Carely — Privacy Policy

Effective Date: October 18, 2026 (previous version: October 12, 2026) · Controller/Provider: Aureate Care Systems LLC ("Carely")

1. Scope

This Policy explains how Carely collects, uses, and shares information through our websites, the hosted platform, and our desktop and mobile applications (the "Services").

Protected Health Information (PHI) that an Agency processes in Carely is handled under our Business Associate Agreement with that Agency and the Agency's own privacy notices. For that PHI, the Agency is the responsible party and this Policy is secondary.

2. Information we process

A. Information Agencies put into the platform (processed on the Agency's behalf)

• Care-recipient (client) data, including PHI: name, date of birth, address, contact, gender, language, responsible party or power of attorney, reason for care, care needs, mobility and fall history, cognitive and behavioral notes, allergies, diet, non-medical medication reminders, durable medical equipment, physician information, care plans, incident reports, visit reports, and satisfaction surveys; the answers to any additional intake or care-plan questions the Agency has added; and the documents and spreadsheets an Agency uploads to bring its existing records into Carely. For Agencies that turn on the clinical module, this also includes medications and medication-administration records, clinical orders, and clinical notes.
• Caregiver data: name, contact, Social Security Number (encrypted), address, emergency contacts, license number, background-check and criminal-history attestations, references, employment, scheduling, and pay information; availability, skills, experience and specialties; certifications and training records; and the answers to any additional application questions the Agency has added.
• Visit data (EVV): clock-in and clock-out timestamps and the device's location at the moment of each: the coordinates, how accurate the reading was, and where it came from — a phone's GPS, a web browser, or a computer's own location service, which may estimate position from nearby networks. Location is read only when a caregiver clocks in or out. It is not tracked between those moments.
• Mileage trips: when an Agency bills a client for mileage, the trips a caregiver lists for a visit — each place driven from and to, as the caregiver chose it, its position on the map, and the miles between them. These are entered by the caregiver, not taken from the device's location.
• Messages: the messages and images an Agency, its caregivers, and families exchange inside the product.
• Billing data: invoices, insurance amounts, and tokenized payment method references. No full card or bank numbers are stored by Carely.
• Family-member data: name, relationship, and contact details.

B. Information we collect as a controller

• Account and login data: username, name, title, email, role, and authentication logs. When you start a new agency account we create your username from your email address unless you choose your own, and we record the kind of care the agency says it provides and the name and title of the person who signed the Business Associate Agreement.
• Agreement records: which version of the Terms of Service, this Policy, and the Business Associate Agreement you accepted or signed, when, and the network address and browser it was done from. These are kept so the record of what was agreed can be produced if it is ever needed.
• Device and usage data: IP address, device and browser type, log and diagnostic data, and security and audit events.
• Website visit data (carelyapp.care and the public demo): a random first-party visitor identifier stored in your browser, the pages and sections you view, the buttons you use to open the demo or the sign-up form, the demo screens and guided-tour steps you open, the time you spend, the address of the site that referred you and any campaign parameters in the link you followed, your browser and device type, and — if we enable it, which we have not — the country or region derived from your network address. On the sign-up form we record which step you reached and which fields you used — by the field's name, never its contents — and, if the form refused something, which rule it was. We do not record anything you type into the demo or any form for this purpose. If you sign in, create an agency, or join one in the same browser, that browser's identifier is linked to the account, so that a visit which led to an account is not counted as one that did not.
• Communications: messages you send us, such as support requests.
• Cookies and similar technologies on our websites — see §7.

C. Information the apps keep on your device

So that a visit can be recorded where there is no connection, the Carely apps keep a small amount of information on the device itself:

• Your sign-in. In the installed apps it is kept until you sign out, it expires, or you are signed out after fifteen minutes without use. In a web browser it lasts only as long as the tab.
• A caregiver's own visits for the days around today: the client's name, the date and times, the visit's status and type, when it was clocked, and the care-plan checklist. No address, contact details, health notes, or other people's visits are kept. This copy is kept in the same place and for the same time as the sign-in, and is removed whenever the sign-in ends.
• Records waiting to be sent: a clock-in or clock-out made without a connection, with its time and the device's location, and any visit note written with it. Each is removed from the device as soon as our servers have received it, or, if our servers refuse it, when you dismiss the notice that says so.
• A visit in progress: a reference to a visit you have started, your name, and the time it began, so that you can clock out even if you have been signed out. It is removed when the visit ends, and after one day in any case.

This information stays on the device until it is sent to Carely as described above; it is not shared with anyone else. It is protected by the device's own lock, so we ask caregivers to keep a passcode on any phone used for Carely.

3. How we use information

• To provide, secure, maintain, and improve the Services
• To authenticate users and enforce role-based access and tenant isolation
• To send account notices, such as a password-reset link. It goes to the email on your account; if the account has none, to the email on your caregiver or family contact record at your Agency. An Agency administrator can also have one sent to you.
• To process billing and, where enabled, payments through a processor
• To provide support and respond to requests
• To detect, prevent, and respond to fraud, abuse, and security incidents
• To comply with legal obligations and enforce our agreements

We do not sell PHI. We do not use PHI for advertising. We process PHI only as permitted by our Business Associate Agreement with the Agency and applicable law.

4. AI features and what is sent to the model

Carely uses Anthropic's Claude models through Amazon Bedrock, run inside Amazon Web Services in the United States under our AWS Business Associate Addendum. Each feature is sent only what it needs, never a database. Amazon Bedrock does not use what it receives to train models and does not share it with the model's maker.

Reading an uploaded document. When an Agency uploads a client or caregiver packet to bring its records into Carely, the text of that document — which includes names, dates of birth, and health information — is sent to the model so that it can be read into the right fields. This is PHI, processed under the AWS Business Associate Addendum, and an Agency reviews what was read before anything is saved.

Suggesting a caregiver for a client or a visit. No names are sent. What goes is the client's needs as labels, the care level, and the language, and for each candidate caregiver — identified only as C1, C2, C3 — their skills, years of experience, and the scheduler's own reasons and score. Carely's rules decide who is eligible; the model only ranks those people, and an administrator can override it.

Ask Carely — the in-product help assistant answers navigation and how-to questions. Only the text of a help question is sent to the model. It is designed not to receive PHI; do not enter PHI into it.

Written business briefings — Carely generates a plain-English briefing from an Agency's own figures. What is sent is a digest of aggregate numbers and non-identifying labels only: the health score, key-performance values, forecasts, and the severity, category, title, and recommendation of each detected insight. The supporting detail behind an insight — which can name a client or caregiver — is removed before anything leaves Carely, and the model is instructed never to reference individuals.

Troubleshooting by Carely staff — when Carely's own engineers diagnose an error, the error text they paste is sent to the model after names, email addresses, phone numbers and similar identifiers are removed. This tool is for Carely staff only.

An Agency's platform operator can switch off the features that send client information to the model; Carely then uses its own rules for each of them.

5. How we share information

• Subprocessors and service providers that host and operate the Services under contract and, for PHI, under a Business Associate Agreement — see §6.
• Within an Agency workspace, according to the Agency's role-based permissions. For example, a family member sees only their loved one's information.
• Payment and email providers you enable, to perform those functions.
• Legal and compliance: to comply with law, lawful requests, or to protect rights, safety, and security.
• Business transfers: in a merger, acquisition, or asset sale, subject to this Policy.

We do not sell personal information, and we do not "share" it for cross-context behavioral advertising as those terms are defined under California law.

6. Subprocessors

We use vetted subprocessors, each bound by contract and, for PHI, a Business Associate Agreement. Current core subprocessors:

The AWS Business Associate Addendum was executed on July 2, 2026 and covers hosting, backups, address lookup and AI features.

Our email is written so that it carries no PHI. A notice tells you that something is waiting — a new message, a visit report, an invoice — and never what it says. It contains no name, date of birth, address, condition, visit detail or amount. The content itself stays inside Carely, behind your sign-in, which is also why none of our email accepts a reply, and why we do not receive email at that address either.

Because of this, our email provider does not create, receive, maintain or transmit PHI on our behalf, and is engaged under standard data-protection terms rather than a Business Associate Agreement. This is not a matter of trust in the provider: it is a design constraint, and it is enforced automatically — every email our software can produce is checked against every client and caregiver name, date of birth and home address we hold, and a release is blocked if one appears.

Our phone notifications are written the same way. A notification says that something is waiting — a new message, an announcement, an alert — and never what it says. It contains no name, date of birth, address, condition, visit detail or amount, so the services that deliver it do not receive PHI on our behalf.

Carely does not send text messages. All messaging between an Agency, its caregivers, and families happens inside the product; there is no outbound SMS channel and no SMS provider.

7. Cookies and analytics

The hosted application uses cookies and local storage strictly to keep you signed in and operate the app.

Our marketing website and public demo use one first-party cookie (cv), set by our own server and readable by no one else, to recognize your browser across visits for up to 400 days, together with browser storage that holds the same identifier. We use it to understand how people find and explore Carely — how many visit, which pages and sections they view, whether they try the demo, how far through the sign-up form they get, and whether a visit leads to an account. We do not use third-party analytics, advertising cookies, tracking pixels in email, or device fingerprinting, and we never load scripts from other companies for this purpose. Your network address is stored only as a one-way hash and a coarse prefix, never in full.

If your browser sends a Global Privacy Control or Do Not Track signal, we do not set this cookie and do not keep a persistent identifier. You can ask us to delete what we hold about your browser at any time (see §10).

8. Security

We use administrative, physical, and technical safeguards, including encryption in transit (TLS), encryption of especially sensitive fields such as Social Security Numbers, role-based access control with tenant isolation, audit logging, rate limiting, and continuous off-site backups. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

9. Data retention

Website visit events are kept for 90 days, visit sessions for 13 months, and aggregate counts (with no identifier) indefinitely. We retain Customer Data for the duration of the Agency's subscription and as needed to provide the Services, then return or delete it. An Agency that closes its account has a 30-day period in which it can export its data or reactivate, after which the account is archived and purged. Protected Health Information is returned or destroyed under the Business Associate Agreement, and any separately negotiated agreement with an Agency controls where it differs. We retain limited account, security, and transaction records as required by law or for legitimate business purposes. Backups are retained for a rolling window and then expire.

10. Your rights and choices

Depending on your role and where you live, you — or, for PHI, the individual through their Agency — may have rights to access, correct, delete, port, or restrict certain data, and to opt out of certain processing.

For PHI in an Agency workspace, contact the Agency, which is the responsible party; we will support the Agency in fulfilling such requests under our Business Associate Agreement. For data Carely controls, such as account or marketing data, contact us at privacy@carelyapp.care.

We will not discriminate against you for exercising these rights. You can opt out of marketing emails using the unsubscribe link. To have the website visit data for your browser deleted, use the "Forget my browser" link in the site footer, or contact us; we will delete it within 30 days.

11. Children

The Services are not directed to children under 13 and we do not knowingly collect their data. Care recipients are generally adults; if a minor's data is ever entered, the Agency is responsible for the lawful basis and parental consent.

12. United States processing

Carely operates in and stores data in the United States. If you access the Services from outside the U.S., you understand data is processed in the U.S.

13. Changes

We may update this Policy; we will post the new effective date and, for material changes, provide notice through the Services or by email.

14. Contact

Aureate Care Systems LLC 1213 Limbali Street, Mount Dora, FL 32757 privacy@carelyapp.care

HIPAA matters involving an Agency's PHI should be directed to that Agency. You may also contact us at the address above.

Aureate Care Systems LLC · Privacy Policy · Terms of Service