Privacy Policy

Pontosense Inc. and its affiliates ("Pontosense", "we", "us", or "our") are committed to protecting the privacy of our customers and users ("you" or "your"). This Privacy Policy outlines how we collect, use, disclose, store, and protect your personal information in connection with the use of our products and services. This Privacy Policy applies when you interact with our website (the "Website") or use any of our Products as defined below.

This Privacy Policy is available at: https://www.pontosense.com/privacy-policy.

1. Purpose and scope

This Privacy Policy applies to all Pontosense solutions and services (collectively, the "Products"), including:

• The Pontosense Website
• Silver Shield (the "Hardware")
• Pontosense Care App and Portal (the "Platform")
• Technical support, integration, and engineering services (the "Services")

Client-Managed Programs and Third Parties. In many cases, our Products are made available through a client (such as a care provider, operator, or partner organization, hereto referred to as "Client"). In those cases, the client controls how the Product is configured and how resident or patient information is used within the program. Any data collected by the Client for the Product may be transferred and processed by Pontosense to provide the Product access and features. This Privacy Policy describes Pontosense's practices as a service provider. The client's own privacy practices may also apply to its program operations, onboarding, and communications.

HIPAA/PHI Notice (Business Associate Role). In some deployments, Pontosense may process information on behalf of a healthcare provider, health plan, or another regulated organization and that information may constitute Protected Health Information ("PHI") under HIPAA. In those deployments, Pontosense acts as a Business Associate (or subcontractor Business Associate) and processes PHI solely on the customer's instructions and as permitted by applicable agreements (including Business Associate Agreements). Individuals should direct HIPAA privacy requests (e.g., access, amendment, restrictions, accounting) to the customer that administers the program.

If you access our Products or Services from outside Canada, you acknowledge and agree that your personal data may be transferred to, processed in, and stored in Canada, the United Kingdom, the European Union or other jurisdictions where Pontosense or its service providers operate as applicable. Local data protection laws in these jurisdictions may differ from those in your country of residence.

2. Information we collect

We may collect the following categories of personal information ("Personal Information") depending on your interactions with us:

a) When you use our Website:

• Device identifiers (via cookies, pixels, analytics tools, log files, etc.)
• Usage data (browser type, access time, pages viewed, access location, IP address)
• Form data, as listed below in Section 2(b)

b) When you contact us through our Website:

• Full name
• Email Address
• Phone number
• Company name and position (if applicable)
• Country
• Any additional information you voluntarily provide

c) When you use the Products:

• Hardware Status and Performance Data
  • Firmware version
  • Product activation date and time
  • Power status
  • Connectivity status (e.g., RSSI)
  • Angle of installation
  • Diagnostic or error codes
• Network and Hardware Identifiers
  • Wi-Fi network credentials, such as network name (SSID)
  • Hardware serial number
• User Account and Authentication Information
  • Username, email address, password, and session tokens
  • Optional personal data provided for enhanced services, such as names, phone numbers, addresses, and relationship details
• Location and Configuration Data
  • Home and room identifiers as configured by the Client or End User (e.g., room names, floor levels)
  • Room zones and locations as configured by the Client or End User (e.g., bed zones, restricted areas)
  • Installation settings, including installation height and room calibration parameters
  • (Optional) Groups – User- or Client-defined tags or labels applied to residents, devices, users, or locations within the Platform, as configured and inputted by the Client or end user. The content of Group tags is determined entirely by the Client or end user and may include organizational, categorical, or descriptive information. Pontosense does not define, control, or independently verify the content of Group tags.
• Sensor and Event Data
  • Occupancy status, including timestamps (e.g., whether a room or home is currently occupied or vacant)
  • User registration status
  • Zone occupancy – (bed, couch, shower, toilet, doors), including time stamps
  • Zone exit and or entry alerts – bed, couch, toilet, door entry or exit notifications, including timestamps
  • Sensor-generated event data, including timestamps for motion, location, and fall detection
  • Breathing rate trends
  • (Optional) Phone Number, emergency contact number
  • (Optional) Resident data – pets, mobility aids, address, name
  • Review status of event data, indicating whether an event has been acknowledged and reviewed
• User-Provided Input
  • Any additional information you voluntarily submit through the Platform (e.g., in-app notes, feedback)
• Customer Content
  • Information submitted to or processed within the Platform at the direction of a customer (including resident/patient-related information).

3. Data security

We use physical, organizational, and technological safeguards to protect your Personal Information against unauthorized access, use, or disclosure. However, no system is completely secure. You are responsible for maintaining the security of your own login, devices, and networks when interacting with our Products.

If we become aware of a security incident affecting Client content (including PHI where applicable), we will notify the Client in accordance with our contractual obligations and applicable laws.

4. How we use your information

a) Website interactions:

• Analyze usage patterns and performance
• Conduct market research
• Improve website functionality and user experience

b) Customer inquiries:

• Respond to your questions and requests
• Provide customized product or service information
• Customize and improve your experience

c) Product use:

• Enable functionality of the Products
• Provide technical and customer support
• Fulfill contractual obligations
• Combine with offline interactions (e.g., email or phone support)
• Improvements and analysis of the Products

5. Data retention

We retain Personal Information only as long as necessary to fulfill the purposes for which it was collected, or as required by law. Retention periods may vary depending on your jurisdiction and are determined based on:

• Legal obligations
• Contractual requirements
• Business needs
• Relevant time limitations for legal claims

For Client content (including PHI where applicable), retention and deletion are governed by our Client agreements and the Client instructions, subject to legal requirements, backups, and audit/security logging.

6. Disclosure of personal information

Pontosense does not sell or rent your Personal Information. We may disclose your information under the following limited circumstances:

• Legal Obligations: To apply with applicable laws, court orders, or legal proceedings
• Service Providers: To third parties who provide services on our behalf (e.g. IT providers, analytics tools, cloud providers, etc.) under binding confidentiality terms
• Protection of Rights: To enforce our policies or protect the safety, rights, and property of Pontosense or others.

We ensure that third-party vendors use your Personal Information solely for the purpose of providing the contracted services.

7. Your rights

You have certain rights under data protection laws, including:

• Right of Access: Request a copy of the Personal Information we hold about you
• Right to Rectification: Request corrections to inaccurate or incomplete data
• Right to Erasure: Request deletion of your Personal Information under specific conditions
• Right to Withdraw Consent: Withdraw previously given consent at any time
• Right to Restrict Cookies: Control cookie usage through your browser settings

We ensure that third-party vendors use your Personal Information solely for the purpose of providing the contracted services.

Where we process PHI, we disclose PHI only (i) as permitted by our agreements with the Client (including applicable BAAs), (ii) to our authorized subcontractors who are bound by appropriate confidentiality and security obligations (and where applicable, Business Associate terms), or (iii) as required by law.

If you are an individual whose information is processed as part of a customer's HIPAA-regulated program, requests to access, amend, restrict, or receive an accounting of disclosures of PHI should be directed to the Client administering the program. We support our customers in responding to such requests as required by applicable agreements and law.

8. Children's privacy

Pontosense Products are not intended for children under the age of 18. We do not knowingly collect Personal Information from minors. If we discover that such data has been collected inadvertently, we will delete it. If you believe we may have collected information about a minor, please contact us at support@pontosense.com.

9. Changes to this Privacy Policy

We may update this Privacy Policy from time to time without notice. By continuing to use our Products after any changes, you accept the revised Privacy Policy.

Please review this page periodically to stay informed of how we protect your data.

Last Updated: April 13, 2026

10. Contact us

If you have any questions, concerns, or wish to exercise your privacy rights, please contact us at:

Email: privacy@pontosense.com

Website: https://www.pontosense.com