Privacy Policy

1. Introduction

Holo Technologies Inc. ("Holo Alert," "we," "us," or "our") is committed to protecting your privacy and handling your personal information responsibly. This Privacy Policy explains how we collect, use, disclose, retain, and protect your personal information in compliance with Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA), Alberta's Personal Information Protection Act, and Quebec's Act respecting the protection of personal information in the private sector, where they apply.

This policy applies to our website (www.holoalert.ca), our medical alert devices and monitoring service, our customer support, and our marketing. The Holo Connect mobile app has its own privacy policy.

By using our website, products, or services, you consent to the collection, use, and disclosure of your personal information as described in this policy. Where the law requires your express consent for a particular use, such as promotional emails and text messages (Section 8), we ask for it separately, and you can say no without affecting your service.

Your consent may be express or implied depending on the situation.

Express consent is when you clearly agree (for example, filling out a form, checking a box, replying to a message, or telling us on a recorded call).
Implied consent is inferred from your actions (for example, continuing to use our services after being notified of this policy, or giving us your address so we can ship a device).

We rely on express consent where the law requires it, such as sending you promotional emails or text messages (Section 8). For the online advertising described in Sections 6 and 7, we rely on your implied consent: we tell you about it when we collect your details and in this policy, and you can opt out at any time.

We keep a record of each consent, including the date, how it was given, and the wording you saw.

You can withdraw consent at any time, subject to legal or contractual limitations. Withdrawing consent for marketing never affects your monitoring service. Section 11 explains how.

3. What We Collect

We only collect personal information necessary to deliver, support, and market our services:

Identity & Contact: Name, phone number, email, mailing and shipping address, province
Inquiry Details: When you request information, we may ask who the device is for, your relationship to that person, and a short screening question or two (for example, whether the person has had a fall). We use these answers only to guide our conversation with you.
Emergency Contacts: Names, phone numbers, and email addresses of the caregivers and contacts you designate
Device & Usage Info: Device ID, service activity, alert history, approximate location
Billing Details: Payment method (handled by our payment provider; we do not store full card numbers) and transaction records
Communication Records: Emails, text messages, chat conversations, support interactions, customer feedback, and recordings of phone calls with our team, which are normally recorded with a notice at the start of the call
Health & Safety: Medical conditions, medications, mobility, and other details you or your emergency contacts choose to provide so monitoring operators can help in an emergency
Website & Advertising Data: IP address, browser and device type, pages viewed, clicks, form activity, the page or ad that brought you to us, advertising click identifiers (for example gclid or fbclid), and cookie or pixel identifiers, as described in Section 6
Program Participants: Contact and payout details for referral, affiliate, and partner program participants (Section 14)

4. How We Use It

We use your personal information to:

Deliver and manage your medical alert service, including emergency response
Process payments, ship devices, and send billing and service communications
Provide customer support by phone, email, chat, and text
Respond to your inquiry and follow up with you about it
Send you marketing about our products and offers where you have consented or the law otherwise allows (Section 8)
Show you relevant ads online and measure whether our advertising is working (Sections 6 and 7)
Understand how our website is used so we can improve it
Improve service quality and customer experience
Detect and prevent fraud, abuse, and security threats
Meet legal obligations or respond to lawful requests

We do not sell or rent your personal information.

We share personal information only in the following situations:

Monitoring Partners: Our 24/7 monitoring providers (AvantGuard Monitoring and Affiliated Monitoring) receive the information they need to respond to an alert, including your emergency profile, location, and emergency contacts.
Service Providers: We use trusted third parties to run our business. These include HubSpot (customer records, forms, AI-assisted website chat, and email), Klaviyo (email marketing), Stripe (payments), ShipStation (shipping), Vercel and Supabase (hosting and databases), Sanity (website content), Resend (email delivery), Google Workspace (documents and service agreements), Slack (internal notifications), Cloudflare (bot protection on our forms), CallRail (call tracking and recording), PostHog (website analytics), Tracklution (first-party advertising measurement), Rewardful (referral program), and Make.com (workflow automation that adds advertising campaign and click details from Meta to your customer record). The AI tools we use are described in Section 9. They may use your information only to provide services to us.
Advertising Platforms: Meta (Facebook and Instagram), Google, and Microsoft Advertising receive limited information as described in Sections 6 and 7.
Emergency Services and Your Contacts: In an emergency, we and our monitoring partners share your information with emergency responders and the contacts you designated.
Business Transfers: If we sell, merge, or reorganize our business, or assign customer accounts to a financing partner or successor, your information may be transferred as part of that transaction and remains subject to this policy.
Legal Compliance: We may disclose information when required by law, court order, or government request, or to protect the safety of a person.

All service providers are contractually bound to keep your data secure and confidential and to use it only for the services they provide to us. Advertising platforms also operate as independent companies under their own privacy policies; Section 7 explains what that means for you.

6. Cookies, Tracking Technologies and Analytics

Our website uses cookies, pixels, and similar technologies. A cookie is a small file stored in your browser. A pixel is a small piece of code that tells a service you loaded a page or took an action. We use them to keep the site working, understand how it is used, measure our advertising, and show you relevant ads on other sites.

What we use

Necessary: Keeps your shopping cart, protects our forms from bots (Cloudflare Turnstile), and remembers your cookie choices.
Statistics: Google Analytics, PostHog, Vercel Analytics, and Ahrefs Analytics tell us which pages are visited and how people move through the site. PostHog may also record how a visitor interacts with a page (a "session replay"). Anything you type into a form is masked in these recordings, and we connect a session to a customer record only after a purchase.
Marketing: Google Ads, Meta (Facebook and Instagram), and Microsoft Advertising pixels, together with our first-party tracking server (Tracklution, hosted on our own domain), record visits and actions such as viewing a product, starting checkout, submitting a form, or buying. This lets us measure our ads and show you ads for Holo Alert on those platforms (called remarketing). HubSpot sets a cookie that links your website visits to your inquiry so our care team has context when you contact us.
Call tracking: CallRail shows a different phone number depending on how you found our site and records the number you dialled, your caller ID, and the time and length of the call, so we know which advertising leads to phone calls.
Referral tracking: Rewardful sets a cookie when you arrive through a referral or affiliate link so the person who referred you is credited.

Your choices

When you first visit our site, a cookie banner lets you accept or adjust statistics and marketing cookies. You can change your choice at any time by clearing cookies in your browser, which brings the banner back. Your banner choice controls Google's tags on our site through Google Consent Mode.

You can also opt out of personalized advertising directly with each platform: Google, Meta, Microsoft, and the Digital Advertising Alliance of Canada. These settings are held by the platforms, not by us.

Quebec residents: the technologies described in this section can identify you or build a profile of your interests. We describe them here so you can decide, and the banner and the links above are the means to turn them off.

7. Advertising and Matched Audiences

We advertise Holo Alert on Meta (Facebook and Instagram), Google (Search, YouTube, and partner sites), and Microsoft Advertising (Bing). Besides the cookie-based advertising in Section 6, we use two practices that involve your contact details. We want to be clear about both.

Matched audiences (customer lists)

Unless you opt out, we may share your email address, phone number, name, and postal code with these advertising platforms so they can match you to your account on their service. Before the details leave our systems, they are converted into a scrambled code (a "hash") that cannot be turned back into the original. The platform compares that code against its own users and then deletes codes that do not match.

We use matched audiences to:

Show our ads to people who have asked about Holo Alert or bought from us
Stop showing ads to existing customers ("exclusion" lists)
Ask the platform to find people whose interests resemble our customers ("lookalike" or "similar" audiences), a process in which the platform never tells us who those people are
Measure whether our ads led to inquiries and purchases

We do not share health information, your emergency contacts, your device data, or your payment details with advertising platforms, and we do not use health information you give us to decide who sees our ads.

Conversion measurement

When you submit a form, start a checkout, or buy from our website, our tracking server may send the platform whose ad you clicked a record of that action together with hashed contact details, so the platform can confirm the ad worked. This helps us spend our advertising budget responsibly. Under the platforms' terms, they may also use this measurement data for their own purposes, such as improving their advertising systems, according to their own privacy policies: Meta, Google, and Microsoft.

Your consent and choices

When you give us your contact details to ask about or buy Holo Alert, we treat that as your consent to the advertising uses described in this section, unless you tell us otherwise. Every form on our site links to this policy, and every marketing message we send tells you how to opt out.

You can opt out at any time by emailing privacy@holoalert.ca with "advertising opt-out" in the subject line, by replying to any of our marketing messages, or by telling a care team member. We will remove your details from our matched audiences within 30 days. You may still see our ads as a member of the general public, and you can limit that through the platform controls in Section 6.

Advertising platforms process this information in the United States. Section 12 explains our approach to transfers outside Canada.

8. Marketing Communications: Email, Text Messages and Phone

Email

We send promotional emails only with your consent or where Canada's Anti-Spam Legislation otherwise permits (for example, for a limited time after you make an inquiry or a purchase). Every marketing email identifies us and includes an unsubscribe link that takes effect right away. Service emails such as order confirmations, shipping notices, invoices, and safety notices are not marketing and continue for as long as you are a customer.

Text messages (SMS)

We may send both service-related and promotional SMS messages to users who have expressly opted in. Promotional SMS requires separate consent and can be opted into or out of independently.

SMS consent is not shared with third parties or affiliates for marketing purposes.

You may opt out of SMS communications at any time by replying STOP or contacting us directly. Message and data rates may apply.

Phone calls

If you ask about Holo Alert, a care team member may call you to answer your questions. We respect the National Do Not Call List and our own internal do-not-call list; tell us at any time if you would prefer not to receive calls. Calls with our team, whether you call us or we call you, are normally recorded for training, quality, resolving disputes, and keeping a record of the consent you give us. When a call is recorded, you will normally hear a recorded notice at the start. If you do not hear one and want to know whether the call is being recorded, just ask the care team member.

9. AI and Automation Tools

We use AI-based tools and automation platforms (such as Make.com, and the AI-assisted chat on our website provided through HubSpot) to:

Automate repetitive tasks, such as adding advertising campaign and click details to your customer record
Answer common questions in our website chat, with a care team member able to take over at any time
Draft and organize customer communications, which our team reviews
Analyze patterns to improve support and service quality

These systems may process limited personal data such as names, contact history, or service preferences. No decision about your eligibility, pricing, or emergency response is made by automated means alone.

All automation is monitored by our team, and safeguards are in place to ensure compliance with Canadian privacy standards.

10. Data Storage, Security and Retention

Our systems and service providers store and process personal information in Canada and the United States. Section 12 has more on transfers outside Canada.

We retain a record of consent, including timestamp, method of collection, and source (for example, online form, phone request), for compliance and audit purposes.

How long we keep it

Customer accounts: for as long as you are a customer and for up to seven years afterward, as required for tax, accounting, and legal purposes
Inquiries and leads: if you do not become a customer, we delete or anonymize your details 24 months after our last interaction with you. We stop marketing to you sooner when the law requires it.
Consent and unsubscribe records: for as long as we contact you and for three years afterward, so we can prove consent and continue to honour opt-outs
Abandoned checkout records: up to 24 months (Section 16)
Call recordings: for as long as you are a customer. If you do not become a customer, for the same period as your inquiry record.
Website session recordings: up to six months
Analytics data: according to each provider's retention settings, which we keep at the shortest setting that meets our needs

How we protect it

We protect your data using:

Data encryption
Role-based access control
Secure backups
Ongoing security monitoring

Despite best efforts, no system is entirely secure. We continually assess and improve our security practices. If a breach creates a real risk of significant harm to you, we will notify you and the appropriate privacy regulator as the law requires.

11. Your Rights

You have the right to:

Access: See what personal data we have about you
Correct: Fix incorrect or outdated information
Withdraw: Limit or revoke consent for certain uses, including marketing and matched-audience advertising
Delete: Request deletion of your personal data where possible
Port: Ask for a copy of the information you gave us in a structured, commonly used format (a right of Quebec residents that we extend to all our customers)
Complain: Raise a concern with our Privacy Officer and, if you are not satisfied, with a privacy regulator (Section 18)

Contact us at privacy@holoalert.ca to make a request. We may require ID verification. We respond within 30 days, or tell you if we need more time. There is never a charge for withdrawing consent or opting out of marketing.

12. Cross-Border Transfers

Some of our service providers and advertising platforms are located in the United States, so your personal information may be processed or stored there. While in another country, it may be accessible to that country's courts and authorities under its laws. We choose reputable providers, assess how they protect personal information, and use contracts that require them to safeguard it to Canadian standards. Where required, we complete a privacy impact assessment before transferring personal information outside Quebec.

13. Emergency Contacts and Other People's Information

When you give us another person's information, such as an emergency contact or the person who will wear the device, you confirm that you have their permission to share it with us. We use emergency contact details only to reach them in an emergency, to send them service documents you have asked us to send, and to keep their information current. Emergency contacts can ask us at any time to see or remove their details by contacting privacy@holoalert.ca.

14. Referral, Affiliate and Partner Programs

If you join our referral or affiliate program, we collect your name, contact details, and payout information through Rewardful to track referrals and pay rewards. If you arrive at our site through a partner or referral link, we record that so the partner is credited. The partner does not receive your personal information from us unless you provide it to them directly.

15. Children's Privacy

Our services are not intended for individuals under 16. We do not knowingly collect data from minors. If we learn we have collected data from a child without parental consent, we will delete it.

16. Abandoned Checkout Reminder Emails

If you begin an online checkout and enter your email address but do not complete your order, we may send you up to three reminder emails over the following three days with a link to finish your order. We treat starting a checkout as an inquiry about our services, which allows follow-up messages under Canada's Anti-Spam Legislation for six months; in practice, our reminders stop within 72 hours of your last checkout activity.

Every reminder includes an unsubscribe link. Unsubscribing takes effect immediately and is permanent: starting another order later will not restart these reminders. Order confirmations and account emails are not affected.

For this purpose we keep a record of your checkout activity (the products selected, your contact details, and the time of your visit) and of any unsubscribe request. Abandoned checkout records are kept for up to 24 months. Records of unsubscribe requests are kept indefinitely so we can continue to honour them, and records showing how a message came to be sent are kept for at least three years to meet our legal obligations.

These reminders are sent by Holo Technologies Inc., 10180 101 St NW #3400, Edmonton, AB T5J 3S4. If you have questions about them, contact support@holoalert.ca or 1-888-411-4656.

17. Changes to This Policy

We may update this policy to reflect changes to our practices or legal requirements. We encourage you to check back regularly. When changes are made, the "Last Updated" date at the top will be revised. If a change materially affects how we use your personal information, we will post a notice on our website and, where the law requires, tell you directly.

18. Contact Us and Our Privacy Officer

Our Privacy Officer is responsible for how we handle personal information and for this policy. For privacy-related questions, requests, or complaints, please contact:

Privacy Officer, Holo Technologies Inc., Suite 3400, 10180 101 St NW, Edmonton, AB T5J 3S4

Email: privacy@holoalert.ca (for account and service questions, support@holoalert.ca)

Phone: 1-888-411-4656

Website: www.holoalert.ca

We acknowledge every complaint, look into it, and reply in writing, normally within 30 days.

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada, 30 Victoria Street, Gatineau, Quebec, K1A 1H3, at www.priv.gc.ca or 1-800-282-1376. Quebec residents may also contact the Commission d'accès à l'information du Québec at www.cai.gouv.qc.ca. Alberta residents may contact the Office of the Information and Privacy Commissioner of Alberta at www.oipc.ab.ca.

19. Final Provisions

If any part of this policy is found invalid, the rest remains enforceable. By using our services, you acknowledge that you have read, understood, and agree to this policy.