Privacy Policy
Last Updated: September 2026
Overview
The App4Independence (A4i) respects an individual’s privacy and will only collect, use and disclose personal information in accordance with its Privacy Policy. We recognize every individual’s right to privacy and acknowledge our obligation to preserve the confidentiality of personal information.
This Privacy Policy applies to The App4Independence (A4i) and governs how we handle personal information during your participation in the program.
A4i reserves the right to update its Privacy Policy at any time and such modifications shall be effective immediately unless otherwise stated.
Legal Framework
This Privacy Policy is designed to support compliance with applicable privacy and data-protection requirements, which may include the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws in Canada, the Health Insurance Portability and Accountability Act (HIPAA) where applicable in the United States, and other applicable federal, provincial, or state requirements.
What Information We Collect and Why
We only collect information needed to provide and improve our services. Below we describe the categories of personal information, their purposes, and examples of what is collected.
- To Provide Our Services and Support Your Account
Legal basis: Performance of Contract/Legal Obligation
We collect this information to create and manage your account, confirm your identity, and communicate with you when needed. Some of this information is also collected to meet security or legal requirements
Data collected:- Contact information: such as full name, email and phone number to create your account and send you communications
- Device information: such as device identifiers and operating system, to facilitate login and ensure software support and compatibility
- Time zone selection: to schedule notifications, reminders and content at the right local time
- To Personalize Your Experience
Legal basis: Consent / Legitimate Interest
We use your input to tailor services provided by the application and your app experience, including feed content, recommendations, and communications.
Data collected:- Health information: such as medication details, symptoms, sleep quality, appointment details and notes you provide
- Activity data: such as goals tracked, survey answers, wellness check-ins, journal reflections, feed contributions and sound recordings
- To Improve and Maintain the App
Legal basis: Legitimate Interest
We use technical and usage data to understand how the app works and to make it better for everyone.
Data collected:- Device data: such as device model, operating system, app identifiers, crash reports
- Event and usage data: such as which features you use, frequency and duration of use, navigation patterns
- Approximate location via IP address, for analytics and performance monitoring
De-identified Information
A4i de-identifies information using the HIPAA Safe Harbor methodology. De-identified information may be retained and used internally for purposes such as service evaluation, quality improvement, analytics, and product improvement. A4i does not use participant data for scientific research or provide participant data to third parties for independent research purposes.
Consent and Legal Basis for Data Collection
A4i will make a reasonable effort to ensure individuals understand how their personal information will be used. We rely on several lawful bases under data protection law:
- Consent – when you actively provide health information or use optional features that require consent.
- Performance of Contract – when data is needed to create, maintain, and support your account and provide you with the core A4i services.
- Legal Obligation – when we are required to retain or share certain information for security, compliance, or regulatory reasons.
- Legitimate Interest – when we analyze app usage, ensure technical performance, or enhance user experience in a way that does not override your rights or freedoms.
We will collect, use, or disclose personal information without consent only where permitted or required by law.
An individual’s consent may vary from express written consent (during account set up) to implied consent (continued use of the application). We will collect, use or disclose personal information without consent, only where permitted or required by law.
We collect different types of information depending on what’s needed to provide you with the A4i app. Some information is essential for creating your account, keeping the app secure, and making sure core features work properly. Other information is optional and is only collected if you choose to use specific features, such as medication reminders, posting to the feed, or wearable integrations.
The table below explains the categories of data we collect, why we collect them, and whether they are essential or optional.
Data Collection Categories
| Category | Examples of Data Collected | Purpose | Essential or Optional |
|---|---|---|---|
| Account & Security | Mobile number, email, login credentials, IP address | To create and manage your account, confirm identity, and keep the app secure | Essential |
| Core Functionality & Support | Timezone preference, device information, crash logs, usage data | To deliver services (e.g., reminders at the right time), ensure app performance, and provide support | Essential |
| Personalization & Analytics | Interaction data, feature usage patterns, general engagement | To improve app experience, understand which features are most useful, and enhance services | Essential |
| Feature-Specific Data | Medication details (for reminders), posts to the feed, journal entries, health surveys, sleep tracking, wearable data | To provide optional features that you choose to use (e.g., reminders, community engagement, self-tracking) | Optional Collected only if you use these features |
Some information is essential for the A4i app to function. This includes data needed to create and maintain your account, ensure security, and deliver core services. Because this information is necessary, you cannot opt out of its collection and still use the application.
Other types of information are optional and are only collected if you choose to use certain features (for example, entering medication details for reminders or posting to the feed). If you do not wish to provide this information, you can simply choose not to use those features.
You may also stop receiving communications from A4i entirely by uninstalling the app from your device.
Policy Updates and Changes in Purpose
If we change the way we collect or use your personal information, we will update this Privacy Policy and notify you in advance through the app or by email.
If the change involves a new purpose or a different legal basis (for example, moving from “performance of contract” to “consent”), we will ask you to review and, where required, provide consent again before the new use begins.
If you do not agree to the updated terms, you may choose not to continue using the app or withdraw your consent at any time.
Your Rights Regarding Your Data
Depending on your location and applicable law, you may have certain rights in relation to your personal information, including:
- Right of Access – You can request a copy of the personal information we hold about you
- Right to Rectification – You can ask us to correct or update inaccurate or incomplete information.
- Right to Erasure – You can request that we delete your personal information where it is no longer needed, or withdraw your consent where processing is based on consent.
- Right to Restrict Processing – You can ask us to limit how your information is used in certain circumstances.
- Right to Data Portability – You can request a copy of your information in a commonly used format so you can transfer it to another service.
- Right to Object – You can object to our processing of your information when it is based on legitimate interests, or to receiving direct communications.
- Right to Withdraw Consent – Where we rely on your consent (for example, for optional features), you can withdraw that consent at any time.
- Right to Lodge a Complaint – You have the right to lodge a complaint with your local data protection authority if you are unhappy with how we handle your information.
To exercise any of these rights, please contact us at privacy@a4i.me. We will respond in accordance with applicable data protection laws and within required timeframes.
Children’s Privacy
The A4i app is intended for use by adults only. If you believe that a child under the age of 13 has accessed the app and provided personal information without parental or guardian consent, please notify us immediately. You can report this by contacting our Privacy Officer at privacy@a4i.me. We will take prompt steps to remove the child’s information from our systems in accordance with applicable law.
Data Storage and Transfer Security
We take the protection of your data seriously and apply multiple layers of security to safeguard it during storage and transfer.
Database Security
User account passwords are securely hashed using bcrypt and are not stored in plaintext. Access to the database requires valid authentication and is restricted to authorized systems and personnel. Other user data is stored in our secure database environment.
Data in Transit
All data exchanged between the mobile app, our portal, and servers is encrypted in transit using TLS 1.3. This includes traffic from your device to our load balancer and onward to our production servers, ensuring your information is protected from interception during transfer. The mobile app never communicates directly with the database, instead communications are routed securely through the portal application.
Infrastructure Protections
The A4i platform is hosted on Amazon Web Services (AWS), with program data stored in the applicable geographic region based on the client and implementation. Canadian client data is hosted in the AWS Canada region, while U.S. client data is hosted in an AWS U.S. region.
Data at rest is encrypted using AES-256. Administrative access is restricted to authorized personnel based on role, business need, and least-privilege principles. Administrative accounts are individually identifiable and subject to appropriate authentication and access controls. Systems maintain audit and security logging to support security monitoring, investigation, and accountability.
Security Incident Response
A4i maintains documented security incident and data breach response procedures. Suspected security incidents are investigated and addressed in accordance with established incident response procedures. Where client or participant information may have been affected, applicable clients and other parties are notified in accordance with contractual and legal requirements.
Data Retention and Deletion
A4i is a platform used across different programs and implementations, which may have different program durations and data-retention requirements. The applicable program end point, retention period, and data disposition requirements are established for each implementation through the applicable client agreement and applicable legal or regulatory requirements.
In accordance with these requirements, information retained in de-identified form is de-identified using the HIPAA Safe Harbor methodology. Identifiable information is securely deleted when it is no longer required. De-identified information may be retained for the internal purposes described in this Privacy Policy.
Limiting Collection, Use, Disclosure and Retention
A4i limits the collection of personal information, both the amount and the type of information, to that which is necessary for the purposes identified by A4i. A4i collects personal information by fair and lawful means and for purposes that a reasonable person would consider appropriate in the circumstances.
A4i will not use or disclose personal information for purposes other than those for which it was collected for A4i, except with the consent of the individual or as required or permitted by law.
A4i does not sell, license, or otherwise monetize participant data, whether identifiable or de-identified, and does not provide participant data to unrelated third parties for their independent commercial purposes.
A4i may disclose personal information where required or permitted by applicable law, including in response to a valid subpoena, warrant, court order, or other lawful request from a government authority.
Accountability
MEMOTEXT, owner of A4i Inc., is responsible for personal information under its control and has designated a Privacy Officer who is accountable for this Privacy Policy and applicable governing laws. The Privacy Officer may be contacted as follows:
Privacy Officer, MEMOTEXT
Charles Yoon
326 Rushton Road
Toronto, Ontario
M6C 2X9
1-877-636-6838
privacy@a4i.me
Safeguards
A4i protects personal information using technical, administrative, and organizational safeguards appropriate to the sensitivity of the information. These safeguards are designed to protect information against unauthorized access, disclosure, use, modification, loss, or destruction.
Access to personal information is restricted to authorized personnel with a legitimate business need and is subject to appropriate authentication and access controls. A4i uses encryption, logging and monitoring, access controls, and other security measures as described in the Data Storage and Transfer Security section above.
Personal information is retained only for the period required to fulfill the applicable purposes and contractual, legal, or regulatory requirements, after which it is de-identified or securely deleted in accordance with the applicable retention requirements.
Openness
A4i will make available to individuals specific information about its policies and practices relating to the management of personal information. All questions or inquiries about this Privacy Policy or our personal information management practices are to be directed to our Privacy Officer.
Individual Access
Upon request, A4i will inform an individual of the existence, use, and disclosure of their personal information and provide access to that information, except where access is not required or permitted by applicable law. Individuals may request correction of personal information that is inaccurate or incomplete.
Third-Party Links
The A4i app may contain links to third-party websites or services that are not operated or controlled by A4i. If you follow a link to a third-party website or service, any personal information you provide will be subject to that third party’s privacy practices and policies. A4i is not responsible for the privacy practices, content, or operation of third-party websites or services.
Challenging Compliance
Any questions about our Privacy Policy are to be directed to our Privacy Officer. We will inform individuals who make inquiries or lodge complaints about our procedures, and we will investigate all inquiries or complaints. We will notify the complainant of the outcome of the investigation and any relevant steps taken to rectify the issue, including any amendments to our policies and procedures.