act on Behalf of Others

If you use ConSoul on behalf of another individual, you represent that you have the legal authority and consent to do so and to share information related to their care.

11. Emergency Disclaimer

ConSoul is not designed for emergency use. If a medical, safety, or mental-health emergency occurs, contact local emergency services immediately.

12. Children & Minors

ConSoul is not directed to children under 13. If information about a minor is provided, the user confirms appropriate parental or legal authority.

13. Security & Data Storage

We use industry-standard security measures, including:

• Encryption in transit (TLS 1.2+)

• Encryption at rest (AES-256)

• Role-based access controls

• Monitoring and auditing

Data is hosted in Microsoft Azure, primarily in Canadian data centers, with HIPAA-aligned safeguards for U.S. users.

14. Your Rights

Depending on your location, you may:

• Access or correct your data

• Request deletion

• Withdraw consent

• Request a copy of your information

We respond within applicable legal timelines.

15. Governing Law

This Privacy Policy is governed by the laws of the Province of Ontario and applicable federal laws of Canada.

16. Policy Updates

We may update this Privacy Policy periodically. Continued use of the Service constitutes acceptance of the updated policy.

17. Contact Us

Data Protection Officer
Cindy Diogo
ConSoul Inc.
Toronto, Ontario, Canada
📧 info@consoulapp.com