Privacy Policy

Data Ownership and Ethical Practices

You exclusively own your health data. Through our ethical data practices, we empower individuals globally to take control of their health, especially in underserved regions. By using Carthalis, you consent to share your data internally within our platform to enhance your experience, provide personalized insights, and recommend potentially useful resources. We're committed to protecting your privacy and won't sell or share your personal health data with third parties without your explicit consent for each specific use.

Information We Collect

We collect several types of information to provide and improve our services:

• Account Information: When you create an account, we collect your email address, name, and password.
• Profile Information: Information you provide, including preferences and location.
• Usage Data: Information about how you interact with our platform, including features used and time spent.
• Health Data: Health information you provide when filling your health profile, when using our tools, such as symptoms, images, or test results. This information is separated from all other data/identifiers and encrypted for protection

Product Analytics

After you accept our Terms and Privacy Policy during onboarding, we use PostHog to understand how the authenticated product is used and improve it. PostHog receives a pseudonymous account identifier and a limited, allowlisted set of product events, such as feature use and completion of a workflow.

We do not send health data, measurements, form answers, free text, email addresses, access tokens, or OAuth callback URLs to PostHog. Session recording and automatic capture are disabled. When you delete your account, its active analytics identity is cleared alongside your account session.

Google Health Data Integrations

If you choose to connect Google Health, Carthalis requests read-only scopes for activity and fitness, health metrics and measurements, sleep, and profile identity. We use this data to import and display your own wellness metrics inside your account and to power analytics features you explicitly use.

• Scope category: Read-only access for activity, health metrics, sleep, and profile identity.
• Use limitation: Data is used to provide product features you request and to maintain integration sync reliability.
• Retention: Imported health records follow this policy's retention and deletion controls, including account deletion workflows.
• Disconnect and revoke: When you disconnect Google Health in-app, Carthalis revokes provider tokens and removes the local integration link.

We do not sell your Google Health data, identifiable or not. We only process it under the same privacy and security commitments described in this policy.

Oura Data Integrations

If you choose to connect Oura, Carthalis requests OAuth scopes limited to the data we import: daily summaries (sleep, readiness, activity, stress), personal profile fields used for height/weight, workouts, SpO₂, and heart-health metrics (VO₂ max and vascular age estimates). We do not request email, tags, sessions, dense continuous heart-rate samples, or ring configuration.

• Scopes requested: daily, personal, workout, spo2, stress, heart_health.
• Use limitation: Imported data powers your Digital Twin and the other features you use; we do not sell your Oura data, identifiable or not.
• Disconnect and revoke: Disconnecting Oura in-app revokes the Oura access token and removes the local integration link.

Face Data and Camera Use

When you choose to use features that analyze your face, such as facial age estimation or rPPG-based measurements, we process images and/or video from your device's camera solely to provide those features.

Important: Our rPPG (remote photoplethysmography) feature is a research tool only and is not a medical device. It is not intended for medical diagnosis, treatment, or monitoring of any medical condition. The measurements provided are for research and informational purposes only and should not be used to make medical decisions.

By default, this face data is processed in real time and is immediately destroyed once the analysis is complete. We do not retain this face data or use it for any other purpose without your explicit consent.

If in the future we offer optional features that store face age or other face-derived data (for example, to create a profile picture, or personalized visuals), we will only do so with your explicit consent. In that case, you will be able to withdraw your consent and delete your stored face data at any time, and we will retain such face data for no longer than two years from the date of collection unless you request deletion earlier. The data will be stored in a secure, encrypted database, separate from your other data, and will not be shared with third parties without your explicit consent.

How We Use Your Information

We use your information for the following purposes:

• To provide you with health insights and resources
• To provide and maintain our services
• To personalize your experience with our AI health tools
• To improve our platform and develop new features
• To conduct our own research to better help the people who use Carthalis
• To communicate with you about updates or changes to our services
• To provide customer support
• To detect and prevent fraudulent or unauthorized activity
• To advance responsible innovation in health AI technologies

Data Security

We lock your data down with strong security tools like encryption and strict access checks. Your name and contact details live in a different place from your health information.

When we store your encrypted health details, we also replace your identity with a random code. The list that matches this code to you is kept in a separate, well-protected spot. That way, even if in some extreme scenario someone saw the health data, they wouldn't know it belongs to you, and vice versa if someone saw your identity, they wouldn't see your health data.

Data Sharing

We will never sell your health data, including de-identified data. We may share your information only in the following limited circumstances:

• With Your Consent: We will only share your personal health data with third parties when you have explicitly consented to such sharing.
• Service Providers: We may share information with trusted service providers who help us operate our platform, but only as necessary to provide our services.
• Legal Requirements: We may disclose information if required by law, regulation, or legal process.

Programs you can choose to join. Your health data can be valuable to researchers and organizations. We may show you programs — such as research studies or reward programs — that you can choose to join. Before you join, we will tell you what data would be shared, with whom, for what purpose and for how long; what you would receive, if anything; and whether Carthalis is paid in connection with the program and how. If Carthalis keeps part of a payment made for your data, we will show you how much. Whether we are paid never changes what is shared: only what you agreed to. You can withdraw at any time, and no new data will be shared after you do.

Recommendations. When we suggest a product or service, the company behind it receives none of your health data unless you choose to share it. Sponsored suggestions are clearly labelled.

Your Privacy Rights

You have several rights regarding your personal information:

• Access: You can request access to the personal information we hold about you.
• Correction: You can request that we correct inaccurate or incomplete information.
• Deletion: You can request that we delete your personal information.
• Restriction: You can request that we restrict the processing of your information.
• Data Portability: You can request a copy of your data in a structured, commonly used format.
• Objection: You can object to our processing of your personal information.

Data Deletion and Account Management

You are in full control of your data. You can delete individual health entries or profile fields at any time directly from your account dashboard. If you prefer to remove everything, you may permanently delete your account under your profile → Preference Settings. Deleting your account will initiate a cascading deletion of all personal data associated with that account across our systems within 30 days.

Once an item—or your entire account—is deleted, it is removed from our active databases and will no longer be used for any purpose. Back-ups are systematically purged in accordance with our retention schedule to ensure complete erasure.

If Carthalis Changes Hands or Closes

Your health data belongs to you. It is not an asset of Carthalis and will never be sold — on its own, as part of a database, or in any sale, merger, financing, bankruptcy or wind-up of our company. This covers identifiable, pseudonymized, de-identified and derived health data.

If Carthalis is acquired or merges with another organization, your data will only move together with the Carthalis service, to an organization that continues to provide it and that has agreed in writing to keep every commitment in this policy. If no such agreement is made, your data will be deleted rather than transferred. We will tell you at least 30 days before your data moves, so you can download or delete it first. Prospective buyers never receive identifiable health data during negotiations.

If Carthalis shuts down,we will give you at least 60 days' notice so you can download your data. If no successor takes over under the conditions above, we will delete all personal and health data within 30 days after the service ends, and from backups within 90 days.

If Carthalis becomes insolvent, this policy instructs any trustee or receiver that user health data is to be deleted, not sold. A court can sometimes order otherwise; if that ever happens, we will oppose any sale of your health data.

Cookies and Tracking

We use cookies and similar tracking technologies to enhance your experience on our platform. These technologies help us understand how you use our services, remember your preferences, and improve our offerings. You can control cookie settings through your browser preferences.

Children's Privacy

Our services are not intended for children under the age of 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately.

Mission and Ethics

Our mission is to democratize access to state-of-the-art AI health tools by creating a unified platform that hosts a variety of health, wellness, and mental health models. We empower individuals globally to take control of their health, especially in underserved regions, through ethical data practices and transparent policies. Our ethical approach to data is foundational to everything we do.

Changes to This Privacy Policy

We may update this policy. We will give you at least 30 days' notice of any material change by email and in the app. A change that reduces your protection will never apply to data we already hold unless you agree to it; if you don't, your existing data stays under the terms it was collected under, or you can delete it. Changes that only increase your protection may take effect right away.

Governing Law

This Privacy Policy is governed by the laws of Canada. Any disputes arising under this policy shall be subject to the exclusive jurisdiction of the courts located within Canada.

Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us.

For more detailed information about our platform, please visit our documentation.