Consumer Health Data Privacy Policy
Version 1.0. Effective October 24, 2026 for new accounts, and November 8, 2026 for accounts created before October 24, 2026.
This policy describes how ECQO Holdings Inc. ("ECQO," "we," "us," or "our") handles consumer health data, meaning personal information that identifies you or could reasonably be linked to you and that relates to your physical or mental health. It applies to residents of Washington, Nevada, and Connecticut, and to anyone whose consumer health data is collected in those states. We apply the same protections to all users. This policy supplements our Privacy Policy.
1. Consumer Health Data We Collect
- Conversation content with the companion, to the extent it reveals information about your health, wellbeing, or emotions.
- Check-in responses about your wellbeing.
- Safety records: automated safety classifications and the outcome of any human review.
- Wellbeing personalization: preferences and patterns the Services use to tailor conversations.
- Voice audio you send, which may reveal health information.
- Biometric data, only if you separately consent to voice cloning.
We do not collect precise location through our companions. If a future product needs location, it will tell you and ask for your consent first.
2. Sources
We collect consumer health data directly from you when you use the Services, and we create some of it, such as safety records and personalization, from your use of the Services.
3. Why We Collect and Use It
We collect and use consumer health data only with your consent, or as necessary to provide the Services you ask for, in order to:
- provide and personalize your companion conversations;
- operate our safety protocol, including crisis resources and human review;
- keep the Services secure; and
- create de-identified information, which no longer identifies you, to improve the Services, update our curricula and member library, and conduct research.
We ask for your consent to collect consumer health data in a separate step at signup, apart from accepting our Terms. You can withdraw that consent at any time. If you withdraw it, we can no longer provide companion conversations, but crisis resources remain available.
4. Sharing
We share consumer health data only:
- With processors that operate the Services for us under contracts limiting their use of the data to our instructions: Amazon Web Services, Anthropic, ElevenLabs, Stripe, and Cloudflare.
- With your separate consent for any other sharing, which we will ask for in a separate step that names who receives the data and why.
- As required or permitted by law, including to prevent serious and imminent harm.
Organizations that offer ECQO to their people receive only de-identified, aggregated reporting. ECQO Holdings Inc. has no affiliates with which it shares consumer health data.
5. No Sale and No Geofencing
We do not sell consumer health data, and we will not without your signed, valid authorization as the law requires. We do not use geofences around health care facilities to identify, track, or send messages to anyone.
6. Your Rights
You have the right to:
- confirm whether we collect, share, or sell your consumer health data;
- access your consumer health data, including a list of all third parties and affiliates with which we shared or sold it and their contact information;
- withdraw consent to collection or sharing;
- delete your consumer health data, and have us tell our processors and any third parties who received it to delete it too; and
- not be discriminated against for using these rights.
How to make a request. Use the privacy settings in your account, email [email protected], or call +1 888-982-9423. We verify your identity, respond within 45 days, and may extend once by 45 days with notice. Requests are free up to twice a year.
Appeals. If we decline your request, reply to our decision with the word "Appeal." We will respond in writing within 45 days, explaining what we did and why. If you disagree, you may contact your state attorney general: in Washington at atg.wa.gov, in Nevada at ag.nv.gov, and in Connecticut at portal.ct.gov/ag.
7. Security and Access
We limit access to consumer health data to the people who need it to provide the Services or operate our safety protocol, protect it with encryption and logged access, and review our safeguards regularly.
8. Changes
We will notify you of material changes to this policy by email or in the Services before they take effect, and we will ask for your consent again before collecting or sharing consumer health data for a new purpose.
9. Contact
ECQO Holdings Inc. Attn: Privacy 5725 S Valley View Blvd, Ste 5, PMB 338981 Las Vegas, NV 89118 [email protected] +1 888-982-9423
© 2026 ECQO Holdings Inc. All rights reserved.