Saela Technologies Inc.
Privacy Policy
Saela, Inc. ( “Saela”, “we” or “us”) respects and is committed to protecting your, the end user or parent/legal guardian of the end user (“you” or “your”), privacy. This Privacy Policy explains how we collect, use, and disclose information about individuals when individuals access and use our website located at www.saelasync.com (the “Site”), when the Site is used to navigate to third-party platforms, or where users access, download and use the Saela mobile application (the “App”). The Site, and the App are, collectively, the “Services.” This Privacy Policy describes how we collect, use, and disclose personally information (“Personal Information”). This Privacy Policy also describes how we collect, use and disclose the personal health information of users who utilize our App or access portions of the Services that require registration (“Personal Health Information”).
Please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Use, found at https://www.saelasync.com/legal/terms-of-use. Therefore, please make sure that You have read and understand our Terms of Use.
CHANGES TO THIS PRIVACY POLICY
We may change this Privacy Policy from time to time to address new technologies, regulatory requirements, or for other purposes. We will provide notice to you if these changes are significant and, where required by law, we will obtain your consent. Notice may be made by posting a notice on the Services, by notifying you by email using the email address you last provided, or by other means that are consistent with applicable law.
We encourage you to review this Privacy Policy from time to time, to stay informed about our collection, use, and disclosure of personal information through the Services. If you don't agree with any changes to this Privacy Policy, you may terminate your account. By continuing to use the Services after the revised Privacy Policy has become effective, you acknowledge that you accept and agree to the current version of the Privacy Policy.
PERSONAL INFORMATION WE COLLECT
Personal information means any information that may be used to identify an individual, including, but not limited to, an individual’s name, email address, a home, postal or other physical address, phone number, and online contact information (including a screen or user name, geolocation information sufficient to identify street name and name or city or town, or persistent identifiers that can be used to identify a user). Personal Health Information means any information that identifies or can reasonably be linked to an individual and that relates to the individual’s past, present, or future physical or mental health or condition, including without limitation information about menstrual or reproductive health, symptoms, health observations, wellness data, mental health and emotional observations, biometrics, test results, health information and any related inferences generated by the App or Services. Personal Health Information does not include information that has been aggregated or de-identified so that it cannot reasonably be used to identify an individual.
Information You Provide to Us Directly (Without Registration). We collect personal information from individuals who visit the Site (and do not register to use the Site), and from individuals who register to use our Services (through the Site or the App). Individuals may provide us with personal information directly when they fill out forms on our site, request information about our products and services, or otherwise email or interact with us.
Information You Provide to Us Directly (With Registration). A user must create an account within the App in order to use our registration-based Services. The kinds of personal information, which includes Personal Health Information, that You may provide us when using our App include:
· First Name and Last Name
· Cell Phone Number, Carrier and Device Information
· Email address
· Birth Date
· Preferred Pronouns
· Journal Entries and Chat Entries
· Profile Customizations
· SMS, Email and In-App Messaging, Including Communications with Support
· Safety and Wellness Responses
· Appointment and Meeting Scheduling
· Voice or Video Data (when you use communication features of the App) or image data
· Preferred Language
· General health information, as determined by the user
Integrated Services. We also allow users to register to use the Services through third-party integrated service (“Integrated Service”). Where an Integrated Service is made available, we may collect personal information about the individual (including Personal Health Information) that is already associated with your Integrated Service account.
Cookies and Tracking Technology. We collect information automatically when you visit our Site or access and use our Services through a variety of technologies, including cookies, pixels, tags, and Web beacons. We use such tracking technologies to enable certain functions of the Services, to store your preferences, to report usage and performance statistics of the Services, to monitor the effectiveness of our advertising, and to ensure functionality of the Services.
We do not use cookies to serve third-party advertisements, nor to target users with behavioral advertising. If you would like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser. Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features of the Services, you may not be able to store your preferences, and some of our pages might not display properly.
Some third-party services providers (e.g., Integrated Services) that we engage use their own cookies. This Privacy Policy covers only our use of cookies and does not include use of cookies by such third parties.
Information Related to Your Use of the Services. When you interact with our Services, we collect Your IP address (the Internet address of your computer) and other information about your activity and devices, such as your browser type and operating system, session information, feature interaction, content interaction metrics, search queries, network information, geolocation (course only), referral source, language preferences and similar kinds of data We collect this information through the use of cookies and tracking technology referred to above.
Information Sent by Your Mobile Device. If you access and use our App and Services via mobile device (including downloading and using the App), we collect certain information that your mobile device sends when you use our Services, such as device ID, user settings and the operating system of your device, app performance metrics, mobile app version, app permissions granted to us, Bluetooth status, information about your use of the App, and other similar kinds of information. You understand that, by logging onto the App on your mobile device, information pertaining to your use of our Services may be stored to Your mobile device. We are not responsible for any unauthorized access by any third party to such information on Your mobile device.
HOW WE USE PERSONAL INFORMATION
When you register to use our Services, we use the personal information we collect from you (including Personal Health Information) to:
· Create Your Account and Provide the Services to You
· Personalize the Services Based on Your Activity
· Remember Your Activity and Progress
· Enable Messaging and Communications Features in the Services
· Generate AI-Powered Responses
· Recommend Content
· Detect Safety Concerns (including Severe Issues)
· Improve Chatbot Automated Responses (we send deidentified information to third party chatbot providers for this purpose)
· Respond to Your Messages, Inquiries or Requests
· Send You Messages Related to the Performance of the Services
· Perform l Research and Product Development
· Maintain Our Business Records and for Other Internal Business Purposes
· Comply with Applicable Law or Protect Our Legal Rights
· To Comply With Your Requests or For Other Reasons that We Notify You of
We do not use Personal Health Information to market products and services (including the Services).
SMS Messaging
We do not send marketing or promotional text messages to users. All SMS communications are directly related to your use of our Services and your safety
While you can opt out of general SMS communications, safety alert messages related to severe issues are sent for your protection and the protection of others. If you opt out of SMS entirely, these critical safety communications will be sent through other available channels (email, in-app notifications, direct contact with your school).
SMS message content and metadata are retained by our service provider Twilio for 400 days from the date sent, after which they are automatically deleted. You may request earlier deletion of your SMS data by contacting us at privacy@saelasync.com.
THE CATEGORIES OF THIRD PARTIES THAT WE DISCLOSE PERSONAL INFORMATION TO
Service Providers and Vendors. We engage service providers to help us operate, secure, and improve the Services. These providers have access to personal information (and, in some cases Personal Health Information) and are contractually bound to use it only for specified purposes. This category includes:
· Technology Infrastructure Providers. These service providers include cloud hosting, database management, and IT infrastructure services that store and process data on our behalf.
· Communication Service Providers such as email delivery, SMS messaging, and push notification services that help us communicate with users and school personnel.
· Artificial Intelligence and Machine Learning Providers. AI services that power AI functionality and generate dynamic content.
· Analytics and Performance Monitoring. These service providers help us understand product usage, monitor system performance, identify bugs and errors, and improve user experience.
· Security, Identity Verification and Authentication Services. These service providers provide security services such as cyber security tools, cyber security auditing, log monitoring, single sign-on providers and identity management platforms that authenticate users.
· Customer Support and Feedback Tools. These service providers provide software and other services that help us support our platform and to collect, organize, and respond to user feedback and support requests.
· Marketing Service Providers. These service providers provide email marketing, CRM systems, and website analytics.
Research Partners. We may share de-identified and aggregated data sets with research partners for academic research, quality improvement studies, and product development. This data has all direct and indirect identifiers removed and cannot be linked back to individual user, and we do not share Personal Health Information with research partners. De-identified data will have all direct and indirect personal identifiers removed.
Service Integrators. We share limited personal information, including Personal Health Information, with third-party platforms that schools use to integrate our Services, such as student information systems (SIS), learning management systems, and school portals.
Payment Processors. If you pay for Services directly, payment processors receive necessary personal information to process transactions. For regulatory reasons, these are not our service providers and process personal information according to their own privacy policies and terms. We do not share Personal Health Information with payment processors.
Corporate Affiliates. We may share personal information, including Personal Health Information, with our parent company, subsidiaries, joint venture partners, or other companies under common control, who must agree to use personal information consistent with this Privacy Policy.
Acquirers in Business Transactions. In connection with a merger, acquisition, reorganization, or sale of assets, personal information, including Personal Health Information, may be transferred to the acquiring entity.
Government, Law Enforcement, and Legal Processes. We may disclose personal information, including Personal Health Information, to government authorities, law enforcement, or private parties where required by law or to protect or enforce our rights or the rights of third parties.
Other Categories. We may share personal information, including Personal Health Information, with other types of third parties with your consent, at your direction or upon prior notice to you (where prior notice is required by applicable law).
We do not sell personal information, including Personal Health Information, to third parties. We do not share personal information, including Personal Health Information with third parties for their own marketing purposes. We do not permit third-party tracking for advertising purposes on our Services.
REGULATORY STATUS
The App and Services are not intended to be used as a substitute for professional medical advice, diagnosis, or treatment, and Saela is not a “covered entity” or “business associate” as those terms are defined under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Accordingly, HIPAA does not apply to information you provide through the App
USE BY CHILDREN AND MINORS
The App and Services are not intended for use by children under the age of 18, and Saela does not knowingly collect personal information, including Personal Health Information, from children under 18. If we become aware that we have collected personal information from a child under 18 without verified parental consent, we will take steps to delete such information as required by applicable law.
Parents or legal guardians who believe that a child under 18 has provided personal information through the App may contact us using the information provided below to request deletion of such information.
DATA RETENTION AND DELETION; ACCOUNT TERMINATION
Generally, we retain personal information collected from you, whether online, through connected devices or wearables, or through other permitted sources, only for as long as is reasonably necessary to fulfill the purposes for which it was collected, or as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.
You may delete your account through the Services at any time. Upon account deletion, we will delete all Personal Information associated with your account and take reasonable steps to ensure such information is no longer accessible or used by us.
We retain Personal Health Information for as long as a User Account remains active. An account is considered inactive if no logins have occurred within the past twenty-four (24) months. When an account becomes inactive, all Personal Information will be deleted, and any link between Personal Information and Personal Health Information on your device or within our systems will be permanently removed. De-identified or “abandoned” Personal Health Information that can no longer be linked to an individual may be retained indefinitely for purposes such as research, model training, and service improvement, in accordance with applicable law.
If you wish to access, review, modify, or delete personal information you have provided to us, or if you are a parent or legal guardian seeking to exercise these rights on behalf of a user, please contact us at privacy@saelasync.com.
When you delete or modify personal information, we permanently remove the prior version of that information from our active systems and production databases, and it is no longer accessible or used by us. Limited copies may persist for a short period in secure backup systems maintained solely for disaster recovery, legal, or compliance purposes, and are permanently deleted in accordance with our backup retention schedules.
YOUR CHOICES AND OPT-OUTS
Email Communications
We may periodically send emails that directly promote our Services. If you receive such promotional communications from us you will have the opportunity to “opt-out” of future communications from us (either through an account or by following the unsubscribe instructions provided in the e-mail).
Separate from the promotional communications sent to school administrators and school counselors, we may need to send you certain operational or transactional communications regarding the Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms of Use or this Privacy Policy).
Cookies and Tracking Technology
You can manage cookies through your browser settings. Most web browsers automatically accept cookies, but you can modify your browser settings to delete or refuse cookies. Visit your browser’s help pages for specific instructions on cookie management. Note that if you delete or refuse cookies, some features of the Services may not function properly, you may not be able to store your preferences, and some pages may not display properly.
DATA SECURITY
The security of personal information is important to us. We safeguard personal information with physical, electronic, and managerial procedures. In certain areas of our Services, we use industry-standard SSL-encryption to enhance the security of data transmissions. While we strive to protect personal information, we cannot guarantee the security of personal information that we process.
If we become aware of a systems security breach by an unauthorized party or that any user data was used for an unauthorized purpose, we will comply with relevant state and other data breach laws. We will notify users of any breach resulting in unauthorized release of data electronically, at minimum, and without unreasonable delay so that you can take appropriate steps. The notification will include: date of the breach, the types of information that were subject to the breach, general description of what occurred, and steps we are taking to address the breach.
RESPONDING TO DO NOT TRACK SIGNALS
Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers. However, Saela does not track users across apps or websites.
QUESTIONS OR SUGGESTIONS
If you have questions or concerns about our collection, use, or disclosure of your personal information, please email Us at privacy@saelasync.com.
SCHEDULE OF CATEGORIES FOR THIRD PARTY SERVICE PROVIDERS
Cloud Hosting and Storage Providers – for storing user data, backups, and application infrastructure.
Analytics and Data Processing Providers – for processing, analyzing, and aggregating data to improve services and generate trends.
Payment Processors and Billing Providers – for handling subscription payments, invoicing, and refunds.
Communication Providers – for sending emails, push notifications, or other user communications.
Wearable and Device Integration Partners – for collecting health or activity data from connected devices or smart wearables.
Security and Fraud Prevention Providers – for monitoring, auditing, and protecting user data from unauthorized access or misuse.
Professional Services and Consultants – including IT, legal, or research partners that may access data on a need-to-know basis under confidentiality obligations.
Marketing and Customer Support Providers – for supporting user engagement, surveys, or customer support tools.