Racy Tech Privacy Policy

Version française : www.racytech.com/fr/privacy. Colombia: Política de Tratamiento de Datos Personales.

Racy Tech Inc. (“Racy Tech”, “we” or “us,” or “our”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you access or use the Platforms and our practices for collecting, using, maintaining, protecting, and disclosing that information. If you’re a resident of California, Washington, or Nevada or visiting us from the European Economic Area (“EEA”), you should read this policy and the applicable sections below for residents of California, Washington, and Nevada and visitors from the UK and EEA. Senior Users in the countries listed under “Country-Specific Information” should also read that section.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using the Platforms, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, you must not access or use the Platforms. This Privacy Policy may change from time to time (see “Changes to Our Privacy Policy” below). Any changes to this Privacy Policy will be effective immediately upon posting the updated Privacy Policy unless otherwise stated or as required by applicable law. Your continued use of this Platforms after we make changes is deemed to be acceptance of those changes to the fullest extent permitted by applicable law, so please check the policy periodically for updates.

Terms not defined in this Privacy Policy shall have the meanings as set forth in Racy Tech’s Terms of Use, which can be found at www.racytech.com/terms.

Scope of Racy Tech’s Privacy Policy

This Privacy Policy applies to all aspects of our Platforms as well as to information we may collect offline. The Platforms may link to or incorporate websites or content hosted and served by others over which we have no control, such as third-party websites, online properties, platforms, social media, or systems, which are each governed by the privacy policies and business practices of third parties. You understand and agree that Racy Tech is not responsible for the security, privacy, or business practices of any third party.

This Privacy Policy applies to information we collect:

• through communications between you and the Platforms;
• in email, text, and other electronic correspondences and interactions between you and us;
• automatically as you access or use the Platforms;
• through third-party applications, links, and business partners; and
• all content on the Platforms, including without limitation the design, text, graphics, logos, software, and the selection, arrangement, and compilation thereof, is the property of Racy Tech or its licensors and is protected by United States and international copyright, trademark, patent, trade secret, and other intellectual property laws. Aggregated, de-identified, or anonymized data derived from your use of the Platforms (data from which all personal identifiers have been removed such that it cannot reasonably be linked to you) is owned by Racy Tech and may be used and disclosed for any lawful purpose, including improving the Platforms and for analytics, research, and commercial purposes, without further notice to you.

Your Information

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Platforms, including information:

• by which you may be personally identified, such as name, e-mail address, postal address, telephone number, location information, payment information (e.g., credit or debit card information, bank account information, and other forms of payment), social media information, any other identifier by which you may be contacted online or offline, including IP addresses, cookie identifiers, usage details, and other tracking technologies, and any other personal information that you provide to us (collectively, “personal information”);
• health information, including Special Category Health Data, heart rate, blood oxygen level, fall detection data, step count, sleep patterns, medication tracking, blood glucose monitoring, blood pressure tracking, and other health data. Racy Tech is not currently acting as a “covered entity” or “business associate” as those terms are defined under the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”). Except where Racy Tech has executed a written business associate agreement with a Covered Entity or Business Associate, the health information we collect through the Platforms is not “protected health information” subject to HIPAA, and the protections afforded by HIPAA do not apply to such information. Where Racy Tech has executed a business associate agreement, the health information processed under that agreement will be handled in accordance with HIPAA and the terms of the applicable business associate agreement. You should not rely on the Platforms or any information we provide for medical advice, diagnosis, or treatment;
• that is about you but individually does not identify you, such as – geo location, operating system, browser preferences, input devices;
• collected through affiliate links; and/or
• about your internet connection, the equipment you use to access our Platforms, and usage details.

We collect this information:

• directly from you when you provide it to us;
• automatically as you navigate through the Platforms (information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies); and
• from third parties, for example, our business partners.

Information that You Provide

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Platforms. This includes information provided at the time of registering to use or creating an account on our Platforms, purchasing our products, subscribing to our services, posting material, or requesting further services. We may also ask you for information when you report a problem with our Platforms.
• Details of transactions you carry out through our Platforms and of the fulfillment of your orders, in which event you may be required to provide financial information before placing an order through our Platforms.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete.
• Any other information, content or documents you upload to the Platforms.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with the Platforms, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to the Platforms, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). See “Choices About How We Use and Disclose Your Information” below for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Platforms and to deliver a better and more personalized service, including by enabling us to:

• Estimate our Platforms usage statistics and usage patterns.
• Store information about your preferences, allowing us to customize our Platforms according to your individual interests.
• Improve the Platforms we provide to you and other users.
• Recognize you when you return to our Platforms.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Platforms. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platforms.
• Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Racy Tech, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Platforms are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

Senior User Health Data

The Senior User has the following rights with respect to their health data, which may be exercised independently of the Caregiver: (a) Right to Revoke: the Senior User may revoke consent to data collection and sharing at any time via the device consent revocation feature or by contacting privacy@racytech.com; (b) Right to Access: the Senior User may request a copy of their health data held by Racy Tech; (c) Right to Deletion: the Senior User may request deletion of their health data, subject to our retention obligations; and (d) Right to Restrict Sharing: the Senior User may request that Racy Tech restrict or suspend sharing of their health data with the Support Network, even if the Caregiver has configured such sharing. To exercise any of these rights, the Senior User should contact privacy@racytech.com. We will respond within the timeframes required by applicable law and will notify the Caregiver of account-level operational changes (such as suspension of data collection) to the minimum extent necessary to administer the account. The exercise of these rights by the Senior User will not affect the lawfulness of data collection or sharing that occurred prior to the request.

The Senior User can withdraw consent in the app, in Settings → Privacy & data → Withdraw consent, without deleting the account. Collection and sharing then stop at once: the app reads and sends nothing more, and the Support Network no longer sees the Senior User’s readings or location. What was collected before is kept, hidden from the Support Network, until the account is deleted. The Senior User can give consent again in the app at any time; nothing recorded while consent was withdrawn is collected afterwards.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• to present our Platforms and its contents to you;
• to provide you with information, products, or services that you request from us (e.g., access to or use of the Platforms);
• to fulfill any other purpose for which you provide it;
• provide you with notices about your account, including expiration and renewal notices;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to notify you about changes to our Platforms;
• to use data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Platforms, marketing, and your experience;
• to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you (you may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us);
• to contact you with respect to items, products or services that are germane to the products and services that we might provide to you;
• to allow you to participate in interactive features on our Platforms;
• in any other way we may describe when you provide the information; and
• for any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us at privacy@racytech.com. For more information, see “Choices About How We Use and Disclose Your Information” below.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. We are not selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, your personal information and data to any persons or entities.

Retention and Transfer of Information

Retention of Your Personal Information and Data

Racy Tech will retain your personal information and data only for as long as is necessary for the purposes set out in this privacy policy. We will retain and use your personal information and data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Racy Tech will also retain your usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our platform, or we are legally obligated to retain this data for longer time periods.

A record of each consent a Senior User gives or withdraws (the version and language of the text, the choices made, and when) is kept for five years after the account is deleted, as proof of the consent, and is then deleted.

Transfer of your Personal Data

Your personal information and data is processed at Racy Tech’s operating offices and in any other places where servers and the parties involved in the processing are located. It means that this information may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Your consent to this privacy policy followed by your submission of such information represents your agreement to that transfer.

Racy Tech will take all steps reasonably necessary to ensure that your personal information and data is treated securely and in accordance with this Privacy Policy.

International Users

By using the Platforms, you understand and agree that Racy Tech will transfer data to the United States and other global jurisdictions. By choosing to access or utilize the Platforms or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the State of Delaware, United States, and the adjudication of any disputes arising in connection with Racy Tech or the Platforms will be in accordance with the Terms of Use which can be found at www.racytech.com/terms.

If you are accessing the Platforms from the European Economic Area, the United Kingdom, Switzerland, or another jurisdiction with laws governing the cross-border transfer of personal data, please be aware that your personal information may be transferred to, stored in, and processed in the United States and other jurisdictions where Racy Tech or its service providers operate, and where data-protection laws may differ from those of your jurisdiction. Where required by applicable law, Racy Tech relies on appropriate safeguards for such transfers, including the European Commission’s Standard Contractual Clauses or the UK International Data Transfer Addendum, or another lawful transfer mechanism. For Senior Users in Switzerland and the other countries listed under “Country-Specific Information,” the basis for each transfer is set out in that section and in the consent given in the app. You may contact us using the details under Contact Information below to request additional information regarding the safeguards we have implemented.

Security of your Personal Data

The security of your personal information and data is important to us, but please be aware that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information and data, we cannot guarantee its absolute security. Any natural or legal person who processes the data on behalf of Racy Tech may have access to your personal information or data. These third-party vendors collect, store, use, process and transfer information about your activity on our platform in accordance with their respective privacy policies. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, RACY TECH DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, REGARDING THE SECURITY OF YOUR PERSONAL INFORMATION, AND SHALL NOT BE LIABLE FOR ANY UNAUTHORIZED ACCESS TO, DISCLOSURE OF, ALTERATION OF, OR DESTRUCTION OF YOUR PERSONAL INFORMATION, EXCEPT TO THE EXTENT SUCH LIABILITY CANNOT BE EXCLUDED OR LIMITED UNDER APPLICABLE LAW. ANY LIMITATIONS OF LIABILITY SET FORTH IN THE TERMS OF USE ARE INCORPORATED HEREIN BY REFERENCE.

Disclosure of Your Information

Information We May Disclose

Some content or applications, including advertisements, on the Website may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this Privacy Policy:

• to our subsidiaries and affiliates;
• to contractors, service providers, and other third parties we use to support our business and who may be bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them;
• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Racy Tech’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Racy Tech about our Platforms’ users is among the assets transferred;
• to third parties to market their products or services to you if you have not opted out of these disclosures (for more information, see Choices About How We Use and Disclose Your Information);
• to fulfill the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information; and
• with your consent.

We may also disclose your personal information:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our Terms of Use which can be found at www.racytech.com/terms and other agreements, including for billing and collection purposes;
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Racy Tech, our customers, or others (this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Promotional Offers from Racy Tech. If you do not wish to have your email address/contact information used by Racy Tech to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the order form/registration form) or at any other time by logging into your account and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to privacy@racytech.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Racy Tech as a result of a product purchase, warranty registration, product service experience or other transactions.
• Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by emailing us at privacy@racytech.com. For this opt-out to function, you must have your browser set to accept all browser cookies.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

California residents may have additional personal information rights and choices. Please see “State Privacy Rights” below for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@racytech.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

If you are a Washington State resident, the Washington My Health My Data Act (“WMHMDA”) provides additional rights with respect to the consumer health data we collect through the Platforms (such as heart rate, blood pressure, blood glucose, and medication tracking data). We do not sell consumer health data and do not use geofencing to target individuals near healthcare facilities. Where required by the WMHMDA, we will obtain your separate written authorization before collecting or sharing your consumer health data for purposes beyond those described in this Privacy Policy, and you may withdraw any such authorization at any time by contacting privacy@racytech.com. Subject to applicable exceptions, you have the right to confirm, access, and request deletion of your consumer health data, and to withdraw authorization, without discrimination. To exercise these rights, contact us at privacy@racytech.com.

State Privacy Rights

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah or Virgina, you may have certain rights in relation to the personal information we collect from you. However, these rights are not absolute, and we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data;
• Right to access your personal data;
• Right to correct inaccuracies in your personal data;
• Right to request the deletion of your personal data;
• Right to obtain a copy of the personal data you previously shared with us;
• Right to non-discrimination for exercising your rights; and
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).

Depending on the state you live in, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota);
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland);
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon);
• Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Minnesota);
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California); and
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida).

To exercise these rights, please contact us at: privacy@racytech.com.

If you are a California resident, you have the right to request that Racy Tech discloses the specific personal information and categories we have collected about you. To request this information, please contact us at: privacy@racytech.com. You can also request to have your personal information deleted that has been collected about you. To submit a deletion request, please contact us at: privacy@racytech.com. We may not be able to accommodate a request if we believe that it would violate any law or legal requirement.

Country-Specific Information

This section applies to Senior Users in the countries below. The notice and consent a Senior User sees in the app give the same information, in English and, where listed, in the country’s own language. For those users it adds to the rest of this Privacy Policy, and prevails where the two differ. Requests and complaints can be sent to our Data Protection Officer, Aydin Cubukcu, at privacy@racytech.com.

Australia

Legal basis. Health information is sensitive information under the Privacy Act 1988, which we collect only with your consent (APP 3.3). We use and disclose your information only for the purposes described in this Privacy Policy, which you consent to (APP 6). Technical data is collected because it is reasonably necessary to run and secure the service. FamilyWatcher is not a medical device: it keeps your family informed and does not diagnose, treat or monitor any condition.

Your rights. Under the Australian Privacy Principles you can ask for access to the personal information we hold about you (APP 12) and for its correction (APP 13). You can withdraw your consent at any time; this does not affect what was done before. You can complain to us about how we handle your information, and we answer within 30 days. If you are not satisfied with our answer, you can complain to the Office of the Australian Information Commissioner (OAIC), oaic.gov.au, 1300 363 992.

Transfers. Racy Tech Inc. is established in the United States and keeps your data there, with Amazon Web Services, Apple and Google as providers. Before your data goes overseas we take reasonable steps, by contract, to ensure our providers do not breach the Australian Privacy Principles (APP 8.1), and we remain accountable for how they handle it (section 16C of the Privacy Act 1988). Your caregivers see your data wherever they are.

Breaches. If a breach of your data is likely to result in serious harm to you, we will tell you and the OAIC under the Notifiable Data Breaches scheme.

Brunei

Legal basis. Your consent, given after the notice in the app of the purposes. Technical data is collected to run and secure the service, which you are told about here.

Your rights. Under the Personal Data Protection Order, 2025 you can ask for access to your personal data and how it has been used or disclosed, ask us to correct it, and withdraw your consent at any time on reasonable notice. We will tell you what withdrawing means: nothing more is read or shared, and you keep your account. We answer requests within 30 days. You can also complain to the Authority for Info-communications Technology Industry of Brunei Darussalam (AITI), the personal data protection authority.

Transfers. Racy Tech Inc. is established in the United States and keeps your data there. Before your data goes out of Brunei Darussalam we require Amazon Web Services, Apple and Google, by contract, to give it a standard of protection comparable to the Personal Data Protection Order, 2025. Your caregivers see your data wherever they are.

Breaches. If a breach of your data is likely to cause you significant harm, we will tell you and the AITI.

The Gambia

Legal basis. Health data is sensitive personal data under the Personal Data Protection and Privacy Act 2025, which we process with your explicit consent. Transferring your data to the United States: your consent and our contracts with our providers. Technical data is processed to run and secure the service.

Your rights. Under the Personal Data Protection and Privacy Act 2025 you have the right to access your data and receive a copy, to have it corrected or deleted, to object to its processing, to data portability, and to withdraw your consent at any time without affecting what was done before. We answer requests within 30 days. You can also complain to the Information Commission of The Gambia, which oversees personal data protection.

Transfers. Racy Tech Inc. is established in the United States and keeps your data there. Amazon Web Services, Apple and Google handle it under contracts that protect it; you consent to the transfer with the first box of the consent in the app (Personal Data Protection and Privacy Act 2025). Your caregivers see your data wherever they are.

Breaches. If a breach of your data is likely to harm you, we will report it to the Information Commission within 72 hours and tell you.

Georgia

Legal basis. Health data is a special category of personal data, which we process with your written consent, given electronically with the first box of the consent in the app. Transferring your data to the United States: your written consent, after the information on transfers in the notice in the app. Technical data is processed to run and secure the service.

Your rights. Under the Law of Georgia on Personal Data Protection you have the right to information about how your data is processed and to a copy of it, to have it corrected, updated or completed, to have its processing stopped and the data deleted or destroyed, to have its processing restricted, to data portability, and to withdraw your consent at any time without affecting what was done before. We answer within 10 working days, which can be extended by 10 more in exceptional cases. You can also complain to the State Audit Office of Georgia, which oversees personal data protection.

Transfers. Racy Tech Inc. is established in the United States and keeps your data there. Georgia does not recognise the United States as ensuring an adequate level of personal data protection, and no other safeguard under the Law on Personal Data Protection covers this transfer; there is a risk that your data has less protection there. You consent to the transfer in writing, knowing that, with the first box of the consent in the app. Your caregivers see your data wherever they are.

Breaches. If an incident affecting your data is likely to cause you substantial damage, we will tell you.

Israel

Legal basis. Your informed consent, after the notice in the app of the purposes and of who receives your data (section 11 of the Protection of Privacy Law). No law requires you to provide this information: you provide it of your own free will, and without it the service cannot work. Technical data is collected to run and secure the service.

Your rights. Under the Protection of Privacy Law, 5741-1981, you have the right to review the information about you (section 13) and to ask us to correct or delete information that is not correct, complete, clear or up to date (section 14). You can withdraw your consent at any time; this does not affect what was done before. We answer requests within 30 days. You can also complain to the Privacy Protection Authority, gov.il/privacy.

Transfers. Racy Tech Inc. is established in the United States and keeps your data there. It is transferred abroad with your consent, and Amazon Web Services, Apple and Google have undertaken in writing to protect it and not to transfer it on (Protection of Privacy (Transfer of Data to Databases Abroad) Regulations, 5761-2001). Your caregivers see your data wherever they are.

Breaches. If a serious security incident affects your data, we will report it to the Privacy Protection Authority and tell you as it directs.

Japan

Legal basis. Health data that reveals a medical condition is special care-required personal information under the APPI, which we obtain only with your consent (Art. 20(2)). Sharing your data with the caregivers in your family group is provision to third parties, which you consent to with the second box of the consent in the app (Art. 27). Keeping and processing it in the United States with our providers there is provision to third parties in a foreign country, which you consent to with the first box of the consent in the app, after the information on transfers in the notice in the app (Art. 28). Technical data, pairing, session and security, and usage statistics and crash reports are used only for the purposes described in this Privacy Policy.

Your rights. Under the Act on the Protection of Personal Information (APPI) you may ask us to disclose your retained personal data and the records of its provision to third parties (Art. 33), to correct, add to or delete it (Art. 34), and to stop using it, erase it or stop providing it to third parties (Art. 35). You may withdraw your consent at any time; this does not affect what was done before. We answer requests within 30 days. You can also consult the Personal Information Protection Commission of Japan (PPC), ppc.go.jp.

Transfers. Racy Tech Inc. is established in the United States and keeps and processes your data there, with Amazon Web Services, Apple and Google as providers. The United States has no comprehensive federal privacy law like Japan’s Act on the Protection of Personal Information (APPI): personal data there is protected by sector-specific federal laws, by state laws such as the California Consumer Privacy Act and Washington’s My Health My Data Act, and by the Federal Trade Commission, which acts against unfair or deceptive practices. Our providers handle your data under contract, only on our instructions, with security measures; Amazon Web Services and Google are certified under the EU-U.S. Data Privacy Framework. You consent to this provision to third parties in a foreign country with the first box of the consent in the app (Art. 28 APPI). Your caregivers see your data wherever they are.

Breaches. If a leak of your data is likely to harm your rights and interests, we will report it to the PPC and tell you (Art. 26 APPI).

Security measures (Art. 23 APPI). We have appointed a data protection officer, who answers for how personal data is handled. Your data is kept in Amazon Web Services data centres in the United States, which control physical access. The apps send data to our servers only over encrypted connections (HTTPS). In the apps, only you and the caregivers in your family group can see your data, after signing in; passwords and reset codes are stored only in hashed form. The legal environment of the United States, where the data is kept, is described under Transfers above.

Kyrgyzstan

Legal basis. Health data is processed with your consent; your data is transferred out of the Kyrgyz Republic with your consent. Technical data is processed to run and secure the service.

Your rights. You have the right to know whether and how your personal data is processed and to access it, to have it corrected, blocked or deleted, and to withdraw your consent at any time without affecting what was done before. We answer requests within 30 days. You can also complain to the authorised state body for personal data protection of the Kyrgyz Republic.

Transfers. Racy Tech Inc. is established in the United States and keeps your data there, with Amazon Web Services, Apple and Google as providers. Your data is transferred out of the Kyrgyz Republic with your consent, given with the first box of the consent in the app. Your caregivers see your data wherever they are.

Breaches. If a breach of your data is likely to harm you, we will tell you.

Laos

Legal basis. Health data is processed with your consent, and your data is sent out of the Lao PDR with your consent (Law on Electronic Data Protection). Technical data is processed to run and secure the service.

Your rights. Under the Law on Electronic Data Protection you have the right to access your data, to have it corrected or deleted, and to withdraw your consent at any time without affecting what was done before. We answer requests within 30 days. You can also complain to the Ministry of Technology and Communications of the Lao PDR.

Transfers. Racy Tech Inc. is established in the United States and keeps your data there, with Amazon Web Services, Apple and Google as providers. Your data is sent out of the Lao PDR with your consent, given with the first box of the consent in the app (Law on Electronic Data Protection). Your caregivers see your data wherever they are.

Breaches. If a breach of your data is likely to harm you, we will tell you.

Malawi

Legal basis. Health data is sensitive personal data under the Data Protection Act, 2024, which we process with your consent. Transferring your data to the United States: your consent, after the information on transfers in the notice in the app. Technical data is processed to run and secure the service.

Your rights. Under the Data Protection Act, 2024 you have the right to be informed about how your data is processed, to access it, to have it corrected or deleted, to object to its processing, to data portability, and to withdraw your consent at any time without affecting what was done before. We answer requests within 30 days. You can also complain to the Malawi Communications Regulatory Authority (MACRA), which is the data protection authority under the Data Protection Act, 2024.

Transfers. Racy Tech Inc. is established in the United States and keeps your data there, with Amazon Web Services, Apple and Google as providers. Malawi has not found that the United States ensures an adequate level of protection; you consent to the transfer, knowing that, with the first box of the consent in the app, and we keep a record of its basis (Data Protection Act, 2024). Your caregivers see your data wherever they are.

Breaches. If a breach of your data is likely to harm you, we will tell MACRA and you.

New Zealand

Legal basis. We collect your health information directly from you, for the purposes described in this Privacy Policy (rules 1 to 4 of the Health Information Privacy Code 2020), and disclose it to the caregivers in your family group with your authorisation (rule 11). Data your caregivers enter about you is collected from them, as the notice in the app tells you (IPP 3A). Technical data is collected because it is necessary to run and secure the service.

Your rights. Under the Privacy Act 2020 and the Health Information Privacy Code 2020 you can ask for access to the health and personal information we hold about you (IPP 6 and rule 6) and ask us to correct it (IPP 7 and rule 7); we answer within 20 working days. You can withdraw your authorisation at any time; this does not affect what was done before. You can also complain to the Privacy Commissioner, privacy.org.nz, 0800 803 909.

Transfers. Racy Tech Inc. is established in the United States and keeps your data there. Amazon Web Services, Apple and Google hold it only on our behalf, to run the service, and do not use it for their own purposes; New Zealand’s Privacy Act 2020 and the Health Information Privacy Code 2020 continue to apply to it. Your caregivers see your data wherever they are.

Breaches. If a privacy breach has caused or is likely to cause you serious harm, we will tell you and the Privacy Commissioner.

Singapore

Legal basis. Your consent, given after the notice in the app of the purposes (sections 13, 14 and 20 of the PDPA). Technical data is collected to run and secure the service, which you are told about here.

Your rights. Under the Personal Data Protection Act 2012 (PDPA) you can ask for access to your personal data and how it has been used or disclosed in the past year (section 21), ask us to correct it (section 22), and withdraw your consent at any time on reasonable notice (section 16). We will tell you what withdrawing means: nothing more is read or shared, and you keep your account. We answer requests within 30 days. You can also complain to the Personal Data Protection Commission (PDPC), pdpc.gov.sg.

Transfers. Racy Tech Inc. is established in the United States and keeps your data there. Before your data goes overseas we require Amazon Web Services, Apple and Google, by contract, to give it a standard of protection comparable to the Personal Data Protection Act 2012 (section 26 and the Personal Data Protection Regulations 2021). Your caregivers see your data wherever they are.

Breaches. If a breach of your data is likely to cause you significant harm, we will tell you and the PDPC.

Switzerland

Legal basis. Health data and your precise location are processed with your express consent (Art. 6(7) and 31 FADP); health data is sensitive personal data (Art. 5(c)). Keeping your data in the United States: your express consent (Art. 17(1)(a)), given with the first box of the consent in the app. Technical data, pairing, session and security, and usage statistics and crash reports (Google Firebase): our overriding private interest in running, securing and fixing the service (Art. 31). Data your caregivers enter about you: their and your interest in the service working, and your consent for health-related entries.

Your rights. Under the Federal Act on Data Protection (FADP) you have the right to information about whether and how we process your data and to receive a copy of it (Art. 25), to receive it or have it sent to another provider in a common electronic format (Art. 28), to have it corrected (Art. 32), to have it deleted, and to withdraw your consent at any time without affecting what was done before. We answer requests within 30 days. You can also report to the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern, edoeb.admin.ch.

Transfers. Racy Tech Inc. is established in the United States and processes your data there. Switzerland recognises the United States as providing adequate protection only for companies certified under the Swiss-U.S. Data Privacy Framework. Our providers Amazon Web Services and Google are certified; Racy Tech Inc. and Apple, which delivers notifications, are not. Your data is therefore kept and processed in the United States on the basis of your express consent (Art. 17(1)(a) FADP), which the first box of the consent in the app gives. Your caregivers see your data wherever they are.

Breaches. If a breach of your data is likely to put you at high risk, we will report it to the FDPIC and tell you where you need to protect yourself (Art. 24 FADP).

Taiwan

Legal basis. Data concerning your health is collected and used with your written consent, given electronically with the first box of the consent in the app after the notice in the app (Art. 6 of the Personal Data Protection Act). Your other data is collected and used with your consent, within the purposes described in this Privacy Policy (Arts. 19 and 20). Technical data is collected to run and secure the service.

Your rights. Under Article 3 of the Personal Data Protection Act you have the right to inquire about and review your personal data, to receive a copy of it, to supplement or correct it, to ask us to stop collecting, processing or using it, and to ask us to delete it; these rights cannot be waived or limited by contract. We answer requests to review or copy your data within 15 days and other requests within 30 days. You can withdraw your consent at any time; this does not affect what was done before. You can also complain to Taiwan’s competent authority for personal data protection.

Transfers. Racy Tech Inc. is established in the United States and keeps and processes your data there, with Amazon Web Services, Apple and Google as providers. No competent authority in Taiwan has restricted the international transfer of personal data to the United States (Art. 21 of the Personal Data Protection Act). Your caregivers see your data wherever they are.

Breaches. If your data is stolen, leaked, altered or otherwise infringed, we will tell you after looking into it (Art. 12).

Tajikistan

Legal basis. Health data is processed with your consent; your data is transferred out of Tajikistan with your consent (Law on Personal Data Protection). Technical data is processed to run and secure the service.

Your rights. Under the Law of the Republic of Tajikistan on Personal Data Protection you have the right to know whether and how your personal data is processed and to access it, to have it corrected, blocked or deleted, and to withdraw your consent at any time without affecting what was done before. We answer requests within 30 days. You can also complain to the authorised state body for personal data protection of the Republic of Tajikistan.

Transfers. Racy Tech Inc. is established in the United States and keeps your data there, with Amazon Web Services, Apple and Google as providers. Your data is transferred out of the Republic of Tajikistan with your consent, given with the first box of the consent in the app (Law on Personal Data Protection). Your caregivers see your data wherever they are.

Breaches. If a breach of your data is likely to harm you, we will tell you.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platforms, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platforms. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platforms.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on our website’s home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Platforms and this Privacy Policy to check for any changes.

Children’s Privacy

The Platforms are not directed to children under the age of thirteen (13), and Racy Tech does not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Platforms, register on the Platforms, make any purchases through the Platforms, use any of the interactive or public-comment features of the Platforms, or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at the address set forth in the Contact Information section below.

Data Protection Officer

Racy Tech has appointed Aydin Cubukcu as its Data Protection Officer. You can contact the Data Protection Officer with any question, request, or complaint about your personal information at privacy@racytech.com, or by mail at Racy Tech Inc., Attn: Data Protection Officer, 142 W 57th Street, Suite 1016, New York, NY 10019, United States.

The Data Protection Officer is also:

• Québec, Canada: the person in charge of the protection of personal information under the Act respecting the protection of personal information in the private sector (section 3.1);
• Canada: the individual accountable for our compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), and the person who answers questions about the collection, use, disclosure, or storage of personal information by our service providers outside Canada (Alberta Personal Information Protection Act, section 13.1);
• Brazil: our encarregado pelo tratamento de dados pessoais under the Lei Geral de Proteção de Dados Pessoais (Law No. 13,709/2018, article 41). Encarregado: Aydin Cubukcu, privacy@racytech.com;
• Mexico: the person who handles requests to access, rectify, cancel, or oppose the processing of your personal data (ARCO rights) and to revoke your consent, under the Ley Federal de Protección de Datos Personales en Posesión de los Particulares;
• Colombia: the person responsible for handling petitions, queries, and claims under Law 1581 of 2012 and Decree 1377 of 2013, as set out in our Política de Tratamiento de Datos Personales;
• Switzerland: our data protection advisor under the Federal Act on Data Protection (FADP, Art. 10);
• Singapore: the individual responsible for ensuring that we comply with the Personal Data Protection Act 2012 (section 11(3)), whose business contact information is given here (section 11(5));
• Brunei Darussalam: our data protection officer under the Personal Data Protection Order, 2025; and
• Israel, Japan, Australia, New Zealand, Taiwan, Georgia, Kyrgyzstan, Laos, Tajikistan, the Gambia and Malawi: the contact for requests and complaints under the laws named under “Country-Specific Information.”

Contact Information

To ask questions or comment about this Privacy Policy, contact us, or our Data Protection Officer, Aydin Cubukcu, at: privacy@racytech.com.