Privacy Policy

Trusted Life Circle, Inc.

Last Updated: May 28, 2026

Effective Date: May 28, 2026

1. Introduction

Trusted Life Circle, Inc. (“TLC,” “we,” “us,” or “our”) provides a private communication platform for families and caregivers supporting a loved one with cognitive challenges. This Privacy Policy explains what personal information we collect, how we use it, how we share it, and the choices and rights you have.

This Policy covers the Trusted Life Circle mobile application and the website at tlcapp.io (collectively, the “Service”). By using the Service you accept the practices described here.

2. Definitions

Capitalized terms not defined here have the meanings in our Terms of Service.

• “VIP” — the central member of a Circle, typically a person with cognitive challenges.
• “Guardian” — a User who administers a Circle.
• “Contributor” — a User who participates in a Circle.
• “Circle” — a private group of Users centered around a VIP.

3. Information We Collect

Accessibility settings and cognitive-support preferences are used solely to personalize the user experience and support caregiver-directed configuration.

a. Information you give us directly:

• Account information: name, email address, phone number (for SMS verification), date of birth (where required), authentication credentials (passwords or passkey public keys), profile photo.
• Payment information when you subscribe — processed by Apple, Google, or Stripe. We do not store full payment-card numbers.
• Communications you send to support, in feedback, or through inquiry forms.
• User Content: photos, videos, messages, captions, voice clips, and other media you submit to a Circle.
• Information about the VIP that Guardians or Contributors provide, which may include the VIP’s name, image, voice, relationship to other Users, and references to the VIP’s health, cognition, mood, or care.

b. Information collected automatically when you use the Service:

• Device information: device type, operating system version, app version, language, time zone, mobile carrier, screen resolution.
• Identifiers: a TLC-assigned account identifier. On iOS, the App Tracking Transparency identifier only if you grant permission. On Android, the advertising ID where applicable; we do not use it for advertising.
• Usage data: features used, screens visited, taps, session duration, sync events, errors, crash reports.
• Approximate location derived from IP address. We do not collect precise device location.
• Cookies and similar technologies on tlcapp.io as described in our Cookie Policy. The mobile application does not use third-party advertising or analytics trackers.

c. Information from third parties:

• Authentication providers (Sign in with Apple, Sign in with Google): the identifier and basic profile information you authorize them to share with us.
• Payment processors: confirmation of subscription status and transaction metadata, not full payment-card data.

4. Sensitive Information

Some information processed through the Service relates to a VIP’s health, cognitive condition, or care. Although TLC is not a healthcare provider and information shared through the Service is not part of a medical record, we recognize that this information is sensitive and we treat it accordingly:

• We do not sell sensitive personal information.
• We do not use sensitive personal information for advertising.
• We do not share sensitive personal information for behavioral advertising purposes.
• We process sensitive personal information only as needed to provide the Service or where you have given explicit consent.

If you are a Washington State resident, see Section 13 for additional disclosures under the My Health My Data Act.

For users in the European Economic Area or United Kingdom, the lawful basis for processing data concerning health under GDPR Article 9 is your explicit consent, given on account creation and on each significant addition of such information. You may withdraw consent at any time.

5. How We Use Information

We use personal information to:

• Provide, operate, and maintain the Service, including creating accounts and Circles, delivering content to Users, and synchronizing devices.
• Authenticate Users and protect against fraud or unauthorized access.
• Process subscription payments and manage billing.
• Send transactional communications (account confirmations, security alerts, invitation messages, billing notifications, service updates).
• Send product communications you have opted into.
• Provide customer support.
• Improve the Service, including debugging, performance analysis, and feature development. We do not use User Content to train artificial intelligence or machine learning models.
• Detect and prevent abuse, harm, and violations of our Terms.
• Comply with legal obligations.

Lawful bases (EEA/UK users): We process personal data under one or more of the following lawful bases: (i) performance of a contract with you; (ii) compliance with a legal obligation; (iii) your consent (which you may withdraw at any time); (iv) our legitimate interests in operating and securing the Service, where not overridden by your rights and interests.

6. Not Medical Advice

Trusted Life Circle is not a medical device, healthcare provider, emergency response service, or diagnostic tool.

The Service is intended to support communication, social connection, and caregiver coordination. It is not intended to provide medical advice, diagnosis, treatment, or emergency monitoring.

Users should always seek guidance from qualified healthcare professionals regarding medical or cognitive health concerns.

7. How We Share Information

We share information only as described below:

a. Within your Circle. Content you submit to a Circle is visible to the other members of that Circle in accordance with their role.

b. Service providers. We share information with vendors who help us operate the Service under contractual obligations of confidentiality and data protection:

Provider	Purpose	Primary Location
OVH	Application hosting and database	France
Cloudflare, Inc.	Content delivery, R2 object storage, DNS	Global edge network
Apple, Inc.	iOS app distribution, in-app purchase, push notifications, Sign in with Apple	United States
Google LLC	Android app distribution, in-app purchase, push notifications, Sign in with Google	United States
Stripe, Inc.	Payment processing for web subscriptions	United States
Postmark (ActiveCampaign, LLC)	Transactional email delivery	United States
Telnyx LLC	SMS verification codes	United States

c. Legal requirements. We may disclose information to comply with valid legal process, to enforce our Terms, to protect the rights, safety, or property of TLC, our Users, or the public, or to investigate suspected fraud or abuse.

d. Business transfers. If TLC is involved in a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction, subject to confidentiality obligations and notice to affected Users.

e. With your consent. We share information with other third parties when you direct us to do so.

We do not sell personal information. We do not share personal information for cross-context behavioral advertising.

8. International Data Transfers

TLC is based in the United States, and our hosting provider OVH is in France. If you access the Service from outside these countries, your information will be transferred to and processed in jurisdictions that may have data protection laws different from those of your own.

For transfers from the European Economic Area, United Kingdom, or Switzerland to the United States or other third countries, we rely on Standard Contractual Clauses approved by the European Commission or equivalent transfer mechanisms.

9. Data Security

We implement technical and organizational measures designed to protect personal information, including:

• Encryption in transit (HTTPS/TLS) for all client-server communication.
• Encryption at rest for stored data and backups.
• Strong authentication, including passkey (WebAuthn) support.
• Access controls limiting employee access to personal information on a need-to-know basis.
• Audit logging of administrative access.
• Regular security review of code and dependencies.

No system is completely secure. If we become aware of a security incident affecting your personal information, we will notify you in accordance with applicable law, including, where applicable, the FTC Health Breach Notification Rule.

10. Data Retention

We retain personal information only as long as needed for the purposes described in this Policy or as required by law:

• Account data: Retained while the account is active; deleted within 30 days after closure, subject to longer retention for legal, accounting, or dispute-resolution purposes.
• User Content: Retained while in your Circle; deleted within 30 days after you delete it or close your account.
• Backups: May persist in encrypted backups for up to 90 days after deletion.
• Logs and analytics: Retained for up to 18 months in identifiable form, then aggregated or deleted.
• Payment records: Retained for the period required by tax and financial recordkeeping laws (typically up to 7 years).

11. International Users

Trusted Life Circle may be accessed by users outside of the United States, including users in Canada, the United Kingdom, Ireland, Australia, and New Zealand.

By using the Service, you understand that your information may be processed, transferred, and stored in the United States or other jurisdictions where our service providers operate.

We take reasonable measures to protect personal information in accordance with applicable privacy laws.

12. Your Rights and Choices

Depending on your location and applicable laws, you may have the right to:

• Access the personal information we hold about you.
• Correction of inaccurate information.
• Deletion of your personal information, subject to legal retention obligations.
• Portability — receive your data in a structured, machine-readable format.
• Restriction of certain processing.
• Objection to certain processing, including processing based on legitimate interests.
• Withdrawal of consent at any time where processing is based on consent (without affecting prior processing).
• Complaint to a data protection authority.
• Request access to personal information we maintain about you
• Request correction of inaccurate information
• Request deletion of your information
  Withdraw consent where applicable
• Request export of certain account data

To exercise these rights, contact [email protected]. We will verify your identity before fulfilling a request and respond within the time required by applicable law. We will not discriminate against you for exercising your rights.

 

13. California Residents (CCPA/CPRA)

If you are a California resident, you have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

• Right to know the categories and specific pieces of personal information collected.
• Right to delete personal information, with limited exceptions.
• Right to correct inaccurate personal information.
• Right to opt out of the sale or sharing of personal information. We do not sell or share personal information for cross-context behavioral advertising.
• Right to limit use of sensitive personal information. We use sensitive personal information only for purposes permitted under CCPA without requiring an opt-out signal.
• Right to non-discrimination for exercising your rights.

CCPA categories of personal information collected: identifiers; commercial information (subscription history); internet or electronic network activity information; geolocation data (approximate, IP-derived); audio, visual, or similar information (uploaded media); inferences drawn from other personal information; and sensitive personal information (account credentials, and health/cognition-related content where applicable).

To exercise California rights, contact [email protected] You may designate an authorized agent. We retain information as described in Section 9.

14. Other U.S. State Privacy Rights

Residents of Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, and certain other states have rights similar to those described above, including access, deletion, correction, portability, and the ability to opt out of certain processing. To exercise these rights, contact [email protected].

15. Washington State — My Health My Data Act

This section provides additional information for Washington State consumers under the My Health My Data Act (MHMDA).

Consumer Health Data we may collect: Information about the VIP’s cognitive condition (e.g., references to dementia or Alzheimer’s disease), care status, mood and engagement as captured in Circle content, and information that may be inferred from User Content.

Sources of Consumer Health Data: Directly from Guardians, Contributors, and (where applicable) the VIP.

Purposes: To provide the Service as described in Section 5.

Sharing: As described in Section 6. We do not sell Consumer Health Data.

MHMDA rights:

• Confirm whether we are collecting your Consumer Health Data and access it.
• Request deletion of your Consumer Health Data.
• Withdraw consent to the collection and sharing of Consumer Health Data.

Contact [email protected] to exercise these rights.

16. FTC Health Breach Notification Rule

To the extent the Federal Trade Commission’s Health Breach Notification Rule applies to TLC, we will provide breach notice to affected Users, the FTC, and where required, the media, within the timeframes set by the Rule.

17. Children’s Privacy

The Service is not directed to children under 13, or under the age of digital consent set by your jurisdiction (which may be 16 in parts of the European Economic Area and elsewhere). We do not knowingly collect personal information from children covered by these limits. If we learn we have collected personal information from a child without appropriate consent, we will delete it.

A VIP within a Circle may be of any age (including a minor), but the Guardian is responsible for ensuring participation complies with applicable law, including obtaining verifiable parental consent where required.

18. Cookies and Tracking

The website tlcapp.io uses cookies and similar technologies as described in our Cookie Policy. The mobile application does not use third-party advertising trackers.

We honor Global Privacy Control (GPC) signals as an opt-out of sale or sharing where applicable.

19. Email and SMS Communications

We send transactional email through Postmark for account, security, billing, and invitation messages; you cannot opt out of these messages while you maintain an active account. Product or marketing email is opt-in, and you may unsubscribe at any time via the link in the message.

We send SMS verification codes through Telnyx. Standard message and data rates may apply. You may reply STOP to opt out, though doing so may prevent you from receiving security codes required to use the Service.

20. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated version with a new “Last Updated” date and, for material changes, notify Users through the Service or by email. Continued use after the effective date constitutes acceptance.

21. Contact Us

Questions about this Privacy Policy or requests to exercise your rights:

Trusted Life Circle, Inc.

309 N Water St Ste 203 Milwaukee, WI 53202

email: [email protected]

For EU/UK users: If you require an Article 27 representative to handle GDPR matters, contact [email protected] so we can discuss your situation.