HomecareAITech, Inc.
Privacy Policy
INTRODUCTION
We at HomecareAITech, Inc. (“we”, “us”, “the Company”, or “HomecareAITech”) 2035 Sunset Lake Road,
Suite B-2, Newark, Delaware 19702, USA, value your privacy and are committed to keeping your Personal
Data confidential. We use your data solely in the context of providing an application ( the “Larry App”) to
caregivers (“Guardian Angel Users”) and monitored users (“Monitored Users”) to receive information
from sensors (the “Larry Sensor Kit”) placed throughout the home of Monitored Users to understand their
movement, inactivity, and hygiene, including all relevant content and functionality associated with the
Larry Sensor Kit and the Larry App services (collectively, the “Services”).
This Privacy Policy applies to Personal Data HomecareAITech collects from Guardian Angel Users and
Monitored Users (collectively, “Users”) of the Larry App, the Larry Sensor Kit, and any related Services. To
comply with the EU General Data Protection Regulation (“GDPR”), this Privacy Policy covers our
processing activities as a data controller. The term “Personal Data” includes any information that can be
used on its own or with other information in combination to identify or contact one of our Users.
We believe that transparency about the use of your Personal Data is of utmost importance. In this Privacy
Policy, we provide you detailed information about our collection, use, maintenance, and disclosure of
your Personal Data. The Privacy Policy explains what kind of information we collect, when and how we
might use your Personal Data, how we protect Personal Data, and your rights regarding your Personal
Data.
For additional information related to how we use and disclose your Personal Data, please email us at
hello@meetlarry.io.
Agreement to Privacy Policy Terms
BY ACCESSING AND/OR USING THE SERVICES AND THE LARRY APP, YOU ARE ACKNOWLEDGING THAT
YOU HAVE READ AND AGREE TO THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE, PLEASE
DO NOT SUBMIT ANY PERSONAL DATA TO US AND IMMEDIATELY CEASE USE OF THE SERVICES AND THE
LARRY APP.
Privacy Policy Updates
Please note that we occasionally update this Privacy Policy and that it is your responsibility to stay up
to date with any amended versions. Any revisions to the Privacy Policy will be posted on our website and
the Larry App landing page. Any changes to this Privacy Policy will be effective immediately upon providing
notice and will apply to all Personal Data we maintain, use, and disclose. If you continue to use the Larry
App and the Services following such notice, you are agreeing to those changes.
Account Deletion
If at any point you no longer agree to the use and disclosure of Personal Data, as described in this Privacy
Policy, you can delete your User Account on the Larry App (“User Account”) by sending a deletion request
to hello@meetlarry.io.
Questions or Concerns
If you have any questions or concerns after reading this Privacy Policy, please do not hesitate to contact
us at hello@meetlarry.io.
COLLECTION AND USE OF PERSONAL DATA
What Personal Data Does HomecareAITech Collect?
We, HomecareAITech together with our subsidiary Homecareaitech Teknoloji A.S, Yildiz Teknik
Universitesi Davutpasa Kampüsü Teknopark B1 Blok No: 405 Esenler, Istanbul, Turkey, collect four types
of information: (i) Demographic data; (ii) Support data; (iii) Technology data; and (iv) Device data.
Demographic Data: We collect demographic data such as your name, email address, age, gender,
city, and phone number. The collection of this demographic data is primarily used to create your
User Account, through which you can securely utilize the Services.
Support Data: If you contact us for support or to lodge a complaint, we may collect technical or
other information from you through log files and other technologies, some of which may qualify
as Personal Data (e.g., IP address). Such information will be used for the purposes of
troubleshooting, customer support, software updates, and improvements of the Larry App and
related Services in accordance with this Privacy Policy.
Technology Data: We use common information-gathering tools, such a log files, web beacons,
and similar technologies to automatically collect information, which may contain Personal Data
from your computer or mobile device as you navigate the Larry App or interact with emails or
other communications we have sent you. The information we collect may include your IP address
(or proxy server), device and application identification numbers, location, browser type, Internet
service provider and/or mobile carrier, the pages and files you viewed, your searches, your
operating system and system configuration information, and date/time stamps associated with
your usage. This information is used to analyze overall trends, help us provide and improve the
Services, and ensure the proper functioning and security of the Larry App and the Services.
Device Data: If you are a Monitored User, we will collect information from connected devices and
sensors regarding your movement, habits, and activities in your home. We collect this information
to provide you with the Services and to provide Guardian Angel Users with information about
your daily activities or potential emergencies through the Larry App.
How Will HomecareAITech Use Personal Data?
HomecareAITech processes your Personal Data based on legitimate business interests, the fulfillment of
our Services to you, compliance with our legal obligations, and/or your consent. We only use or disclose
your Personal Data when it is legally mandated or where it is necessary to fulfill those purposes described
in this Privacy Policy. Where required by law, we will ask for your prior consent before disclosing your
Personal Data to a third party.
Specifically, HomecareAITech processes your Personal Data for the following legitimate business
purposes:
● To provide Services;
● To fulfill our obligations to you under the Terms of Use;
● To communicate with you about and manage your User Account;
● To properly store and track your data within our system;
● To respond to lawful requests from public and government authorities, and to comply with
applicable state/federal law, including cooperation with judicial proceedings and court orders;
● To protect our rights, privacy, safety, or property, and/or that of you or others by providing proper
notices, pursuing available legal remedies, and acting to limit our damages;
● To handle technical support and other requests from you;
● To enforce and ensure your compliance with our Terms of Use or the terms of any other applicable
services agreement we have with you;
● To manage and improve our operations, the Larry App, and the Larry Sensor Kit, including the
development of additional functionality;
● To manage payment processing;
● To evaluate the quality of service you receive, identify usage trends, and improve your user
experience;
● To keep our Services, the Larry App, and the Larry Sensor Kit safe and secure;
● To send you information about changes to our terms, conditions, and policies; and
● To allow us to pursue available remedies or limit the damages that we may sustain.
With Whom Does HomecareAITech Share Personal Data?
We may share your personal information with the following categories of individuals/entities:
Business Partners and Vendors: We share Personal Data with a limited number of partners,
service providers, and other persons/entities who help run our business (“Business Partners”).
Specifically, we may employ third-party companies and individuals to facilitate our Services,
provide Services on our behalf, perform Service-related functions, or assist us in analyzing how
our Services are used. Our Business Partners are contractually bound to protect your Personal
Data and to use it only for the limited purpose(s) for which it is shared. Business Partners’ use of
Personal Data may include, but is not limited to, the provision of services such as data hosting, IT
services, customer services, and payment processing.
Our Advisors: We may share your Personal Data with third parties that provide advisory services
to HomecareAITech, including, but not limited to, our lawyers, auditors, accountants, and banks
(collectively, “Advisors”). Personal Data will only be shared with Advisors if HomecareAITech has
a legitimate business interest in or a legal basis for sharing such data.
Third Parties for Research Purposes: If you provide consent, we may share certain Personal Data
with third parties for research purposes.
Third Parties Upon Your Direction or Consent: You may direct HomecareAITech to share your
Personal Data with third parties. Upon your request and consent, we may share such Personal
Data with those third parties that you identify.
Third Parties Pursuant to Business Transfers: In the event of a reorganization, merger, sale, joint
venture, assignment, transfer, or other disposition of all or any portion of HomecareAITech’s
corporate entity, assets, or stock (including in connection with any bankruptcy or similar
proceedings), we may share your Personal Data with a third party.
Government and Law Enforcement Authorities: If reasonable and necessary, we may share your
Personal Data to (i) comply with legal processes or enforceable governmental requests, or as
otherwise required by law; (ii) cooperate with third parties in investigating acts or omissions that
violate this Privacy Policy or the Terms of Use; or (iii) bring legal action against someone who may
be violating the Terms of Use or who may be causing intentional or unintentional injury or
interference to the rights or property of HomecareAITech or any third party, including other Users
of our Services.
Where Is Personal Data Processed?
FOR UNITED STATES USERS: Personal Data we collect from United States Users through the Larry App and
the Larry Sensor Kit will be stored on secure servers in the European Economic Area (“EEA”). Some
Personal Data may be transmitted to third parties, which parties may store or maintain the data on their
secure servers. These third parties are not permitted to transfer your Personal Data outside of the EEA.
The Larry App is “native” to your device, meaning information you enter into the Larry App may be also
stored directly on the device you use to access and enter information into the Larry App.
FOR EU DATA CITIZEN USERS: Personal Data we collect from EU data citizens (“EU Data Citizen Users”)
through the Larry App and the Larry Sensor Kit will be stored on secure servers in the EEA. Some Personal
Data may be transmitted to third parties, which parties may store or maintain the data on their secure
servers. These third parties are not permitted to transfer your Personal Data outside of the EEA. The Larry
App is “native” to your device, meaning information you enter into the Larry App may also be stored
directly on the device you use to access and enter information into the Larry App.
How Long Does HomecareAITech Retain Personal Data?
HomecareAITech retains your Personal Data only as long as necessary and as required for our business
operations, the provision of Services, archival purposes, and/or to satisfy legal requirements. The exact
period of retention will depend on: (i) the amount, nature, and sensitivity of the Personal Data; (ii) the
personal risk of harm for unauthorized use or disclosure; (iii) the purposes for which we process your
Personal Data, including whether those purposes can be achieved through other means; and (iv) business
operations and legal requirements. In general, HomecareAITech strives to retain your data for no longer
than four (4) years after your User Account is closed (the “Retention Period”); however, the above factors
may extend or decrease this Retention Period.
At the end of the applicable Retention Period, we will remove your Personal Data from our databases and
will require that our Business Partners remove any identifiable Personal Data from their databases. If
there is any data that we are unable to delete entirely from our systems for technical reasons, we will put
in place appropriate measures to prevent any further processing of such data. Please note that once we
disclose your Personal Data to third parties, we may not be able to access that Personal Data and we
cannot force the deletion or modification of such information by third parties.
HomecareAITech and its Business Partners reserve the right to continue using de-identified and
anonymized data indefinitely, even after Personal Data has been removed from HomecareAITech’s
databases. We may continue to disclose de-identified or anonymized data to third parties in a manner
that does not reveal personal information, as described in this Privacy Policy. Our continued use of de-
identified and anonymized data will comport with applicable law.
What Happens to Personal Data Submitted by Minors?
HomecareAITech does not knowingly collect Personal Data from individuals under the age of 18.
Additionally, our Services are not directed to individuals under the age of 18. We request that these
individuals not provide Personal Data to us. If we learn that Personal Data from users under the age of 18
have been collected, we will deactivate the User Account associated with that data and take reasonable
measures to promptly delete such data from our records. If you are aware of a user under the age of 18
accessing the Services or Larry App, please contact us at hello@meetlarry.io.
YOUR RIGHTS
What Rights Do Users Have Concerning Their Personal Data?
As a User of HomecareAITech’s Services and the Larry App, you have certain rights relating to your
Personal Data. These rights are subject to local data protection and privacy laws, and may include the
right to:
● Access your Personal Data held by HomecareAITech;
● Erase/Delete your Personal Data, to the extent permitted by applicable data protection and
privacy laws and to the extent technologically feasible;
● Receive communications related to the processing of your Personal Data;
● Restrict the processing of your Personal Data, to the extent permitted by law;
● Object to the further processing of your Personal Data, including the right to object to marketing;
● Request that your Personal Data be transferred to a third party, if possible;
● Receive your Personal Data in a structured, commonly used, and machine-readable format;
● Lodge a complaint with a data protection regulator or other supervisory authority;
● Rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal
Data, ensure it is complete; and/or
● Not be subject to a decision based solely on automated processing, including profiling, which
produces legal effects ("Automated Decision-Making").
Where the processing of your Personal Data by HomecareAITech is based on consent, you have the right
to withdraw that consent at any time. If you would like to withdraw your consent or exercise any of the
rights listed above, please contact us at hello@meetlarry.io.
How Can Users Update, Correct, or Delete Personal Data or Their User Account?
You may change your email address and other contact information or request changes or corrections to
other information by contacting customer support at hello@meetlarry.io. In order to comply with certain
requests to limit use of your Personal Data, we may need to terminate your ability to access and/or use
some or all of the Services. BY REQUESTING TO LIMIT USE OF YOUR PERSONAL DATA OR DELETE PERSONAL
DATA, YOU ACKNOWLEDGE AND AGREE THAT HOMECAREAITECH WILL NOT BE LIABLE TO YOU FOR ANY
CORRESPONDING LIMITATION IN THE SCOPE OF SERVICES OR TERMINATION OF SERVICES AS NECESSARY
TO COMPLY WITH YOUR REQUEST.
You have the right to request deletion of any Personal Data from your User Account. To request deletion
of your Personal Data, please email us at hello@meetlarry.io and include a description of the Personal
Data you would like removed. We will respond to all requests for data deletion as soon as reasonably
possible.
Should you decide to delete your User Account entirely, you may do so by emailing hello@meetlarry.io.
By terminating your User Account, you agree that you will not be able to access any information previously
contained in your User Account. You further understand that it may not be technologically possible to
remove all of your Personal Data from our systems. While we will use reasonable efforts to remove your
Personal Data, the need to back up our systems to protect information from inadvertent loss means a
copy of your Personal Data may exist in a non-erasable form that will be difficult or impossible for us to
locate or remove.
SAFEGUARDING PERSONAL DATA
Is Personal Data Secure?
HomecareAITech understands the importance of data confidentiality and security. We use a combination
of reasonable physical, technical, and administrative security controls to: (i) maintain the security and
integrity of your Personal Data; (ii) protect against any threats or hazards to the security or integrity of
your Personal Data; and (iii) protect against unauthorized access to or use of such information in our
possession or control that could result in substantial harm to you.
While HomecareAITech uses reasonable security controls, WE CANNOT GUARANTEE OR WARRANT THAT
SUCH TECHNIQUES WILL PREVENT UNAUTHORIZED ACCESS TO YOUR PERSONAL DATA.
HOMECAREAITECH IS UNABLE TO GUARANTEE THE SECURITY OR INTEGRITY OF PERSONAL DATA
TRANSMITTED OVER THE INTERNET, AND THERE IS NO GUARANTEE THAT YOUR PERSONAL DATA WILL
NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL,
TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. ACCORDINGLY, WE DO NOT AND CANNOT ENSURE OR
WARRANT THE SECURITY OR INTEGRITY OF ANY PERSONAL DATA YOU TRANSMIT TO US. YOU ASSUME
THE RISK THAT UNAUTHORIZED ENTRY OR USE, HARDWARE OR SOFTWARE FAILURE, AND OTHER
FACTORS MAY COMPROMISE THE SECURITY OF YOUR PERSONAL DATA AT ANY TIME.
What Safeguards Does HomecareAITech Have in Place to Secure My Personal Data?
HomecareAITech stores Personal Data on secured servers and uses a combination of technical,
administrative, and physical safeguards to protect your Personal Data. Such safeguards include, but are
not limited to, authentication, pseudonymization, encryption, backups, and access controls.
How Can Users Protect Their Personal Data?
You are solely responsible for preventing unauthorized access to your User Account by protecting your
account credentials and limiting access to the devices you use to operate the Larry App. HomecareAITech
has no access to or control over your device’s security settings, and it is your responsibility to implement
any device-level security features and protections you feel are appropriate (e.g., password protection,
encryption, remote wipe capability). We recommend that you take all appropriate steps to secure any
device that you use to access our Services or the Larry App.
Please note that HomecareAITech will never send you an email requesting confidential information, such
as account numbers, usernames, passwords, or Social Security Numbers. If you receive a suspicious email
from HomecareAITech, please notify us at hello@meetlarry.io.
Further, if you know of or suspect any unauthorized use or disclosure of your User Account information
or any other security concern, please notify HomecareAITech immediately.
What if HomecareAITech Experiences a Data or Security Breach?
HomecareAITech takes the security of your Personal Data seriously. In the event of a data or security
breach, HomecareAITech will take the following actions: (i) promptly investigate the security incident,
validate the root cause, and, where applicable, remediate any vulnerabilities within HomecareAITech’s
control which may have given rise to the security incident; (ii) comply with laws and regulations directly
applicable to HomecareAITech in connection with such security incident; (iii) as applicable, cooperate with
any affected HomecareAITech User in accordance with the terms of HomecareAITech’s contract with such
User; and (iv) document and record actions taken by HomecareAITech in connection with the security
incident and conduct a post-incident review of the circumstances related to the incident and
actions/recommendations taken to prevent similar incidents in the future. HomecareAITech will notify
you of any data or security breaches as required by and in accordance with applicable law.
MARKETING AND COMMUNICATIONS
Does HomecareAITech Send Marketing or Advertisement Materials?
HomecareAITech may use your Personal Data to contact you with newsletters, marketing, or promotional
materials and other information that may be of interest to you. You may opt out of receiving any
marketing or advertisement materials from HomecareAITech at any time by following the unsubscribe
link or by emailing us at hello@meetlarry.io.
Can Users Opt Out of Receiving Communications from HomecareAITech?
We may send communications, including emails, to you regarding your User Account and the Services or
the Larry App. You can choose to filter any User Account, Services, and Larry App emails using your email
settings, but we do not provide an option for you to opt out of these communications.
If you consent to receive marketing or other communications not related to your User Account, the
Services, or the Larry App, we will provide you with the option to opt out of such marketing
communications within the applicable message.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, the California Consumer Privacy Act (“CCPA”) may apply to you. Please see
the CCPA Attachment for an explanation of your rights.
Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask for and
obtain from us an annual list identifying the categories of personal information which we shared, if any,
with our affiliates and/or third parties in the preceding calendar year for marketing purposes. This list will
be provided free of charge. Contact information for such affiliates and/or third parties must be included.
If you are a California resident and would like a copy of this notice, please submit a written request to the
following address:
HomecareAITech, Inc.
2035 Sunset Lake Road, Suite B-2
Newark, Delaware
19702, USA
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