Privacy Policy

CircleCare (“we,” “us,” or “our”) is operated by Maple Ridge LLC. This Privacy Policy explains how we collect, use, share, and protect your personal information when you use the CircleCare mobile application, the CircleCare web companion at my.circlecare.app, and related services (the “Service”).

CircleCare is a family care coordination app that helps families manage medications, appointments, and emergency information for aging parents and loved ones. Because of the nature of our Service, we collect and process health-related information, which we treat with the highest level of care.

Our role and HIPAA: CircleCare is a consumer app for families — not a healthcare provider, health plan, or clearinghouse. We are not a “covered entity” or “business associate” under HIPAA, so the health information you choose to store (such as medications, conditions, and appointments) is not “Protected Health Information (PHI)” regulated by HIPAA, and we do not sign Business Associate Agreements. We still treat this information as sensitive personal data and protect it accordingly — encrypted in transit and at rest, access limited to your care circle, and never sold (see “How We Protect Your Information” below).

1. Information We Collect

Information You Provide

Account Information

• Email address
• First and last name
• Password (encrypted, managed by our authentication provider)
• Timezone and language preference
• App preferences — notification settings, quiet hours (the times you choose not to be notified), 12- or 24-hour clock, and your preferred weight and glucose units
• The date you accepted our Terms of Service

Care Circle Information

• Circle name (e.g., “Mom — Smith Family”)
• Care recipient's name and date of birth
• Circle member roles (owner, caregiver, care recipient)

Health and Medical Information

• Medication names, dosages, and schedules
• Medication confirmation status (taken, skipped, or missed)
• Medication details you add or scan — prescription number, prescribing doctor, pharmacy name and phone, refill counts, and the date a medication was discontinued
• Text captured by on-device scanning of prescription labels and insurance cards
• Whether a medication, appointment, or task was added by typing it in the form, by scanning a photo, or by voice, so that this can be shown to your care circle
• Health measurements you record — blood pressure, heart rate, blood glucose, and weight, with the date and time
• Medical conditions and allergies
• Blood type
• Insurance information (carrier, policy number, group number)
• Doctor information (name, specialty, phone, address)
• Advance directives and DNR status
• Appointment and task details

Notes and Daily Log

• Daily care notes about the care recipient, including the mood you select and the categories you tag (such as meals or sleep)
• Notes attached to an appointment, task, or medication dose
• Notes attached to a health measurement

Documents You Upload

• Files you add to a circle — medical records, prescriptions, insurance documents, and legal documents, as PDFs or images
• The label, category, and any note you give a document

Emergency Contact Information

• Names, phone numbers, and relationships of emergency contacts
• Name and phone number of a power of attorney, if you add one

Photos and Images

• Care recipient photos
• Medication reference photos
• Insurance card photos
• Photos of prescription labels you scan to fill in medication details

Communication Data

• Messages sent to the AI Care Assistant (text and voice transcripts)

Information Collected Automatically

Device Information

• Device timezone and language settings
• Push notification token (for delivering notifications)
• Device platform (iOS or Android) and app version
• IP address — processed transiently to rate-limit abusive requests and protect accounts from automated attacks. We do not use it for advertising, and we do not sell it. The IP address itself is retained only for the few minutes a rate-limit window lasts.
• Approximate location (country, and in some cases city) — derived from your IP address by our analytics and subscription providers. Our analytics provider records it alongside usage events so we can understand where the Service is used. Our subscription provider uses it, at the moment a payment page is opened, to decide which currency to show you. We do not use it to build advertising profiles, and it is never combined with your care circle content.

Usage Information

• Feature usage patterns (e.g., which screens you visit, actions you take)
• App events (e.g., medication confirmed, circle created)
• Error reports

Subscription Information

• Your plan (free or premium), trial status, and the purchase identifier the app store gives us for your subscription

If You Import a Calendar

• The identifier of each imported event and which calendar it came from, so the same event is not imported twice

We do NOT collect:

• Precise location data
• Contact lists or address books
• Browsing history
• Advertising identifiers

2. How We Use Your Information

We use your information to:

• Provide the Service — Create and manage care circles, track medications, schedule appointments, store emergency information
• Send Notifications — Medication reminders, confirmation alerts to family members, appointment reminders, and circle activity updates
• Process Subscriptions — Manage your subscription status and enforce plan limits
• Send Emails — Account verification, circle invitations, password resets, and optional email digests summarizing circle activity
• Power the AI Assistant — Provide context-aware caregiving guidance based on your circle's medications, appointments, and activity (premium feature)
• Improve the Service — Understand how features are used, identify bugs, and improve the user experience
• Ensure Security — Detect fraud, enforce rate limits, and protect accounts

We do not use your health information for advertising, profiling, or any purpose unrelated to providing the Service.

3. How We Share Your Information

We share your information only with the following service providers, and only as necessary to operate the Service:

On iPhone, when you type an address into the doctor office address or appointment location field, the text you type is sent to Apple Maps to suggest matching addresses; we do not send your location or any account or care circle information with it.

We do NOT:

• Sell your personal information to anyone
• Share your health data with advertisers
• Use your data for targeted advertising
• Provide your information to data brokers

Within Your Care Circle

When you join a care circle, other members of that circle can see:

• Your name and role in the circle
• Medication confirmations and activity (e.g., “Margaret took Atorvastatin at 8:03 AM”)
• Tasks and appointments you create or complete
• Activity feed entries related to your actions

This sharing is fundamental to how CircleCare works — it enables families to coordinate care together.

If you leave or are removed from a circle, your name stays on the care records you contributed to in that circle. Deleting your account replaces it with “Deleted User”.

4. How We Protect Your Information

• Encryption in Transit — All data transmitted between your device and our servers uses HTTPS/TLS encryption
• Encryption at Rest — Data stored in our database is encrypted at rest
• Row-Level Security — Database access policies ensure you can only access circles you belong to
• Secure Credential Storage — If you enable biometric login (Face ID / Touch ID), your credentials are stored in your device's secure enclave (iOS Keychain / Android Keystore) and never transmitted to our servers
• Hashed Secrets — Invitation codes and verification codes are hashed before storage using bcrypt
• Rate Limiting — Authentication endpoints are rate-limited to prevent brute-force attacks
• Biometric Data — We never collect, store, or transmit your biometric data (fingerprint, face scan). Biometric authentication is handled entirely by your device's operating system

5. Data Retention

• Active Account — We retain your data for as long as your account is active
• Subscription Expiration — If your subscription ends, your account returns to the free plan. Nothing is deleted. If you own more than one circle, you choose which one stays fully editable; your other circles, and any caregivers beyond the free plan's limit, become read-only. Full access is restored if you resubscribe
• Account Deletion — You can delete your account at any time from the Profile screen in the app. Upon deletion, we remove your account and personal data from our systems. Some data may persist in backups for up to 30 days. Care records and files you added to circles owned by someone else stay in those circles (see Photos & Documents)
• Circle Deletion — Circles deleted by their owner are permanently removed from our systems within 30 days
• Photos & Documents — Medication photos and documents you upload are stored separately from our database and are not included in database backups. When you delete your account, the files in circles you own are deleted immediately. Files you added to a circle someone else owns stay in that circle as part of its shared care record, like its activity feed entries. While you can still edit that circle, you can delete the documents you uploaded and remove medication photos; the circle's owner can delete them too. When an owner deletes a circle, its files are deleted along with the rest of the circle (see Circle Deletion). Once a file is deleted, no backup copy is kept
• Activity Logs — Circle activity feed entries are retained for the life of the circle, as they serve as a shared care record for all circle members
• IP Address — Retained only for the few minutes a rate-limit window lasts, then deleted automatically. It is not stored in our application logs, which record a salted, pseudonymous token in its place
• Email Records — We keep a record of each email we sent you (type and date, not content) for 12 months. A record of any unsubscribe request is kept for as long as your account exists so we can honour it
• Approximate Location — The country (and in some cases city) derived from your IP address is retained by our analytics provider alongside the usage event it describes, for as long as that event is retained. The IP address it was derived from is not kept

6. Your Rights

Depending on where you live, you may have the following rights regarding your personal information:

All Users

• Access — Request a copy of the personal information we hold about you
• Correction — Update or correct inaccurate information via the app or by contacting us
• Deletion — Delete your account and personal data from the Profile screen, or by contacting us
• Portability — Request your data in a portable format

United States (California — CCPA / CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

• Right to Know — Request the categories and specific pieces of personal information we have collected about you, the sources, the business purpose for collecting it, and the categories of third parties with whom we share it
• Right to Delete — Request deletion of the personal information we have collected from you, subject to certain legal exceptions
• Right to Correct — Request correction of inaccurate personal information
• Right to Opt Out of Sale or Sharing — We do not sell or share your personal information, so there is nothing to opt out of. We have not sold or shared personal information in the preceding 12 months
• Right to Limit Use of Sensitive Personal Information — We use the health information you provide solely to operate the Service, never for advertising or profiling
• Right to Non-Discrimination — We will not discriminate against you for exercising any of these rights

To exercise any of these rights, contact us at privacy@circlecare.app. We will verify your request using the email address associated with your account, and you may use an authorized agent to submit a request on your behalf.

Residents of other U.S. states (such as Virginia, Colorado, Connecticut, and Utah) may have similar rights, which we honor on request.

European Economic Area, United Kingdom, and Switzerland (GDPR)

• Legal Basis — We process your health data based on your explicit consent (GDPR Article 9(2)(a)). We process account data based on contractual necessity (Article 6(1)(b)) and legitimate interests (Article 6(1)(f)) for security and service improvement
• Withdraw Consent — You may withdraw consent at any time. For analytics, use the Usage analytics switch under Profile → Privacy in the app, or the Cookie Preferences link on this website. For health data, delete your account. Withdrawal does not affect the lawfulness of processing before withdrawal
• Restriction — Request that we restrict processing of your data in certain circumstances
• Objection — Object to processing based on legitimate interests
• Complaint — Lodge a complaint with your local data protection authority
• Data Transfers — Your data is stored in the United States. We rely on Standard Contractual Clauses (SCCs) as approved by the European Commission to ensure adequate protection for international data transfers. Our database provider (Supabase) has executed a Data Processing Agreement that includes these safeguards. Our analytics provider (PostHog) has also executed a Data Processing Agreement that incorporates these clauses

Canada (PIPEDA)

• Consent — We collect and use your personal information with your knowledge and consent
• Access and Correction — You may request access to and correction of your personal information
• Withdrawal — You may withdraw consent at any time, subject to legal or contractual restrictions
• Complaint — You may file a complaint with the Office of the Privacy Commissioner of Canada

Australia (Privacy Act)

• Access and Correction — You may request access to and correction of your personal information under Australian Privacy Principles (APPs)
• Health Information — We treat medication, medical, and emergency data as “health information” under the Privacy Act and apply enhanced protections
• Complaint — You may file a complaint with the Office of the Australian Information Commissioner (OAIC)
• Data Transfers — Your data is stored in the United States. By using the Service, you consent to this transfer. We take reasonable steps to ensure our overseas service providers comply with the APPs

Mexico (LFPDPPP)

• ARCO Rights — You have the right to Access, Rectify, Cancel, and Oppose the processing of your personal data
• Consent — We obtain your consent for the collection and processing of sensitive personal data (health information)
• Complaint — You may file a complaint with the Instituto Nacional de Transparencia, Acceso a la Información y Protección de Datos Personales (INAI)

7. Children's Privacy

CircleCare is intended for adults and is not directed to anyone under 18. We do not knowingly collect personal information from anyone under 18. If you believe someone under 18 has provided us with personal information, please contact us and we will delete it.

Note: Care recipients (e.g., aging parents) whose information is entered by caregivers are not “users” of the Service. Their information is entered and managed by authorized circle members.

8. Biometric Authentication

If you choose to enable biometric login (Face ID, Touch ID, or fingerprint), your email and password are stored in your device's secure enclave — a hardware-protected area of your device that is separate from our servers. We never receive, transmit, or store your biometric data. The biometric check is performed entirely by your device's operating system. You can disable biometric login at any time in the app settings.

9. AI Care Assistant

The AI Care Assistant is an optional premium feature that provides caregiving guidance. When you use it:

• The messages you type — including recent messages in the same conversation — are sent to OpenAI to interpret your request, and for general caregiving questions OpenAI writes the reply. We do not send your stored medications, appointments, medical conditions, or other health records to OpenAI; answers about your circle's data are assembled on our own servers
• Voice input is transcribed on your device before being sent — we do not transmit raw audio
• Conversations are not used to train AI models
• The AI assistant does not provide medical advice and is not a substitute for professional healthcare guidance

Adding by Voice

In the mobile app you can add a medication, task, or appointment by speaking. When you do:

• Your phone turns what you say into text on the device, using its built-in speech recognition or, on supported iPhones, Apple's on-device model. The app then fills in the form for you to review
• Your voice recording and the words you said are not sent to CircleCare, OpenAI, or anyone else. Only the details you choose to save are stored, the same as an entry you type
• On iPhone, Apple's permission prompt for speech recognition may say that speech data is sent to Apple. CircleCare asks iOS to keep recognition on your phone, and voice add is not offered on phones that cannot do so

10. Cookies and Similar Technologies

Our website uses a minimal set of cookies and similar browser-storage technologies (such as local storage):

• Strictly Necessary — We store your cookie-consent choice and language preference in your browser. These are essential for the site to function and remember your settings, and do not require consent.
• Analytics (anonymous by default) — Our website collects anonymous, session-only usage data — which pages are viewed, and which sections and controls are used — to help us understand how visitors use the site. This collection uses no cookies and no persistent identifier, and it cannot be linked to you. It runs until you decline. If you click “Accept” on our cookie banner, we additionally store a random identifier in your browser so we can recognize your visits across sessions. If you click “Decline,” or later change your mind using “Cookie Preferences,” analytics is turned off entirely for your browser: nothing further is collected and any identifier is removed. We also honor the Global Privacy Control and Do Not Track browser signals as a decline. We do not use advertising cookies, cross-site trackers, or session recording, and this data is never linked to your name, email, or account.

You can change your decision at any time using the “Cookie Preferences” link in our website footer, or by clearing your browser's site data. Declining, or withdrawing consent after accepting, stops all analytics collection on our website for that browser.

Analytics in the CircleCare apps

The sections above describe our marketing website. The mobile app and the web companion at my.circlecare.app handle analytics separately, and the defaults differ:

• Mobile app — When you create an account you are asked, in a separate optional checkbox, whether to share usage data linked to your account. It is unticked by default, and signing up does not depend on it. Accounts created before this choice existed remain enabled and can turn it off at any time in Profile → Privacy → Usage analytics.
• Web companion (my.circlecare.app) — Analytics is off unless you turn it on in Profile → Privacy.

We also keep an operational record of which of our own emails we sent you (for example the welcome email or a getting-started tip) — the type of email and the date, never its content or your address. If usage analytics is on for your account, we additionally record whether you opened the app from a link in one of those emails, subject to the same analytics choice described above.

Your choice is recorded on your CircleCare account, not only on the device or browser where you made it. Changing it in the app or on the web companion updates the same account record, and because the account holds the decision both clients apply it: the mobile app when you sign in, when it starts and restores your session, and when you return to it after it has been in the background, and the web companion when a page loads and when you sign in. Reinstalling the app, signing in on a different phone, or opening the web companion in a different browser no longer loses your setting and no longer puts you back on the default. A change takes effect at those points rather than instantly — a decision made in one place applies in another the next time that app or browser loads it.

That record is part of your personal information. When you request a copy of your data, it includes the date you granted analytics consent and the date you withdrew it.

When analytics is off, we still collect a limited amount of anonymous, session-only usage and crash data: which screens are used, which actions succeed or fail, and automatic crash reports. In this mode the analytics client runs under a random identifier that is held only in memory — it is never written to your device and is discarded when the app or browser tab closes, so one session cannot be joined to the next. Your account ID and email address are never attached, your IP address is not sent, and identifiers that could point to a person or household (such as account, circle, or event IDs) are removed from each event before it is sent. Turning analytics off still deletes the identified usage data previously collected from you and stops anything already queued on your device from being sent; data collected after that point is simply not linked to you. This anonymous collection cannot be switched off inside the app. It exists so we can see when the app fails.

App analytics never includes health readings, medication names or dose amounts, condition or allergy details, care notes, messages, or document contents. It records which screens are used and which actions succeed or fail, plus a few details about those actions: the type of reading logged (such as blood pressure), whether a dose was marked taken, late, or skipped, a medication's schedule pattern (such as twice daily) and how long it was active, a document's category, which emergency information sections were changed, and the general topic of a question to the assistant. Events are linked to your account ID, your care circle's ID, and basic device and app details. Neither the mobile app nor the web companion attaches the name or email address on your account. Earlier versions did — the mobile app until June 2026 and the web companion until September 2026. We have removed them from analytics profiles; analytics events recorded before those dates may still include them. We do not use session recording in the apps.

11. Push Notifications

We use Expo's push notification service to deliver medication reminders, family activity alerts, and other notifications. Your device's push token is stored on our servers and shared with Expo solely for the purpose of delivering notifications. You can disable notifications at any time through your device settings or the app's notification preferences.

12. Subscription and Payments

If you subscribe inside the mobile app, your payment is processed entirely by Apple (App Store) or Google (Google Play). We receive only your subscription status (active, expired, trial) through RevenueCat, which acts as an intermediary with the app stores.

If you subscribe on our website, checkout is handled by Stripe. Stripe collects your payment method details and billing address directly and processes them as an independent controller under its own privacy policy. We receive your subscription status, not your card number.

In neither case do we collect or store your credit card number.

13. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the app or by email before the changes take effect. Your continued use of the Service after changes are posted constitutes your acceptance of the updated policy.

14. Contact Us

If you have questions about this Privacy Policy or want to exercise your rights, contact us at:

Maple Ridge LLC
5900 Balcones Drive, Suite 100
Austin, TX 78731
Email: privacy@circlecare.app

For GDPR inquiries, you may also contact your local supervisory authority.
For PIPEDA inquiries, contact the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.
For Australian Privacy Act inquiries, contact the OAIC at www.oaic.gov.au.
For Mexican data protection inquiries, contact INAI at www.inai.org.mx.

15. Other Languages

This Privacy Policy is also available in other languages. The translations are provided for convenience:

• Español
• Français
• Français (Canada)
• Deutsch
• Italiano
• Português (Brasil)
• Português (Portugal)