Privacy Policy

1. Introduction — Who We Are and Scope

This Privacy Policy explains how Sahlware LLC, the company that provides the ANDITO service ("ANDITO," "we," "us," or "our"), collects, uses, discloses, and protects personal information. ANDITO is an ambient AI caregiving assistant designed for a family caregiver to help monitor a bed-ridden adult with dementia ("the monitored person") in a home setting. The Service uses a webcam connected to a home device, on-device artificial-intelligence vision processing, a caregiver dashboard, and text-message (SMS) notifications (together, the "Service").

This Policy applies to individuals who create an account and use the Service (each, a "Caregiver," "you," or "your"), to visitors of the ANDITO product site at https://andito.sahlware.com, and to the personal information we process about the monitored person on your behalf. It does not apply to third-party websites, products, or services that we do not control.

Because the Service processes information about a person's health and daily condition, we also publish a separate Consumer Health Data Privacy Policy at https://andito.sahlware.com/consumer-health-data. It describes, in more detail, the health-related information the Service collects, how we obtain your consent, and the rights you have over that information. Where the two documents overlap, the Consumer Health Data Privacy Policy controls for consumer health data.

By creating an account, installing the home device software, or otherwise using the Service, you acknowledge that you have read and understood this Policy. Your use of the Service is also governed by our Terms of Service at https://andito.sahlware.com/terms, which are incorporated here by reference.

This Policy is written for consumers in the United States. Section 9 describes state-specific and international rights.

2. Information We Collect

We collect the following three categories of information.

2.1 Caregiver Account Data

When you register for and use the Service, we collect information you provide directly:

• Name
• Mobile phone number (used to deliver SMS safety alerts and daily summaries — see Section 4)
• Email address (used to sign in and for account communications such as sign-in confirmation and password reset)
• Password (stored only in salted, hashed form — we never store your password in plaintext)
• Your consent choices (which notices you accepted, when, and from which network address — see Section 7)

2.2 Patient Monitoring Data

To provide the core caregiving function, the Service generates and stores, on your behalf and about the monitored person:

• AI observations — structured text descriptions, produced on the home device, of what appears to be happening in the monitored space: for example, whether the monitored person appears to be in bed, their approximate position and activity, their apparent mood, whether other people are present, and how confident the system is in each observation. These are text and numeric labels, not images.
• A small number of still snapshots each day — no more than five per day, kept only if they pass the fail-closed privacy safeguards described in Section 5. These snapshots may show a monitored, vulnerable adult and are treated as sensitive information.
• Your feedback on observations (for example, marking an observation as correct or incorrect) and your acknowledgement of alerts.

Raw, continuous video is never stored — not on our servers, not in the cloud, and not by any third party. See Section 5.

2.3 Device, Usage, and Log Metadata

We automatically collect limited technical information necessary to operate, secure, and troubleshoot the Service: home-device identifiers, software version, connection and heartbeat status, event, sync, and alert timestamps, dashboard sign-in activity, IP address, browser and device type, and diagnostic or error logs (configured to exclude image content and sensitive personal data).

2.4 Notice at collection (summary)

We do not sell personal information, do not share it for cross-context behavioral advertising, and do not use it for advertising of any kind.

3. How We Use Information

We use the information above only to provide, secure, and improve the Service, specifically to: create and maintain your account and authenticate dashboard access; run in-home AI analysis and generate the observations and snapshots that populate your timeline; send transactional safety alerts, daily summaries, and service messages by SMS (Section 4); send account emails such as sign-in confirmation and password reset; detect, investigate, and respond to safety-relevant events; operate, maintain, secure, debug, and improve the Service; keep records of your consent choices and privacy requests; and comply with legal obligations and enforce our Terms of Service.

We do not use Patient Monitoring Data or your contact information for advertising, and we do not sell personal information. See Sections 4 and 9.

No AI training on your household's data. We do not use Patient Monitoring Data (observations, snapshots, or your feedback) to train general-purpose AI models, and we do not permit our service providers to do so. If this ever changes, we will update this Policy, tell you before the change takes effect, and obtain any consent the law requires.

4. Mobile / SMS Messaging

This section describes how we collect and use mobile phone numbers and SMS consent.

How we collect your number and consent. We collect your mobile phone number when you provide it during account setup or in your account settings, and you opt in to receive SMS messages from ANDITO by checking a separate, unchecked box. Providing a number is optional: the Service works without one, but you will not receive text alerts or summaries.

How we use your number. We use your mobile phone number to send you:

• transactional safety alerts — for example, a notification when the Service detects a safety-relevant event involving the monitored person;
• daily summaries — a short morning and evening text describing what happened, at the times you choose; and
• service messages about your account and the operation of the Service, such as a device-offline notice.

These are non-marketing, service-based messages central to the caregiving function you signed up for. Message frequency varies with monitored events: typically up to two summary texts per day plus alerts as they occur. Message and data rates may apply.

No marketing sharing or sale of mobile data.

Mobile information and SMS opt-in/consent are NOT shared with third parties or affiliates for their marketing purposes. No mobile information will be sold or shared with third parties for marketing or promotional purposes.

Service-provider sharing (delivery only). We share your mobile phone number only with our SMS delivery provider, acting as our service provider strictly to transmit the messages you have requested. That provider is contractually restricted to using this information solely to deliver our messages on our behalf and may not use it for its own purposes.

Opt-out and help. You can opt out of SMS messages at any time by replying STOP to any message from us; you will receive a confirmation and we will stop sending SMS messages to that number. You can also remove your number in Settings. Reply HELP for assistance, or contact us at privacy@sahlware.com. Opting out of SMS turns off text alerts and daily summaries; you can still review events on the dashboard.

5. How We Protect the Monitored Person's Privacy

ANDITO is designed to be privacy-preserving and fail-closed: when the Service is unsure whether something is appropriate to keep, it discards it.

Video is analyzed in your home. The camera feed is analyzed by AI software running on the device in your home. Camera images are not sent to us or to any third party for analysis. The only information that leaves your home is the text observations described in Section 2.2 and the limited snapshots described below.

Video only — no audio. ANDITO captures video only. No audio is recorded, transmitted, or stored.

No recorded footage. The Service does not record, transmit, or store continuous video. There is no video archive anywhere: not on the home device, not in our systems, and not with any third party.

Fail-closed snapshots. A still snapshot is kept only when our automated privacy checks positively confirm that the image is appropriate to keep and shows the expected care scene. If any check is uncertain, fails, or cannot run, the image is treated as private and discarded. No more than five snapshots are kept per day.

If this ever changes. If we change the Service so that camera images are analyzed outside your home, or so that more images are kept than described here, we will tell you before the change takes effect and ask for your consent where the law requires it (see Section 12).

6. Service Providers / Processors We Share With

We do not sell personal information and we do not share it with third parties for their own marketing. We share limited information with vetted service providers ("processors") who process it only on our behalf, under contract, and only to provide the Service:

Each processor is contractually bound to protect the information, to use it solely to perform services for us, and not to use it for their own marketing, to train their own AI models, or for other independent purposes. We keep a current list of these service providers and will give it to you on request at privacy@sahlware.com. We have no affiliates with whom we share personal information.

We may also disclose information (a) to comply with law, legal process, or lawful government requests; (b) to protect the rights, safety, or property of ANDITO, our users, the monitored person, or the public; or (c) in connection with a merger, acquisition, financing, or sale of assets, in which case we will require the recipient to honor this Policy and will notify you of any material change.

7. Sensitive Data, Consent, and Caregiver Responsibility

The Service processes information about a vulnerable adult, including still snapshots that may show the monitored person and observations about their health and daily condition. We treat this as sensitive information and as consumer health data, and we apply heightened safeguards, including the fail-closed checks and data minimization described in Section 5.

Your consent. Before monitoring begins, we ask you to give specific, separate consent to the collection of the monitored person's consumer health data. This consent is not bundled into the Terms of Service and is not pre-checked. We record what you consented to, the version of the notice you saw, the time, and the network address the consent came from. You may withdraw consent at any time as described in Section 9; withdrawing consent ends monitoring.

Your responsibility and authority. By using the Service to monitor another person, you represent and warrant that you have the legal right and authority to do so — for example, as the individual's legal guardian, health-care agent, or power-of-attorney holder, or with the individual's informed consent where they are able to give it — and to consent to this processing on their behalf, consistent with applicable law. You are responsible for camera placement, for informing others in the home as required, and for lawful use of the monitored data. These obligations are described further in our Terms of Service (https://andito.sahlware.com/terms).

Not a medical device; not HIPAA. ANDITO is a consumer wellness and safety-awareness tool. It is not a medical device, and Sahlware LLC is not a HIPAA covered entity or business associate.

8. Data Retention and Deletion

We retain personal information only as long as necessary for the purposes described in this Policy. Retention is enforced automatically by a daily job, not left to manual clean-up.

Deleting your account and data. You can delete your account at any time from Settings → Account → Delete account, or by emailing privacy@sahlware.com. Deleting your account permanently removes the monitored person's observations, snapshots, alerts, and feedback; the household's device registrations; your name, phone number, email address, and consent records; and your sign-in. We also instruct our service providers to delete the information they hold for you (for example, the delivery records of text messages sent to your number).

How long deletion takes.

• In-product deletion takes effect immediately in our live systems.
• Emailed requests are acknowledged within 10 business days and completed within 45 days of receipt. If a request is unusually complex we may take up to 45 additional days, and we will tell you why before the first 45 days end.
• Backup copies expire within 30 days after deletion from live systems and are never restored to production.

We honor verified deletion requests except where we are required or permitted by law to retain specific information (for example, a record that the deletion request itself was received and completed).

9. Your Privacy Rights

9.1 Rights we honor for everyone

Wherever you live, you may ask us to:

• Confirm whether we process personal information about you or the monitored person, and access it;
• Correct inaccurate account information (you can edit most of it in Settings);
• Delete your account and the associated personal information (Section 8);
• Withdraw consent to the collection of the monitored person's consumer health data (which ends monitoring);
• Receive a list of the service providers with whom we share personal information; and
• Appeal a decision if we decline a request.

How to make a request. Use the controls in Settings, or email privacy@sahlware.com from the email address on your account. You may also make a request through an authorized agent who provides your signed permission.

How we verify requests. For requests made in the product, being signed in is the verification. For emailed requests, we verify by matching the sending address to the account and confirming through a reply to that address; we may ask for one additional piece of account information if the match is unclear. We never ask for your password.

Timing. We acknowledge requests within 10 business days and respond within 45 days of receipt. We may extend once by 45 days when reasonably necessary and will tell you before the first period ends. We do not charge for requests unless they are manifestly unfounded or excessive.

Appeals. If we decline all or part of a request, we will explain why and how to appeal. Send an appeal to privacy@sahlware.com with "Appeal" in the subject line. We will respond in writing within 45 days with the outcome and, if we deny the appeal, how to contact your state attorney general (for Washington residents: https://www.atg.wa.gov/file-complaint).

No discrimination. We will not deny you the Service, charge a different price, or provide a different level of service because you exercised a privacy right.

9.2 California Residents (CCPA/CPRA)

In addition to the rights above, California residents have the right to know the categories and specific pieces of personal information we collect, the sources, our purposes, and the categories of third parties with whom we share it (Sections 2, 3, and 6 provide this information). We do not sell personal information and do not share it for cross-context behavioral advertising, so there is no "Do Not Sell or Share" choice to make; we honor Global Privacy Control signals as a request to opt out where one is received. We use sensitive personal information (including monitoring images and health-related observations) only to provide the Service you requested and not to infer characteristics for advertising, so no "Limit the Use of My Sensitive Personal Information" choice is required. Section 2.4 serves as our notice at collection.

9.3 Washington Residents (My Health My Data Act)

The monitoring data the Service collects about the monitored person is "consumer health data" under Washington's My Health My Data Act. Our Consumer Health Data Privacy Policy at https://andito.sahlware.com/consumer-health-data describes the categories of consumer health data we collect and why, the sources, what we share and with whom, how we obtain your consent, and how to exercise your rights to confirm, access, delete, withdraw consent, and appeal. We do not sell consumer health data, and we do not share it with third parties or affiliates other than the service providers described in Section 6.

9.4 Other U.S. State Residents

Residents of other states with comprehensive privacy laws (for example, Virginia, Colorado, Connecticut, Utah, Texas, and Oregon) and of states with consumer health data laws (for example, Nevada and Connecticut) have rights similar to those in Section 9.1. We honor these rights for everyone, whether or not a particular law applies to us. Contact privacy@sahlware.com.

9.5 EU / UK Residents (GDPR / UK GDPR)

ANDITO is offered to consumers in the United States and does not currently target users in the EEA, the UK, or Switzerland. If those laws nevertheless apply to you, our legal bases are performance of our contract with you, your consent (withdrawable), our legitimate interests in operating a safe and reliable Service, and compliance with legal obligations. You may have rights to access, rectify, erase, restrict, port, and object, and to lodge a complaint with your supervisory authority.

10. Security

We implement technical and organizational measures designed to protect personal information, including: in-home analysis that keeps video in your home; encryption in transit and at rest; access controls that limit each caregiver to their own household's data; salted-and-hashed password storage; a private, access-controlled store for snapshots served only through short-lived, caregiver-specific links; least-privilege access for systems and service accounts; and records of privacy requests and account deletions. No method of transmission or storage is completely secure; we cannot guarantee absolute security. If we become aware of a breach affecting your personal information, we will notify you and the appropriate authorities as required by applicable law.

11. Children's Privacy

The Service is intended for use by adults (18+), is not directed to children under 18, and we do not knowingly collect personal information from children under 18 as account holders. The Service is designed and offered to monitor an adult, not a minor. If you believe a child's personal information has been provided to us in violation of this Policy, contact privacy@sahlware.com and we will take appropriate steps to delete it.

12. Changes to This Policy

We may update this Policy from time to time. When we make material changes, we will update the "Version" and "Effective date" above and give you notice in advance by email or in the product. Where a change would expand how we collect, use, or share consumer health data, we will ask for your renewed consent before it takes effect. Your continued use of the Service after a non-material update takes effect constitutes acceptance of the revised Policy.

13. Contact Us

• Sahlware LLC · 33819 NE 52nd Way, Carnation, WA 98014
• Email: privacy@sahlware.com · Website: https://andito.sahlware.com (company site: https://sahlware.com)