SoloMio Privacy Policy

Effective Date: May 25, 2026 
Last Updated: May 25, 2026

17402198 CANADA INC. (operating as SoloMio or SoloMio Health) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use the SoloMio mobile app, website, and related services (the “Services”).

SoloMio is a wellness and self-care platform. We provide personalized, AI-generated recommendations focused on movement, sleep, stress management, and recovery. The Services are not a medical service and do not collect, use, or disclose personal health information in the clinical or medical sense.

By using the Services, you consent to the practices described in this Policy.

1. Who We Are & Accountability
17402198 CANADA INC.
200 Bridgeland Avenue
Toronto, Ontario, Canada

We are accountable for personal information under our control. If you have questions or complaints, contact our Privacy Officer at mio@solomiohealth.com.

This Policy is designed to comply with Canada’s PIPEDA (Personal Information Protection and Electronic Documents Act) and applicable U.S. state privacy laws (including CCPA/CPRA for California residents where we meet thresholds).

2. Information We Collect
We collect only the information necessary to deliver and improve the Services.Information You Provide Directly
- Account details (email address, name, password)
- Profile and wellness information (age range, wellness goals, self-reported preferences)
- Responses to onboarding questions and AI chat interactionsInformation from Wearable Devices & Third-Party Integrations 
- When you connect Apple Health, Garmin, Oura, Samsung Health, or other platforms, we receive biometric and activity data such as: Heart rate variability (HRV), sleep metrics, activity levels, recovery scores, and related wellness signals
- We do not access your full medical records or clinical health data.Automatically Collected Information
- Device information, IP address, operating system, app version
- Usage data (features used, time spent, interactions with recommendations)
- Cookies and similar technologies for analytics and functionality (you can manage these in your device settings)Information from Others
- We may receive aggregated or de-identified insights from service providers to improve our AI models.

3. How We Use Your Information
We use your information for the following purposes:
- Deliver the Services - Generate personalized AI wellness recommendations and adaptive plans (our core “intelligence layer”).
- Improve & Train Our AI - Use aggregated and de-identified data to refine the recommendation engine, reinforcement learning models, and overall platform performance. We minimize use of identifiable data for training.
- Personalization & User Experience - Tailor insights, notifications, and coaching to your goals and biometric trends.
- Analytics & Product Development - Understand how users engage with the app to improve features.
- Security, Fraud Prevention & Legal Compliance - Protect the platform and meet legal obligations.
- Communications - Send important service updates (you may opt out of marketing emails).

We do not use your personal information to make automated decisions that produce legal or similarly significant effects.

4. How We Share Your Information
We do not sell
your personal information.
We may share
information in these limited circumstances:
- Service Providers - Trusted vendors (cloud hosting such as AWS, AI model providers, analytics tools, email services) that help us operate the Services. They are contractually bound to protect your data and use it only for our purposes.
- Aggregated / De-identified Data - We may share anonymized trends or insights (e.g., “users with similar HRV patterns respond well to X”) that cannot reasonably identify you.
- Legal Requirements -  When required by law, court order, or to protect rights and safety.
- Business Transfers - In the event of a merger, acquisition, or sale of assets (you would be notified). 

We do not share identifiable biometric or wellness data with third parties for their own marketing purposes.

5. Your Rights & Choices
You have the following rights regarding your personal information:
- Access & Portability - Request a copy of the personal information we hold about you.
- Correction - Ask us to correct inaccurate or incomplete information.
- Deletion - Request deletion of your account and associated data (subject to legal retention requirements).
- Withdraw Consent - Disconnect wearable integrations or delete your account at any time.
- Object to Processing - Request that we stop using your data for certain purposes (e.g., AI model improvement).
- Opt-out of Marketing - Unsubscribe from promotional emails via the link in each message.
- For California residents - You may have additional rights under the CCPA/CPRA, including the right to know what personal information we collect, delete it, and opt-out of any “sale” or “sharing” (we do not sell or share personal information for cross-context behavioral advertising).

To exercise any right, email mio@solomiohealth.com. We will respond within the timelines required by applicable law (generally 30 days for PIPEDA requests).

6. Data Security
We use reasonable administrative, technical, and physical safeguards to protect your information against loss, theft, and unauthorized access. This includes encryption in transit and at rest for sensitive data, access controls, and regular security reviews.

No method of transmission or storage is 100% secure. You are responsible for keeping your account password confidential.

7. Data Retention
We retain your personal information only as long as necessary to provide the Services, fulfill the purposes outlined in this Policy, or comply with legal obligations.

When you delete your account, we will delete or anonymize your personal information within a reasonable period, except where we are required to retain it (e.g., for legal or safety reasons).

8. International Data Transfers
Your information may be processed and stored in Canada and the United States (our primary cloud infrastructure and some AI service providers are located there).

When we transfer personal information outside Canada, we use appropriate safeguards (such as contractual clauses) and remain accountable under PIPEDA for the protection of your data.

9. Children’s Privacy
SoloMio is not intended for individuals under 18 years of age (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately so we can delete it.

10. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting the new Policy in the app, on our website, or by email. Your continued use of the Services after the effective date of any changes constitutes acceptance of the updated Policy.

11, Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact:

Privacy Officer
17402198 CANADA INC. (operating as SoloMio)
200 Bridgeland Avenue
Toronto, Ontario, Canada
Email: mio@solomiohealth.com

You may also file a complaint with the Office of the Privacy Commissioner of Canada (www.priv.gc.ca) or your local privacy regulator.

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Full Terms of Use are available in the app settings and at our website www.SoloMioHealth.com  This Privacy Policy works together with our Terms of Use and Medical Disclaimer. By using SoloMio, you acknowledge that you have read and understood this Policy.