Privacy Policy

Version 2.0. Effective October 24, 2026 for new accounts, and November 8, 2026 for accounts created before October 24, 2026.

This Privacy Policy explains how ECQO Holdings Inc. ("ECQO," "we," "us," or "our") collects, uses, shares, and protects personal information across every ECQO companion and white-label edition, our courses, certifications, simulation labs, member libraries, marketplace, and websites (the "Services").

Information about your health and wellbeing is also covered by our Consumer Health Data Privacy Policy, which applies alongside this one.

1. The Short Version

We do not sell your personal information, and we never will.
We do not use your conversations or check-ins for advertising, and we do not use advertising cookies or tracking pixels.
Our AI providers process your conversations only to generate responses. They do not keep them or use them to train their models.
Organizations that offer ECQO to their people see only de-identified, aggregated trends, never your conversations.
We turn information into de-identified form, which can no longer reasonably identify you, to improve the Services, update our curricula, and conduct research. Research that identifies you happens only if you opt in.
You can access, correct, download, and delete your information.

2. Information We Collect

Information you give us

Account information: email address and password. Sign-in is handled by a secure managed identity service.
Signup confirmations: that you are 18 or older, your state of residence, and the versions of our Terms and policies you accepted, with the date.
Payment information: billing details processed by Stripe. We do not store full card numbers.
Conversation content: the messages and voice audio you send to the companion, and its responses.
Check-in responses: your answers to short wellbeing questions.
Learning records: course enrollment, progress, assessments, simulation lab work, certificates, and certification status.
Communications: messages you send us, and feedback you choose to give.

Information collected automatically

Usage information: features used, session length, and similar activity.
Device information: browser, operating system, device identifiers, and IP address.
Cookies: only those needed to sign you in, keep the Services secure, and remember your preferences.

Information we create

Safety records: automated safety classifications and the outcome of any human review.
Personalization settings: preferences the Services learn from your use, such as language and conversation style.

3. How We Use Information

We use personal information to:

provide and personalize the Services, including generating companion responses;
operate the safety protocol described in our Terms, including crisis resources and human review;
deliver courses, score lab work, and issue and verify certificates and certifications;
process payments and manage accounts;
send service messages, receipts, and required notices;
keep the Services secure and prevent misuse;
create de-identified and aggregated information, as described in Section 6; and
meet legal obligations and enforce our agreements.

We do not use your conversation content or check-in responses for advertising, and we do not use them to make decisions that produce legal or similarly significant effects about you.

4. Conversations, AI Processing, and Safety Review

AI processing. Your messages are processed in real time by Anthropic Claude models through Amazon Web Services, and voice responses are produced by our speech provider. These providers process your content only to generate responses. They do not retain it or use it to train their models.
Our record. We keep conversations in a secure, encrypted, tamper-evident record so your history carries across sessions and so we can show you, a reviewer, or a regulator exactly what happened.
Automated safety monitoring. Automated systems check conversations for signs of serious risk.
Human review. When a session raises serious safety concerns, a trained human reviewer looks at it after the conversation. Reviewers are credentialed, access only what they need, and every access is logged.

5. Voice and Biometric Information

The companion's voices are synthetic. Voice audio you send is processed to understand you and is stored with your conversation history under Section 4.

If we offer voice cloning, we will create a voiceprint only after you give separate written consent that explains the purpose and how long we keep it. Voice enrollment audio and voiceprints are held under contract with defined storage locations and deletion requirements. We never sell or share them for anyone else's purposes. We destroy them when the purpose you consented to is complete, when you withdraw consent, or within three years of your last interaction with us, whichever comes first, unless the law requires us to keep them longer.

6. De-identified and Aggregated Information

We may remove or transform information so that it can no longer reasonably be linked to you or your device. This is de-identified information. Aggregated information combines many people's information so that no individual can be identified.

How we use it. We use de-identified and aggregated information, including information drawn from conversations, check-ins, course work, and simulation lab activity, to:

improve the Services and our safety protocol;
update our curricula, certifications, and member library, on a regular schedule after review by our teams and advisors;
conduct and publish research; and
give organizations aggregated reporting.

Our commitments. We publicly commit to keep de-identified information in de-identified form, and we will not attempt to re-identify it. Anyone we give de-identified information to must agree in writing not to re-identify it. We never publish an individual's conversation, voice, or identity in curricula, research, or marketing without that person's separate written consent. When we report aggregated results, we do not report groups small enough to point to an individual.

7. Research

Research that uses only de-identified information follows Section 6.

Research that uses information that identifies you happens only with your separate opt-in consent, which you can give or decline in the Services. You can withdraw at any time, and we will stop using your identifiable information for research from that point. Information already de-identified, or already included in completed research, cannot be withdrawn because it no longer links to you. Research that requires review by an ethics board, such as an institutional review board, receives that review before it begins.

8. How We Share Information

We share personal information only:

With service providers that operate the Services for us under contracts that limit their use of the information to our instructions: Amazon Web Services (hosting, storage, sign-in, and AI model access), Anthropic (AI responses), ElevenLabs (voice), Stripe (payments), and Cloudflare (content delivery and security).
With organizations you join through, but only de-identified, aggregated reporting. Organizations do not receive your conversation content.
With your consent or at your direction.
For safety, when we believe in good faith that disclosure is needed to prevent serious and imminent harm to you or others, as the law permits.
For legal reasons, to comply with law, court orders, or valid government requests, and to protect the rights and safety of ECQO, our users, or the public.
In a business transfer, such as a merger, acquisition, or sale of assets. The receiving company must honor this policy, and we will notify you before your information becomes subject to a different policy.

We do not sell personal information. We do not share it for cross-context behavioral advertising. We do not use targeted advertising.

9. How Long We Keep Information

We keep information only as long as needed for the purposes in this policy, using these criteria:

Account and conversation information: while your account is active. After you close your account or ask us to delete it, we delete or de-identify it within a reasonable time, except as described below.
Check-in responses and personalization settings: while your account is active, then deleted.
Learning and certification records: while your certification is active and as long as needed to verify credentials you earned.
Safety records: as long as required by law, professional standards, or to defend legal claims.
Payment records: as long as tax and financial recordkeeping laws require.
Voice enrollment audio and voiceprints: as described in Section 5.
De-identified and aggregated information: may be kept, because it no longer identifies you.

10. Security

We protect information with encryption in transit and at rest, managed secrets, least-privilege access, logged access for reviewers, and regular security reviews. No system is perfectly secure. If a breach affects your personal information, we will notify you and regulators as the law requires.

11. Your Rights and Choices

Depending on where you live, you may have the right to:

know what personal information we have and how we use it;
get a copy, including in a portable format;
correct inaccurate information;
delete your information;
withdraw consent you have given, including research consent;
opt out of sale, targeted advertising, and profiling that produces significant effects (we do none of these); and
not be treated differently for using your rights.

How to make a request. Use the privacy settings in your account, email [email protected], or call +1 888-982-9423. We will verify your identity before acting. You may use an authorized agent, and we will confirm the agent's authority. We respond within 45 days, and may extend once by 45 days if needed, with notice.

Appeals. If we decline your request, you may appeal by replying to our decision with the word "Appeal." We will respond within the time your state's law requires. If you are not satisfied, you may contact your state attorney general.

Global Privacy Control. We treat a Global Privacy Control signal from your browser as a request to opt out of sale and sharing.

12. California Residents

Categories collected in the past 12 months: identifiers; customer records; commercial information; internet and device activity; audio information; professional and education information; inferences used for personalization; and sensitive personal information, namely account login credentials and information about health and wellbeing contained in conversations and check-ins. Sources and purposes are described in Sections 2 and 3, sharing in Section 8, and retention in Section 9.

Sale and sharing: We have not sold or shared personal information, including of anyone under 16, in the past 12 months.

Sensitive personal information: We use it only for purposes the law permits without an opt-out, such as providing the Services you request, safety, and security. We do not use it to infer characteristics about you for any other purpose.

Shine the Light: We do not share personal information with third parties for their own direct marketing.

13. Nevada Residents

We do not sell covered information as defined in Nevada law. You may still send a request to opt out of sale to [email protected]. Nevada residents' consumer health data is also covered by our Consumer Health Data Privacy Policy.

14. Residents of Other States

Residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and other states with privacy laws may use the rights and appeal process in Section 11. Residents of Washington, Nevada, and Connecticut have additional rights in our Consumer Health Data Privacy Policy.

15. Users Outside the United States

The Services are operated from the United States, and your information is processed there. For users in the European Economic Area, United Kingdom, and Switzerland, we process personal information on these legal bases: to perform our contract with you; with your explicit consent for health information and optional features; for our legitimate interests in security and improving the Services; and to meet legal obligations. Where required, we use Standard Contractual Clauses for international transfers. You may lodge a complaint with your local data protection authority.

16. Children

The Services are not directed to anyone under 18, and we do not knowingly collect information from children. If you believe someone under 18 has given us information, contact [email protected] and we will delete it.

17. HIPAA

For our consumer Services, ECQO is not a HIPAA covered entity, and the information you give us directly is protected by this policy and applicable state law rather than by HIPAA. When we provide Services to a health care organization under a HIPAA business associate agreement, we protect that information as HIPAA requires, and that organization's notice of privacy practices also applies.

18. Changes to This Policy

We may update this policy. For material changes, we will notify you by email or in the Services before they take effect, and we may ask you to accept the updated version. We record the version you accept. We will not use personal information in a materially different way than described when it was collected without your consent.

19. Contact Us

ECQO Holdings Inc. Attn: Privacy 5725 S Valley View Blvd, Ste 5, PMB 338981 Las Vegas, NV 89118 [email protected] +1 888-982-9423

Read the Terms of Service →Read the Consumer Health Data Privacy Policy →Back to ECQO Holdings