SeniorThrive Privacy & Data Sharing Policy

Last Updated: July 27, 2026 · Effective Date: July 27, 2026

This policy replaces all previous versions. One change is material: the "Tracking & Advertising" section below now describes retargeting advertising. For accounts created before July 27, 2026, that change takes effect August 26, 2026, and we will not share your information for advertising before that date or without your Marketing cookie consent, whichever is later.

Your Privacy at a Glance (Key Takeaways)

We know privacy policies can be long, so here's a quick overview:

We Collect Your Info: To provide and improve SeniorThrive, and to keep it secure.
Your Health Info is Special (PHI): It gets extra protection and is only shared with your explicit consent through Circle.
You're in Control: You can see, change, or ask us to delete your information. You also control marketing communications.
Strong Security: We use robust measures to protect your data.
Circle Sharing: You decide what PHI is shared with whom in your care circle.
Our Full Terms: This policy works together with our Terms of Service, which has more legal details.

Questions? We're here to help. Contact us at [email protected].

Respecting Your Privacy: Secure & Trustworthy

In the digital age, privacy is vital, especially when it involves your home and health. At SeniorThrive, we place your privacy and security at the core of our service. We're not just creating a platform; we're building a trusted environment where we are deeply committed to protecting your safety and confidentiality.

Our Commitment to Health Data Privacy

SeniorThrive is committed to protecting the privacy and security of your health-related information. While SeniorThrive is not a HIPAA covered entity or business associate, we voluntarily apply strong privacy and security standards to all health-related information you share with us, including encryption, access controls, and audit logging. If we enter into arrangements with healthcare providers or other HIPAA-covered entities that require us to act as a Business Associate, we will enter into appropriate Business Associate Agreements and comply with the applicable requirements of HIPAA.

Scope & Acceptance

By creating an account or using the SeniorThrive website, web application, our iOS or Android mobile applications, or any Circle feature ("Services"), you confirm that you have read, understood, and agree to this entire Privacy & Data Sharing Policy and our Terms of Service (which are incorporated herein by reference and govern your use of our Services). You are also responsible for taking reasonable steps to protect your account, such as using a strong password and keeping your login credentials confidential.

Who's Covered: All users, including Focus Older Adults (OAs), Circle Administrators, Professional Caregivers, and Family Members, whenever you access any SeniorThrive feature.

Information We Collect

We collect and process the following categories of information:

Account & Contact:

Name, email, phone number, password.

Device & Usage:

Device type, operating system, IP address, browser type, features used, errors encountered.

Location (with your consent):

Precise or coarse GPS data to enable location-based services.

Profile & User-Generated:

Photos you upload, free-text entries, support requests.

Health & Fitness (if you opt in):

PHI: Activities of Daily Living (ADL), Instrumental ADL, BMI, medication logs, fall incidents, wellness check-ins, mood/symptom tracking, vital signs.
Non-PHI: Aggregate metrics (ThriveScore), general activity counts.

Apple Health (HealthKit), if you connect it:

If you use our iOS app and choose to connect Apple Health, we read only the health and fitness data you authorize on the Apple permission screen: steps, walking distance, heart rate, weight, sleep, and, where your device provides them, walking steadiness, walking speed, and fall events. We use this data solely to show you your own wellness information, keep your ThriveScore current, and share it with the people in your Circle you have chosen to share it with.

We do not write any data back to Apple Health. We never use Apple Health data for advertising, marketing, or retargeting, we never sell it, and we never disclose it to data brokers. We do not use Apple Health data for any purpose other than your health and fitness within the Services, and we do not share it with third parties other than the service providers who operate SeniorThrive on our behalf under confidentiality obligations, or where you direct us to share it. Apple Health data receives the protections described under Security Measures below.

You can disconnect Apple Health at any time in the iOS Health app under Sharing, or in SeniorThrive under Preferences. Disconnecting stops future reads; to delete readings we have already imported, contact us at [email protected].

Household & Environmental:

Room Check photos, pet information, household to-do lists.

Financial (if you transact):

Payment details collected via secure third-party processors (we never store full card numbers).

Cookies & Tracking:

We use cookies, beacons, and similar technologies for analytics and personalization.
Marketing Cookies (Optional, off until you turn them on): If you opt in on our public marketing website, we and our advertising partners, currently Meta (Facebook and Instagram) and Reddit, use these to measure ad performance and to show you SeniorThrive ads after you leave our site. These technologies do not run inside the signed-in SeniorThrive application or our mobile apps. See "Tracking & Advertising" below for the limits we place on this.

De-Identification:

When processing data for analytics or research, we strip direct identifiers (name, email, device ID) and employ methods consistent with recognized de-identification standards (such as those outlined under HIPAA) to prevent re-identification. We avoid combining this de-identified data with other datasets that could lead to re-identification unless you explicitly opt in.

Tracking & Advertising

Most people who visit seniorthrive.com are researching a change for themselves or a parent and are not ready to decide the same day. With your permission, we advertise to people who have visited our public marketing pages so they can find their way back. This section explains exactly how far that goes and, just as importantly, where it stops. For a detailed list of all cookies and tracking technologies we use, please see our Cookie Policy.

Retargeting Advertising (Optional):

If you turn on Marketing cookies, we place advertising technologies on our public marketing website from Meta Platforms, Inc. (the Meta pixel, which powers advertising on Facebook and Instagram) and Reddit, Inc. (the Reddit pixel). These technologies tell the advertising partner that a browser visited a SeniorThrive marketing page and, if you later create an account or start a subscription from that visit, that the visit led to a signup. The partner uses this to show you SeniorThrive ads and to measure whether our advertising works. Under California law this activity is considered "sharing" personal information for cross-context behavioral advertising, even though no money changes hands, and you have the right to opt out of it at any time (see "Your Advertising Choices" below).

We also use Google Analytics and Google Tag Manager on our marketing website, under the same Marketing consent, to understand which pages and campaigns bring people to SeniorThrive.

Limits We Place on Advertising Technologies:

These limits are commitments, not aspirations:

Public pages only. Advertising technologies run only on our public marketing website. They are not present in the signed-in SeniorThrive application, in our iOS or Android apps, or on any page behind a login.
No health data, ever. We never transmit health or health-related information to an advertising partner. That includes anything you enter in the app, assessment or questionnaire answers, ThriveScore, medications, Room Check results, Apple Health or wearable readings, and any information about a specific condition, diagnosis, symptom, or care need.
Page visits, not conclusions about you. Our advertising technologies run across our public marketing website, including educational articles and tools about home safety and healthy aging. What they record is that a browser opened a page. They do not receive your answers, your results, or any conclusion about your health, and we do not build advertising audiences defined by a health condition, diagnosis, or care need. Reading an article on our site never places you in a health-based advertising audience.
No sensitive matching. We do not enable automatic advanced matching, and we do not upload customer lists derived from health information, assessment results, or care relationships to any advertising platform.
Consent first. Advertising technologies load only after you affirmatively grant Marketing consent in our cookie banner, and never for a browser sending a Global Privacy Control (GPC) signal.
Not for older adults' data. We do not use information collected inside a Focus Older Adult's account, or shared within a Circle, for any advertising purpose.

Session Recording and Heatmaps (Optional):

Under the same Marketing consent, we use Microsoft Clarity on our public marketing website to see how visitors move through our pages. Clarity records page interactions such as mouse movement, scrolling, and clicks, and assembles them into aggregate heatmaps and individual session playbacks, which we use to find pages that confuse people. Clarity runs across our public marketing website, including the quizzes and tools we offer there, but never inside the signed-in SeniorThrive application or our mobile apps, so it never observes your account, your health information, your medications, your assessments, or anything in your Circle. Withdrawing Marketing consent stops it, as does a Global Privacy Control signal. Our product analytics provider, PostHog, does not record sessions at all.

Your Advertising Choices:

You can withdraw Marketing consent at any time through the cookie preferences link in our website footer, which stops future sharing immediately. You may also send a Global Privacy Control signal from your browser, which we honor as a universal opt-out, or email [email protected] with the subject line "Opt Out of Advertising." Opting out does not affect your access to any part of SeniorThrive, and we never charge a different price or provide a lesser service because you opted out.

Product Analytics (SeniorThrive Web Application):

Within the SeniorThrive web application, we use PostHog (PostHog, Inc., 2261 Market Street #4008, San Francisco, CA 94114, United States) to understand how our service is used and to improve the experience. PostHog acts as our data processor under a Data Processing Agreement and stores data in the United States. PostHog receives a pseudonymous user ID and event data describing your interactions with the platform (such as page views and sign-in events). PostHog does not receive your name, email address, home address, phone number, date of birth, medications, home safety photos, assessment results, care plan, role (senior, family member, or caregiver), or any information about your health or care relationships. Session recording is disabled. We load PostHog only after you grant Tier 3 (Marketing & Analytics) consent, and we honor the Global Privacy Control (GPC) browser signal as a universal opt-out.

Cookie Banner Controls:

Our cookie banner offers at least three tiers, Necessary, Functional, and Marketing. You choose which to allow.

Browser Settings:

You can disable or block third-party cookies in your browser (Chrome, Safari, Firefox, etc.).

Do-Not-Track:

While browsers may send a "Do Not Track" signal, enforcement varies. Use your cookie banner choices and browser settings for reliable control.

How We Use & Share Your Information

App Functionality & Security:

To provide, maintain, and secure our Services, including authentication, fraud prevention, uptime monitoring, customer support.

Personalization & Analytics:

Content recommendations, troubleshooting, feature testing, service improvement.

Care Collaboration (Circle):

With your explicit approval, share precise data categories with caregivers and family as detailed in the Circle Addendum.

Communication:

Notifications, onboarding emails, product updates, service announcements (you control marketing opt-in/out).

Third-Party Services & Advertising:

We share information with third-party service providers who assist us in operating our Services, only under written confidentiality and data protection agreements. Advertising is limited to our public marketing website, requires your Marketing consent, and never involves health-related information. See "Tracking & Advertising" above.

Legal Compliance:

Responding to lawful requests from public and government authorities, complying with legal processes, enforcing our terms and conditions, protecting our operations or those of any of our affiliates, protecting our rights, privacy, safety or property, and/or that of our affiliates, you or others; and allowing us to pursue available remedies or limit the damages that we may sustain.

Business Transfers:

In a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be sold or transferred as part of that transaction. Your rights and protections regarding your PHI will travel with it.

Referral Introductions:

If you request a referral through SeniorThrive, we may collect details you provide (such as your name, contact information, and general description of your home safety or accessibility needs) to help identify an appropriate service provider. We may share only the necessary details with potential providers to facilitate an introduction. We do not sell or rent this information, and we encourage you to review the privacy practices of any provider you choose to engage.

Artificial Intelligence and Automated Processing

Several SeniorThrive features use artificial intelligence (AI) and automated processing to provide you with personalized information and recommendations. We believe in full transparency about how your data is processed by AI systems.

AI-Powered Features:

Our AI features use Google's Gemini AI models, which we access through Google Cloud's Vertex AI platform provided by Google LLC under enterprise data processing terms. Depending on which features you use, the following categories of information may be sent to that platform for processing:

Photos you choose to submit, such as room photos for a home safety review, medication labels you ask us to read, or images you ask us to identify.
Text you write or submit, such as messages to an AI companion, health topics you search, or content you ask us to check for signs of a scam.
Assessment and profile responses, including questionnaire answers and daily-living assessment scores, used to generate personalized recommendations and care plan suggestions.
Data categories you have consented to share with a companion, such as home safety results, wellness logs, or check-ins, used only to personalize that companion's responses to you.

Each AI feature is identified as AI-powered where you use it. Information is sent only when you use the feature, and none of it is used for advertising. A current list of the third-party service providers that process data on our behalf is available on request at [email protected].

AI Data Handling:

We process your data through Google Cloud's Vertex AI platform under Google's enterprise data processing terms and Data Processing Addendum. Under these terms: (1) Google does not use your data, prompts, or AI outputs to train or improve Google's foundation AI models; (2) Google acts as our data processor with respect to your data, not as an independent controller; (3) Google may retain input and output data for up to 30 days solely for abuse and safety monitoring, after which it is deleted; and (4) data is processed within Google Cloud regions we select. We do not permit any AI sub-processor to use your data for purposes beyond providing the service to SeniorThrive.

AI Limitations:

AI-generated content is provided for informational purposes only and may contain errors, omissions, or inaccuracies. AI outputs do not constitute medical advice, professional home safety assessments, or clinical recommendations. You should not rely solely on AI-generated information and should always consult qualified professionals for medical, safety, or care decisions.

Automated Decision-Making:

SeniorThrive uses automated processing to compute your ThriveScore (a composite wellness, safety, and connection metric) and to assess medication risk profiles based on FDA data. These computations are performed on our own servers and do not involve external AI services. No automated decision has binding legal or similarly significant effects on you. You may contact us at [email protected] to request information about how automated processing applies to your account.

Integration with Third-Party Services

In addition to the AI services described above, SeniorThrive integrates with the following third-party services that may receive your data:

Google Services:

Google Calendar: If you connect your calendar, appointment details (event titles, times, locations, and attendees) are synced with Google Calendar via their API.
Google Photos: If you connect Google Photos, we access your photos and albums with your OAuth authorization. We request read-only access.
Google Maps: Address and location data may be sent to Google Maps for geocoding and location-based features.
YouTube API: Enables video features (e.g., embedded tutorials, SeniorThrive Explores series). Search queries are sent to YouTube.

Health Data Services:

FDA openFDA API: Medication names (without any personal identifiers) are sent to the U.S. Food and Drug Administration's public API to retrieve drug label information and recall data.
MyHealthFinder (HHS): Demographic information (age and sex, without personal identifiers) may be sent to the U.S. Department of Health and Human Services to retrieve personalized health recommendations.

Product and Content Services:

When you search for a book, a product, or a local service provider inside SeniorThrive, we send your search terms to third-party book, product, and service-directory providers to return results. These searches are sent without your name, email address, or any health information.

Other Integrations:

Fitness trackers (such as Oura, Fitbit, and Withings), analytics platforms, and other third-party services we integrate with are vetted for appropriate privacy and security standards, including data processing agreements where applicable.

Third-Party Privacy Policies:

By using SeniorThrive features that interact with Google services, you also agree to Google's Terms of Service and Privacy Policy. We encourage you to review the privacy practices of all third-party services you connect through SeniorThrive.

Your Rights & Choices

Access & Correction:

View or edit your account details and PHI entries at any time through your account settings.

Export & Deletion:

Download your data (e.g., in CSV/JSON format) or request permanent deletion of your account and associated data, subject to legal retention requirements and our data retention policies.

Consent Management:

Toggle data-sharing settings in Settings → Privacy, especially for Circle features.

Cookie Controls:

Adjust cookie preferences via our cookie banner or your browser settings.

Email Opt-Out:

Every marketing email footer has an "Unsubscribe" link; you can also adjust preferences under Settings → Notifications.

Children's Privacy:

We do not knowingly collect personal information from children under 13 (or a higher age threshold where applicable by law). Our services are not directed to children. If we learn we have collected a child's personal information, we will promptly delete it.

State-Specific Privacy Rights

Depending on where you live, you may have additional rights under state privacy laws. Below is a summary of key rights by state. To exercise any of these rights, contact us at [email protected]. We will respond within the timeframe required by applicable law. We will not discriminate against you for exercising your rights.

California (CCPA/CPRA)

If you are a California resident, you have the right to:

Know: Request the categories and specific pieces of personal information we have collected about you, the sources, the business purposes, and the categories of third parties with whom we share it.
Delete: Request deletion of your personal information, subject to certain exceptions.
Correct: Request correction of inaccurate personal information.
Opt Out of Sale/Sharing: SeniorThrive does not sell your personal information for money, and we never sell or share health-related information for advertising under any circumstances. If you grant Marketing consent on our public marketing website, we do share limited identifiers and browsing activity from those public pages with Meta for cross-context behavioral advertising, as described under "Tracking & Advertising" above. You may opt out at any time through the cookie preferences link in our footer, by sending a Global Privacy Control signal, or by emailing [email protected]. We do not knowingly share the personal information of consumers under 16.
Limit Use of Sensitive Personal Information: You may limit our use of sensitive personal information (including health data) to purposes necessary to provide the Services.
Non-Discrimination: We will not deny you services, charge different prices, or provide a different quality of service because you exercised your privacy rights.

You may designate an authorized agent to make a request on your behalf. We may require verification of your identity before fulfilling any request.

Washington (My Health My Data Act)

If you are a Washington resident, the My Health My Data Act provides you with specific rights regarding consumer health data, which includes information SeniorThrive collects such as medication information, wellness check-ins, vital signs, Room Check results, emergency card medical information, and any health-related search or symptom entries. These rights do not extend to our product-analytics telemetry (page views and sign-in events sent to PostHog), which does not identify your health status, conditions, role, or care relationships. Your rights with respect to your consumer health data include:

Consent: We will obtain your consent before collecting or sharing your consumer health data, except as necessary to provide the Services you requested.
Access: You may request confirmation of whether we are collecting or sharing your consumer health data.
Deletion: You may request deletion of your consumer health data.
Withdrawal: You may withdraw consent for future collection or sharing of your consumer health data.
No advertising use, and no sale: We do not use or disclose consumer health data for advertising, retargeting, or audience building, and we do not sell consumer health data. Our advertising technologies run only on public marketing pages and never receive health data, as described under "Tracking & Advertising" above.
No geofencing: We do not operate a geofence around any health care facility, and we do not use location data to identify or advertise to you based on visits to health care providers.

Colorado, Connecticut, Virginia, and Texas

If you reside in Colorado, Connecticut, Virginia, or Texas, you generally have the right to:

Confirm whether we are processing your personal data and access that data.
Correct inaccuracies in your personal data.
Delete your personal data.
Obtain a portable copy of your personal data.
Opt out of targeted advertising, sale of personal data, and profiling that produces legal or similarly significant effects.
Automated Decision-Making (Colorado, Connecticut): You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. You may also request information about the logic used in automated processing that affects you.

If we decline your request, you may appeal by contacting us at [email protected] with the subject line "Privacy Rights Appeal."

Email Communication & Consent

Opt-In Required:

During signup, you explicitly consent to receive emails, each opt-in is logged with a timestamp.

Confirmation Email:

After you opt in, we send a verification link before any regular communications begin.

Types of Messages:

Welcome/onboarding, wellness reminders, product updates, community news, legal/security notices.

Withdraw Consent:

Use the "Unsubscribe" link in any email or adjust in Settings → Notifications.

Third-Party Delivery:

We use trusted providers (e.g., Dreamlit, OneSignal) under strict confidentiality; we never sell your email address.

Security Measures

We employ robust technical, administrative, and physical safeguards designed to protect your information from unauthorized access, use, alteration, and disclosure. These include:

Encryption: AES-256 at rest; TLS 1.2+ in transit.
Access Controls: Role-based permission checks on every PHI request.
Audit Trail: We keep an append-only audit record of changes to health-related information, capturing who made the change, what was changed, and when. Audit records cannot be edited or erased once written, apart from the removal of aged records under our retention schedule.
Access Records: When someone else in your Circle opens a category of your health information, we record that too, including attempts to open a category you have kept private. The record holds who looked, which category, and when. It never holds a copy of what they saw.
Vendor Commitments: Where a third party processes health-related information on our behalf, our agreement with them includes written data protection terms restricting them to processing that information on our instructions and for no purpose of their own.
Security Review: We review our code and infrastructure for security issues as part of our development process.

While we take significant measures to protect your data, no security system is impenetrable. We cannot guarantee the absolute security of your information. In the event of a data breach involving your personal information where notification is required by law, we will notify you in accordance with applicable legal requirements.

Changes to This Policy & Contact

We'll post updates to this Privacy Policy here and notify you (e.g., via email or in-app notification) at least 30 days before material changes take effect. Your continued use of SeniorThrive after such notice constitutes your acceptance of the revised policy.

Questions or Complaints: [email protected]

Accessibility: We are committed to making this policy accessible. If you need it in an alternative format, please contact us.

Contact Us

Privacy questions, data requests, or notices under applicable state privacy laws may be sent to:

SeniorThrive LLC
Attn: Privacy Officer
5436 Via Carrizo, Laguna Woods, CA 92637
Email: [email protected]

Acknowledgement

By continuing to use SeniorThrive, via our website, web application, mobile applications, or Circle features, you confirm you've read, understood, and accepted this Privacy & Data Sharing Policy and our Terms of Service in their entirety.

Governing Law & Our Terms of Service

This Privacy Policy and any disputes related to it or your use of SeniorThrive Services will be governed by and construed in accordance with the laws of the State of California, without regard to its conflict of law principles.

Our Terms of Service contain important provisions regarding dispute resolution (which may include arbitration and a class action waiver), limitations on liability, and other terms that govern your use of our Services. Please review them carefully.

International Data Transfers

SeniorThrive is based in the United States. If you are accessing our Services from outside the United States, please be aware that your information, including personal data and PHI, may be transferred to, stored, and processed in the United States, where our servers are located and our central database is operated. The data protection and other laws of the United States might not be as comprehensive as those in your country. By using our Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Policy.

Circle Data-Sharing Addendum

This Addendum applies only when you use any Circle features centered on a Focus Older Adult's (OA's) care. It details how data, especially Protected Health Information (PHI), is shared within a Circle.

Key Definitions

PHI (Protected Health Information):

Information that relates to your past, present, or future physical or mental health or condition, the provision of health care to you, or the past, present, or future payment for the provision of health care to you, and that identifies you or for which there is a reasonable basis to believe it can be used to identify you. Examples include medication logs, fall incidents, vital signs, and mood/symptom entries.

Non-PHI:

Other data that is not PHI. Examples include room checks (unless they incidentally contain PHI), general appointments, and to-do lists.

Roles:

Focus OA: The older adult whose data lies at the heart of the Circle.
Circle Admin: Manages membership & shared household information.
Professional Caregiver: Enters and views clinical PHI necessary for care, subject to the professional and contractual confidentiality obligations that apply to them and, where applicable, to their employing agency.
Family Member: Views approved data categories, adds non-PHI entries, and may sync calendars.

Role-Based Permissions & PHI

Action / Category	Focus OA	Circle Admin	Professional Caregiver	Family Member	PHI?
Medications	✓	With Consent	With Consent	With Consent	PHI
Fall Incident Reports	✓	With Consent	With Consent	With Consent	PHI
Wellness Check-Ins & Mood Logs	✓	With Consent	With Consent	With Consent	PHI
Vital Signs & Clinical Notes	✓	With Consent	With Consent	With Consent	PHI
Medical Appointments	✓	With Consent	With Consent	With Consent	PHI
General Appointments	✓	✓	✓	✓	Non-PHI
Household / Room Checks	✓	✓	With Approval	With Approval	Non-PHI
Calendar Sync (External Apps)	✓	✓	✓	✓	Non-PHI
Family-Suggested Events (Propose / Confirm)	✓ (Confirms)	✓	View only	With Consent (Suggest)	Non-PHI

Footnotes:

Explicit OA consent required before any access.
Sensitive household items (e.g., room check photos) require OA/Admin approval for sharing.
Only non-PHI metadata (e.g., event time, title, location for general appointments) syncs unless you expressly opt in to share more details that might constitute PHI.
Family-Suggested Events: Family Members may propose calendar events only after the Focus OA enables the "Family suggestions on my calendar" toggle in Privacy Settings. Each suggestion appears on the OA's home dashboard with Confirm / Decline buttons; nothing is added to the calendar until the OA acts.

Family Coordination Calendar

SeniorThrive includes a shared family calendar so family members in your Circle can help coordinate around your day-to-day. The following terms apply specifically to that feature.

Family suggestions require your explicit consent. Family Members (other than your designated Circle Admin / Family Advocate) cannot write to your calendar unless you turn on "Family suggestions on my calendar" in Privacy Settings. This toggle is OFF by default and may be changed only by you. Adding a family member to your Circle does not, by itself, grant them the ability to add or edit events on your calendar.

You confirm every suggestion. When the toggle is on, family members can suggest events that appear on your home dashboard with Confirm and Decline buttons. Nothing is added to your calendar until you explicitly confirm. You may decline by selecting from a short list of reasons (e.g., "Not a good time," "Already have plans," "Want to talk first," "Not now"). Decline reasons are stored only as these short labels; we do not capture free-text decline reasons because they can inadvertently include sensitive information you intended only for one family member.

Family activity log. Each calendar event has an activity log that family members in your circle can see. The log records who suggested an event, who confirmed it, who claimed responsibility, who released responsibility, and any comments family members added. Comments are limited to 500 characters and are intended for logistics ("I'll meet you at the front entrance"), not medical detail. If a family member exercises a right to delete their account, references to them in the log are replaced with "a former family member" while the record of the action itself remains for the rest of the circle's continuity.

Conflict warnings between family members. When a family member proposes an event, our service may indicate that the proposed time overlaps with an existing item on your calendar. The warning is intentionally limited to the fact and approximate time of the conflict (e.g., "another commitment around 3:00 PM"). We do not share the title, location, or other details of the conflicting item with the proposer.

Notifications. We deliver coordination notifications through two channels: in-app alerts and a once-daily email digest. The in-app channel shows full event titles to family members who already have access through the Circle. The email digest, because it leaves our platform, applies an additional protection: events typed as "Health" are referenced by category only ("Health appointment") rather than by the full title that you or a family member entered. All other event types are referenced by their full title.

Coordination is communication, not a service. Confirming or declining a suggestion, claiming responsibility for an event, or commenting in the activity log is a way to keep your family in sync. It is not a guarantee that any family member will follow through on the activity recorded. SeniorThrive does not provide care or transport; we provide the place where your family aligns on what they are doing for you.

Rate limit and undue-influence protection. To protect against pressuring patterns, Family Members are limited to a small number of suggestions per day. The Circle Admin / Family Advocate role is not subject to this limit because the role itself reflects a delegation you have already made.

How Consent Works

Sharing is off by default. Nothing in a category of your health information becomes visible to a Circle member until you turn that category on for that person under Preferences → Privacy. Each control names the category and the person before you confirm, tells you that you can undo it at any time, and links to the Role-Based Permissions table above.

The same is true of the choices that let information leave SeniorThrive. Inviting someone to your Circle, connecting an external calendar, and connecting Apple Health or a fitness tracker each require a separate, affirmative choice by you, and each explains what will be shared before you make it. We do not treat one consent as permission for a different one.

Audit & Revocation

Immediate Enforcement:

Revoking consent via Settings → Privacy instantly hides all affected PHI from the relevant Circle member(s).

Notifications:

In-app toasts and optional email alerts to impacted members:

Example: "Access to [Focus OA Name]'s [Category] data was revoked by [Focus OA Name/Circle Admin Name] on May 20, 2025."

Data Retention & Portability

Active PHI:

Remains accessible within an active Circle according to the permissions you've set.

Post-Circle/Account Closure:

Upon Circle deletion or Focus OA account closure (including in the event of death), PHI is archived for a period of six months. This retention period supports data recovery needs and allows legally designated representatives to request data export. After this period, PHI is securely purged from our active systems, subject to any overriding legal or regulatory retention obligations.

Export:

You or your legally designated representative can request an export of your data.