Elomia Screening Apps

Privacy Policy

This Privacy Policy describes what data we collect and how we handle your information when you use our self-assessment mobile apps for iOS and Android (the "Screening Apps"). It applies to every Screening App published by Elomia Health, Inc. Together with our Terms of Use, this Privacy Policy governs our legal relationship.

Key Points

We are committed to complying with applicable data protection and privacy laws in the jurisdictions where we operate, including the General Data Protection Regulation (GDPR) for users in the European Economic Area, the United Kingdom and Switzerland; the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) for California residents; other US state privacy laws; and other relevant privacy frameworks. We regularly review and update our practices to maintain compliance as laws and regulations evolve.

What Data Do We Collect?

What is Personal Data?

Personal data is any information that can be used to identify you, either on its own or when combined with other information. This includes obvious identifiers like your email address and phone number, and digital information that can be linked back to you, such as a device identifier or IP address. Information about your health, including answers to a mental-health questionnaire, is sensitive personal data.

At Elomia Health, we collect only the data necessary for the Screening Apps to function. We believe that the less data we collect, the better. For the Screening Apps, that is very little.

What is Processing?

Personal data processing means any operation performed on your data, including collection, storage, use, sharing or deletion.

Data that stays on your device

The following data is created and stored only on your device. It is never transmitted to us or to anyone else unless you choose to export or share it yourself:

If you delete the app, this data is deleted with it. We cannot recover it. If you wish to keep it, use the export features in the app.

Data we process

Type of data Processing reasons Lawful basis Notes on processing
Email address To send email reminders and calendar invitations you asked for Consent Collected only if you turn on email or calendar reminders. Deleted when you turn them off or delete your data.
Phone number To send SMS reminders or automated reminder calls you asked for Consent Collected only if you turn on SMS or call reminders. Deleted when you turn them off or delete your data.
Push notification token To deliver push notifications on your device Consent Created when you allow notifications. Contains no personal content.
Anonymous installation identifier To measure how the app is used and to fix errors Legitimate interest A random identifier not linked to your name, email or phone number.
Log data of your usage of the app (screens opened, features used, app version, device type, language, time zone, crash reports) To improve the app and keep it stable Legitimate interest Never includes your answers, scores or notes.
Email address, name or nickname, and message content To answer support requests, feedback or complaints you send us Performance of the contract Only when you contact us.
Postal address, name and signature To process inquiries sent to our physical address Performance of the contract Only if you write to us by post.

Note on legal basis: "Performance of the contract" means we need this data to provide the service you asked for. "Legitimate interest" means we have a valid business reason to process this data, balanced against your privacy rights. "Consent" means we have your explicit permission, which you give by turning a feature on and can withdraw by turning it off.

What we do not collect

We do not collect your name, date of birth, location, contacts, photos, health records or any information from other apps. We do not use advertising identifiers. We do not use AI services to process your answers.

Automated Decision-Making

The Screening Apps calculate your score using the published scoring rules of the questionnaire and show you the result band those rules define. This calculation happens on your device. It is a fixed arithmetic rule, not a decision about you: it does not diagnose any condition, does not affect your legal rights, and is not used to make any decision on our side. The app may also suggest other Screening Apps based on the questionnaire you took, not on your answers.

Data Disclosure to Third Parties

We do not sell your personal data. We do not share your data with third parties for their own marketing or advertising purposes. We share data only with service providers who help us run the Screening Apps, under contract, and only the minimum needed for each service.

Service provider Type of provider Purpose of disclosure Data shared
Google Cloud (USA) Infrastructure Hosting of the reminder service Email addresses and phone numbers of users who turned on those reminders; reminder schedule
Firebase (USA) Communication and technical Push notifications, crash reporting, usage analytics Push token, anonymous installation identifier, device information, app version, time zone, language, crash logs, usage events
SendGrid (USA) Communication Email reminders and calendar invitations Email address only
Twilio (USA) Communication SMS reminders and automated reminder calls Phone number only
Sentry (USA) Technical Error reporting Device information, app version, language, time zone, IP address, error logs
Mixpanel (USA) Analytics Usage analytics Anonymous installation identifier, usage events, device information

Your answers, scores and notes are never shared with any provider, because they never leave your device.

If you contact us through third-party platforms such as social media, you are subject to their terms and we do not control how they process your data.

Your Opt-Out Rights

What you can turn off at any time, in the app's Settings:

Activity How
Push notifications Turn off in Settings or in your device's notification settings
Email, calendar, SMS or call reminders Turn off the channel in Settings; we delete the address or number when no reminder uses it
All reminders Pause reminders in Settings
Everything Delete all data in Settings; this erases the app's data on your device and asks us to delete any reminder contact details we hold

What you can ask us to stop: collecting usage analytics for improvement. Contact privacy@elomia.com. We may not be able to remove already-collected anonymous data because we cannot link it to you.

Consequences of refusing: the questionnaire, your results and your history work without giving us any personal data at all. Refusing reminders means only that we cannot remind you.

Our Security Framework

On your device. Your answers and history are stored in the app's private storage, which other apps cannot read. You can protect the app with your device's passcode, Face ID or Touch ID where supported; biometric data never leaves your device and we never receive it.

In transit. All communication between the app and our servers uses HTTPS with TLS 1.2 or higher.

On our servers. Reminder contact details are encrypted at rest using Google Cloud's native encryption with secure key management. Access to production systems is restricted by role, logged and reviewed regularly. We run automated vulnerability scans weekly, monitor for threats continuously, and maintain a documented incident response plan. Our practices follow industry best practices, including those outlined in SOC 2 and HIPAA. All team members pass background screening and complete security training on joining and annually. Encrypted backups are tested regularly, and a Business Continuity Plan is tested annually.

Vulnerability disclosure. If you believe you have found a security issue, please report it to security@elomia.com.

Data Retention Periods

Data Retained
Answers, scores, notes, settings On your device, until you delete them or the app
Email address or phone number for reminders Until you turn the channel off, delete your data, or 12 months after the last reminder was delivered, whichever is first
Push token Until you disable notifications or uninstall the app
Usage logs and crash reports Up to 24 months from collection
Support correspondence Up to 3 years from your last interaction with our support team

Because there is no account, "Delete all data" in Settings is immediate and permanent. There is no grace period and no way for us to restore it.

Your Data Processing Rights

Right What this means How to exercise it
Right to be informed To know how we collect, use and share your data Read this Privacy Policy and our Terms of Use; ask us at support@elomia.com
Right to access To get a copy of the personal data we hold about you Your answers and history are on your device; use Export in Settings. For reminder contact details, contact privacy@elomia.com
Right to rectification To correct inaccurate data Edit your email or phone number in Settings
Right to erasure To have your data deleted Delete all data in Settings; or contact privacy@elomia.com for reminder contact details
Right to data portability To receive your data in a portable format Use Export in Settings (PDF or CSV)
Right to opt out of sale or sharing To object to sale of your data or targeted advertising No action needed; we do neither
Right to object to automated decision-making To request that automated decisions be disabled Not applicable; the app makes no decisions about you beyond arithmetic scoring on your device
Right to limit use of sensitive personal information To restrict processing of health data We do not process your health data; it stays on your device
Right to withdraw consent To take back permission you gave Turn off the relevant reminder channel in Settings

How to exercise your rights. Most rights can be exercised in Settings. For everything else, contact privacy@elomia.com. We do not charge a fee for requests unless they are clearly unfounded, repetitive or excessive, in which case we will tell you in advance.

Our response standard. We will acknowledge receipt of your request within 10 business days and respond within 45 calendar days, extendable once by 15 days with notice. Straightforward requests are typically answered in under 2 days. We may ask for information to verify your identity.

When we cannot fulfill a request. This can happen if the request is unclear or not about your own data, if we are restricted by law, or if the data has already been deleted. If we deny a request for access, you may ask for a review by a qualified individual not involved in the original decision; we will respond within 30 calendar days.

Children's Privacy

The Screening Apps are intended for people aged 16 or over. One Screening App is designed to be completed by a parent or carer about a child; it is answered by the adult, stored on the adult's device, and we do not collect any information from the child. Under the Children's Online Privacy Protection Act (COPPA), we do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided personal information to us, contact support@elomia.com and we will delete it.

Contact Information

The Screening Apps are operated by Elomia Health, Inc., registered at 8 The Green Ste 6359, Dover, DE 19901.

Privacy questions: privacy@elomia.com
Other questions, feedback, complaints or claims: (302) 244-7193 or support@elomia.com

If you are a resident of the EEA, you may also refer to the EDPB website for your national data protection authority. Swiss residents: EDÖB. UK residents: ICO.

Data Protection Officer: Taras Pohrebniak, pohrebniak@elomia.com.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated policy here with the revision date at the top. If the updates significantly affect you, we will notify you by push notification in the app or, if you have given us an email address for reminders, by email. By continuing to use the Screening Apps after changes take effect, you accept the updated Privacy Policy.