Privacy Policy

At Amoviti, privacy and security are fundamental to the Family Continuity System we provide to families.

This Privacy Policy explains what personal information Amoviti collects, how we use and protect it, when we disclose it, how long we retain it, and the rights and choices available to you.

This Privacy Policy applies to the Amoviti website, web application, mobile applications, and other services that link to or reference this Privacy Policy (collectively, the “Services”).

Amoviti is available to users generally. Paid plans are currently offered in the United States.

Because our technology, security controls, features, and service providers may change over time, this Privacy Policy describes our practices as of the Last Updated date above. Where a security or privacy capability has not yet been enabled, we do not represent that it is in operation. We will update this Privacy Policy when our practices materially change, as described in Section 29, Changes to This Privacy Policy.

1. Who We Are

The Services are provided by:

In this Privacy Policy, “Amoviti,” “we,” “us,” or “our” means Amoviti Technologies LLC.

Amoviti determines the purposes and means of processing personal information in connection with the Services, except where a third party processes information independently under its own privacy policy and terms, including certain payment providers described in Section 13.

For privacy questions, requests, complaints, or concerns, contact our Privacy Officer:

Email: privacy@amoviti.com

Mail:

Privacy Officer

2. Information We Collect

We collect personal information that is reasonably necessary to provide, secure, maintain, support, and improve the Services and the features you choose to use.

The information we collect depends on how you interact with Amoviti.

A. Account Information

When you create an Amoviti account, we collect:

• Your name;
• Email address;
• Account identifier; and
• Information necessary to authenticate and protect your account.

We may determine your approximate country from your network connection when you create an account. We do not ask you to provide your country for this purpose.

If you sign in using Google, Google may provide us with your:

• Name;
• Email address; and
• Google profile photo.

We do not receive unrelated information from your Google account through Google Sign-In.

B. Information You Choose to Provide

Depending on the Services and features you use, you may provide:

• Mobile telephone number;
• Postal address;
• Date of birth;
• Citizenship or nationality;
• Residency information;
• Marital status;
• Profile photograph;
• Family information;
• Emergency contacts;
• Beneficiaries;
• Property and asset information;
• Emergency and continuity instructions; and
• Other information you voluntarily enter into your account.

Most of this information is optional. Certain features may require particular information to function.

C. Documents and Records

Amoviti allows you to store documents and records in your account, including information relating to:

• Identity;
• Passports and immigration;
• Insurance;
• Financial and tax matters;
• Property and mortgages;
• Legal matters;
• Wills and trusts;
• Estate planning;
• Medical or health matters;
• Family relationships; and
• Emergency or continuity planning.

Documents may contain information about you and other individuals.

You decide which documents and records to store. Amoviti does not require you to upload any particular category of document.

Because documents may contain highly personal, confidential, or legally sensitive information, you should consider carefully whether a document is appropriate for storage in Amoviti.

D. Information About Other Individuals

You may provide information about family members, emergency contacts, beneficiaries, and other individuals.

This may include:

• Name;
• Email address;
• Telephone number;
• Postal address;
• Date of birth;
• Nationality or citizenship;
• Place of birth;
• Relationship to you; and
• Information contained in documents you upload.

If applicable law requires you to have a lawful basis, authorization, or consent before providing another person’s personal information to Amoviti, you are responsible for obtaining that authorization.

E. Payment and Subscription Information

Amoviti does not receive or store your payment-card number.

Depending on how you purchase a subscription, payment is processed by:

• Stripe;
• Apple App Store; or
• Google Play.

Amoviti receives information reasonably necessary to administer your subscription, including:

• Subscription plan;
• Subscription status;
• Billing period;
• Purchase or transaction identifiers;
• Renewal information; and
• Refund or dispute information.

F. Device, Technical, and Usage Information

Depending on your settings and how you use the Services, we may collect technical and usage information, including:

• Session identifiers;
• Timestamps;
• Application environment;
• Approximate region;
• Platform;
• Notification token;
• Application-generated device identifier;
• Application version; and
• Security and authentication information.

Analytics is subject to the controls described in Section 18.

Amoviti does not intentionally collect:

• Precise geographic location;
• Device advertising identifiers; or
• Device information for purposes of creating advertising profiles.

G. Information Collected Before Account Creation

You may use the Amoviti Preparedness Score without creating an account.

If you do so, your Preparedness Score answers and result may be stored in your browser for up to seven (7) days so that you can return to them.

Campaign parameters contained in the link through which you accessed the score may also be retained.

If you subsequently create an account, the applicable Preparedness Score information and campaign information may be associated with your account.

H. Information We Derive

We may derive information from the information you provide or documents you store, including:

• Your Preparedness Score;
• Gaps identified by the Preparedness Score;
• Document classifications;
• Information extracted from documents, including applicable expiration dates;
• Reminders and alerts generated from your records;
• Relationships between records, such as which insurance policy relates to a property; and
• Records of activity used by configured continuity or emergency workflows.

We also maintain an activity timestamp reflecting your deliberate activity within the Services. Certain continuity features use this information to distinguish activity from periods of inactivity.

We do not use this information to create advertising profiles.

3. How We Collect Information

We obtain personal information primarily from you.

We may also receive information from:

• Google, when you use Google Sign-In;
• Google Drive, when you voluntarily import files;
• Payment and subscription providers;
• Your browser or device, including approximate country information;
• Service providers that operate portions of the Services; and
• Security, fraud-prevention, and abuse-detection systems.

We do not purchase personal information from data brokers.

We do not enrich your Amoviti account using data-broker profiles or public-record databases.

4. Google Drive Imports

Amoviti may allow you to import files from Google Drive through the web application.

When you initiate an import, you select individual files using Google’s file-selection interface. Amoviti is provided access only to the files you select for import.

Amoviti does not obtain general access to your Google Drive and does not:

• Search your Drive;
• Browse unrelated files;
• Modify your Drive files;
• Move your Drive files; or
• Delete your Drive files.

Amoviti does not request your Google account name, email address, profile photo, or unrelated Google account information for the purpose of importing files.

Each selected file is copied into your Amoviti account and thereafter treated as an Amoviti document under this Privacy Policy.

The Google Drive authorization used for the import is used only for the import process and is not stored by Amoviti for continuing server-side access to your Google Drive.

Amoviti’s use and transfer of information obtained through Google APIs is intended to comply with the Google API Services User Data Policy, including its Limited Use requirements.

Information obtained from Google Drive is used only to:

• Perform the import you requested;
• Provide the Amoviti Services associated with the imported document;
• Share information according to your instructions;
• Provide processing through the service providers described in Section 13; or
• Comply with applicable law.

We do not use Google Drive content for advertising or sell it.

We do not use Google Drive content to train or improve artificial-intelligence or machine-learning models.

You may revoke Amoviti’s Google Drive access through your Google Account. Revoking access does not automatically delete files already copied into your Amoviti account. Those copies remain subject to this Privacy Policy and may be deleted through Amoviti.

5. How We Use Personal Information

We use personal information for the following purposes:

Providing and Operating the Services

• Create and manage accounts;
• Authenticate users;
• Store, organize, search, and display records;
• Provide document-management functionality;
• Provide reminders and expiration alerts;
• Enable authorized sharing;
• Operate emergency and continuity workflows; and
• Provide requested account features.

Preparedness Features

• Calculate your Preparedness Score;
• Identify preparedness gaps;
• Generate relevant reminders and suggestions; and
• Provide relationships and connections between records.

Document and AI Features

• Identify and classify documents;
• Read and extract information from documents;
• Perform analyses that you request;
• Answer questions using the Family Assistant; and
• Provide other AI-enabled features you intentionally use.

Communications

• Send authentication codes;
• Send service-related communications;
• Send requested reminders and alerts;
• Send emergency or continuity notifications; and
• Respond to support requests.

Security and Abuse Prevention

• Detect and prevent fraud;
• Detect unauthorized access;
• Investigate security incidents;
• Prevent abuse and misuse;
• Maintain audit records; and
• Protect the Services and our users.

Payments and Administration

• Administer subscriptions;
• Process subscription-related information;
• Process refunds and disputes;
• Maintain financial records; and
• Comply with applicable accounting and tax obligations.

Product Improvement

Where analytics is enabled by you, we may use analytics information to understand how the Services are used and improve the Services.

Legal Compliance

We may process personal information as reasonably necessary to:

• Comply with applicable law;
• Respond to lawful requests;
• Establish, exercise, or defend legal claims;
• Enforce our agreements; and
• Protect the rights, safety, and security of Amoviti, our users, or others.

What We Do Not Do

We do not:

• Sell your personal information;
• Use your family records for advertising;
• Use your documents to train AI models;
• Use your personal information to create advertising profiles; or
• Use your personal information for materially different purposes without appropriate notice and, where required, consent.

6. Artificial Intelligence, Document Processing, and Automated Features

Amoviti uses automated technologies, including artificial intelligence, to provide certain document and Family Assistant features.

Initial Document Processing

When you upload a document, Amoviti first attempts to identify and process the document on your device where technically feasible, without sending the document to an AI model.

If the document cannot be sufficiently identified on the device, Amoviti may process the document using Google Cloud services.

The initial automated processing may occur automatically once for a document version.

Document Text Processing

Where a document already contains machine-readable text, Amoviti may process that text directly.

Where a document is a scan or photograph, Google Document AI may be used to convert applicable pages into text.

Where additional analysis is required, extracted text may be processed using Google Vertex AI.

Document images are not generally sent to an AI model. An exception may apply when a document, such as a passport information page, cannot be adequately interpreted from extracted text and image processing is necessary.

AI Service Provider

Amoviti uses Google Cloud enterprise services, including:

• Google Document AI; and
• Google Vertex AI.

These services operate within Amoviti’s Google Cloud environment in the United States region.

Document content transmitted for these services is transmitted through authenticated and encrypted connections.

Amoviti does not intentionally send document content to consumer chatbot services or unrelated third-party AI providers.

To the extent required by our applicable contractual arrangements, Google processes customer content in accordance with the applicable Google Cloud terms and data-processing commitments, including restrictions applicable to customer data and model training.

Family Assistant

When you use the Family Assistant, relevant information from your Amoviti records may be processed to answer your question.

We keep your Family Assistant questions and the answers you received so you can look back at them. They are visible only to you, and they are kept until you clear them in Settings → Privacy or your account is deleted.

AI-generated results may be inaccurate, incomplete, or outdated.

You should independently verify important information and should not rely solely on AI-generated responses when making legal, financial, medical, insurance, tax, property, estate-planning, or other consequential decisions.

AI Training

Amoviti does not use your documents or personal records to train AI models.

We do not permit our service providers to use your documents for their own AI model training where prohibited by our applicable contractual arrangements.

If our AI-processing practices or AI service providers materially change, we will update this Privacy Policy before implementing the material change where required by law.

7. Medical and Health Information

Amoviti permits you to voluntarily store medical or health-related documents.

Health-related information may be considered sensitive personal information under applicable privacy laws.

Amoviti processes health-related documents only as necessary to provide, secure, and support the features you choose to use.

For health-related documents, Amoviti’s document-recognition process is limited to identifying the document type. If automated processing is necessary, the document may undergo the initial document-reading process described in Section 6.

Amoviti does not intentionally extract health information from documents for use by the Family Assistant.

The Family Assistant does not use the contents of health documents for its responses.

Where a paid AI credit would otherwise be consumed for an operation that Amoviti determines is a health document and for which analysis is not performed, the applicable credit may be returned in accordance with the product’s credit rules.

Amoviti is not a healthcare provider, health plan, or health insurer.

Unless expressly stated otherwise in a separate written agreement, Amoviti does not operate as a HIPAA covered entity or business associate in providing its consumer Services.

The Services are not intended to provide medical diagnosis, treatment, or medical advice.

8. Sensitive Personal Information

Certain information stored in Amoviti may be considered sensitive personal information under applicable law, including:

• Government identification information;
• Passport and immigration information;
• Citizenship or nationality information;
• Health-related information;
• Information concerning children;
• Biometric information contained in documents, where applicable; and
• Other information that applicable law classifies as sensitive.

We process sensitive information only for the purposes described in this Privacy Policy and as permitted or required by applicable law.

We do not sell sensitive personal information.

We do not use sensitive information for advertising.

We do not intentionally infer sensitive characteristics about you from your records for advertising or profiling purposes.

Amoviti does not perform facial recognition or create a facial biometric identifier from photographs contained in documents.

Where applicable law requires affirmative consent before sensitive personal information may be processed, Amoviti will obtain consent in the manner required by that law.

9. Your Amoviti Household

An Amoviti household has one account owner.

The account owner is the individual who controls the account and determines which information is stored, shared, or released through configured continuity features.

Amoviti does not provide separate sign-in access to other household members under the household account.

Other individuals receive access only when the account owner intentionally:

• Shares a document or link with them; or
• Configures an emergency or continuity workflow that releases information to them.

10. Emergency and Family Continuity Features

Amoviti is designed to help families access important information when the account owner is unavailable.

Emergency and continuity features operate according to instructions configured by the account owner.

Shared Documents

When you share a document through Amoviti, the recipient may receive access without creating an Amoviti account.

The recipient must complete the applicable verification process, which may include a code sent to the contact information selected by you.

Recipients receive access only to the information associated with the applicable sharing mechanism.

Emergency Portal

The emergency portal may be accessible to an individual who possesses the applicable Emergency ID.

Verification codes are sent only to contact information registered for the applicable person or workflow.

Amoviti does not rely solely on contact information supplied by an unverified visitor to authorize access.

Where applicable, Amoviti may notify the account owner or otherwise record attempted access.

Emergency Workflow Activation

When an emergency or continuity workflow configured by the account owner is activated, only the information designated by the account owner is released to the people identified in that workflow.

Inactivity Does Not Mean Death

Amoviti does not treat inactivity alone as evidence that an account owner has died.

Silence or lack of activity, by itself, does not constitute confirmation of death.

Where a configured workflow requires confirmation of death, Amoviti may require the documentation and human verification specified by the applicable workflow.

Where account transfer following death requires Amoviti review, a member of the Amoviti team may review a death certificate against the identity information associated with the account.

Amoviti does not release an account to another person solely because that person requests access.

The account may be handled according to the account owner’s configured instructions, which may include:

• Archiving the account following confirmed death;
• Transferring designated information to a designated person following confirmed death and Amoviti review of a death certificate; or
• Deleting the account after it has gone unused for a period the account owner chose. This follows inactivity, not death: any sign-in resets the period, and the account owner is emailed 30 and 7 days before deletion.

11. Access to Information by Amoviti

Amoviti’s systems can process and, where necessary, access the documents and records stored in your account because those capabilities are necessary to provide certain Services, including:

• Search;
• Reminders;
• Expiration alerts;
• Document processing;
• AI features you request;
• Security operations;
• Customer support; and
• Technical troubleshooting.

Access to production information is restricted to authorized personnel who have a legitimate business need.

Access is granted individually rather than universally.

Access to production systems is subject to security, confidentiality, and access-control requirements.

Product actions involving your records are recorded in applicable audit systems.

Amoviti personnel may access personal information only when reasonably necessary to:

• Operate the Services;
• Provide customer support;
• Investigate security incidents or abuse;
• Maintain service reliability;
• Resolve technical problems;
• Protect users and the Services; or
• Comply with applicable law.

12. Security

Amoviti uses administrative, technical, and organizational safeguards designed to protect personal information.

These measures include, as applicable:

Encryption

Information is encrypted in transit using TLS.

Information stored in Google Cloud is encrypted at rest using Google Cloud’s applicable encryption mechanisms, including AES-256 where applicable.

Access Controls

Database and application access controls are designed to restrict access to the appropriate household and authorized operations.

Requests for information belonging to another household are rejected by applicable database and security controls.

Sensitive Account Operations

Certain high-risk operations require additional authentication, including operations such as:

• Exporting account information;
• Deleting an account; and
• Changing certain emergency or post-death recipients.

Additional authentication may include a fresh email verification code and, where supported by the mobile application, device-based biometric authentication together with applicable verification.

Audit Logging

Amoviti maintains audit records designed to record applicable security-sensitive actions, including who performed an action and when.

Audit records do not intentionally contain the contents of your documents.

Sessions

Security controls are used to expire authentication sessions and reduce the risk associated with stolen or abandoned sessions.

Signing out of all sessions affects operations that require server-side authentication. A previously issued session token may remain temporarily valid until it expires.

Security Monitoring

Amoviti maintains security monitoring and controls intended to detect:

• Unauthorized access;
• Fraud;
• Abuse;
• Security incidents; and
• Other suspicious activity.

Security Testing

We periodically review and improve our security controls, backup practices, recovery procedures, and security testing.

No information system can guarantee absolute security.

13. Service Providers and Third Parties

Amoviti does not sell personal information.

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

We use selected third-party service providers to operate the Services.

These providers fall into two categories:

1. Service providers that process information on our behalf; and
2. Companies that independently process payment transactions under their own terms and privacy policies.

Service Providers Processing Information on Our Behalf

Google Cloud

Google Cloud provides cloud infrastructure and services used to store data and operate Amoviti.

Google Cloud services used by Amoviti include Document AI and Vertex AI for applicable document-processing and AI functionality.

RevenueCat

RevenueCat manages subscription information across supported web, iOS, and Android purchasing channels.

RevenueCat may receive an Amoviti account identifier and subscription information such as plan, status, and applicable dates.

RevenueCat does not receive your payment-card number from Amoviti.

ZeptoMail

ZeptoMail delivers Amoviti emails, including authentication codes, service notifications, and emergency notifications.

ZeptoMail may receive the applicable recipient email address and message content.

Cloudflare

Cloudflare provides network delivery, traffic management, and security services.

Cloudflare may process network connection information necessary to provide these services.

Cloudflare does not receive the contents of documents merely because it provides network and security services.

PostHog

PostHog provides product analytics that help us understand how the Services are used, only when you have enabled analytics.

PostHog may receive the analytics information described in Section 18, including a pseudonymous identifier, your Amoviti account identifier once you sign in, and network information from which an approximate location is derived. PostHog does not receive the contents of your documents or records.

Advertising Measurement

The company below is not a service provider acting only on our instructions. It receives a limited, assessment-only signal and uses it under its own terms as an independent business.

Meta (Facebook) Pixel

Meta Platforms, Inc. provides the Meta Pixel, which we use to measure the effectiveness of our advertising. It runs only when you have enabled analytics, and only on our public Family Preparedness Score pages — never on signed-in pages.

When it runs, Meta may receive that your browser started or completed the public assessment, together with a Meta-set cookie and network information, and may use this under its own terms to attribute and optimize advertising and to build audiences. Meta does not receive the contents of your documents or records, your Amoviti account identifier, your name, or your email through the Pixel.

Payment Providers

Stripe

Stripe processes web-based payments under Stripe’s own terms and privacy practices.

Your payment-card information is provided directly to Stripe and is not stored by Amoviti.

Apple

Apple processes purchases made through the Apple App Store under Apple’s terms and privacy practices.

Amoviti receives information necessary to determine the applicable subscription and purchase status.

Google Play

Google processes purchases made through Google Play under Google’s applicable terms and privacy practices.

Amoviti receives information necessary to determine the applicable subscription and purchase status.

Service Provider Changes

The service-provider list above reflects the providers used as of the Last Updated date.

If Amoviti adds a service provider that will materially process personal information, we will update this section as required by applicable law.

Services Not Currently Enabled

The following services are implemented or available within our technical environment but are not currently enabled for production processing of your information:

• Sentry; and
• Twilio.

Neither provider is currently intended to receive your personal information through active production use.

If either service is enabled for production processing, this Privacy Policy will be updated as appropriate.

14. Legal Disclosures and Business Transfers

Amoviti may disclose personal information when reasonably necessary to:

• Comply with applicable law;
• Respond to a valid subpoena, court order, or lawful government request;
• Protect the rights, safety, security, or property of Amoviti, our users, or others;
• Detect or investigate fraud, abuse, security incidents, or unlawful activity;
• Establish, exercise, or defend legal claims;
• Enforce our Terms of Service; or
• Facilitate a corporate transaction.

Corporate transactions may include:

• Merger;
• Acquisition;
• Financing;
• Corporate restructuring;
• Bankruptcy; or
• Sale or transfer of assets.

Where personal information is transferred as part of such a transaction, we will take reasonable measures to protect the information and provide legally required notices.

15. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• Provide the Services;
• Maintain security;
• Prevent fraud and abuse;
• Comply with legal, tax, and accounting requirements;
• Resolve disputes; and
• Establish, exercise, or defend legal claims.

Retention periods vary depending on the type of information.

Unless otherwise stated:

• Account records are retained while your account remains active;
• Audit records are retained for seven (7) years;
• Analytics information is retained for two (2) years; and
• Support correspondence is retained for three (3) years.

Billing Records

After account deletion, we may retain limited billing-related information, including:

• Amounts charged;
• Records concerning automatic-renewal authorization;
• Applicable transaction information;
• Refund information; and
• Payment-dispute information.

Such information may be retained for seven (7) years after the end of the year of the applicable last payment where necessary for legal, tax, accounting, fraud-prevention, or dispute-resolution purposes.

Where reasonably possible, retained billing records are separated from active account information.

16. Account Deletion

You may request deletion of your Amoviti account through Settings → Privacy & Data.

When you initiate account deletion, the account enters a ninety (90) day recovery period.

During this period, signing back into the account may restore the account and cancel deletion.

After the recovery period:

• Documents are permanently deleted;
• Contacts are permanently deleted;
• Assets are permanently deleted;
• Plans and workflows are permanently deleted; and
• Other account information is deleted in accordance with our deletion processes.

Backup copies are scheduled for deletion within thirty (30) additional days.

Certain limited information may be retained after account deletion when necessary to:

• Comply with applicable law;
• Maintain security;
• Prevent fraud or abuse;
• Resolve disputes;
• Process refunds or payment disputes;
• Establish or defend legal claims; or
• Maintain required financial and tax records.

Individual records that you delete may be removed from active systems before the account’s full deletion process is completed, subject to applicable backup and legal-retention requirements.

17. Cookies and Local Browser Storage

Amoviti uses limited browser storage and cookies necessary to operate the Services.

Authentication information is maintained using browser storage rather than a traditional authentication cookie where supported by the applicable application.

A limited session cookie may be used when a person:

• Opens a document shared through Amoviti; or
• Uses the emergency portal.

Such sessions expire after thirty (30) minutes of inactivity and will not remain valid for more than twenty-four (24) hours.

Where technically applicable, the cookie is configured so that it cannot be accessed by ordinary browser scripts.

Amoviti may also store certain information locally in your browser or device to operate the Services, including:

• Unfinished drafts;
• Theme preferences;
• Recent searches;
• Preparedness Score answers before account creation;
• Temporary working files;
• Offline application resources; and
• On-device document-processing resources, where supported.

Clearing your browser or application data may remove locally stored information.

18. Analytics and Advertising

Amoviti does not display advertising inside the Service.

We do not operate, or show you inside the Service:

• An advertising network; or
• Advertising shown to you inside the Service.

Amoviti uses Google Analytics for Firebase and PostHog for product analytics. We also use the Meta (Facebook) Pixel on our public Family Preparedness Score pages to measure and improve our own advertising, as described below.

The Meta Pixel is a small piece of code from Meta Platforms, Inc. It runs only on our public Family Preparedness Score pages, and only when analytics is enabled. It tells Meta when a visit to those pages starts the assessment and when it is completed, so we can measure how our advertising performs and reach similar audiences; it sets a Meta cookie in your browser. It does not run on signed-in pages, and Meta does not receive the contents of your documents or records, your name, or your email through it. It is governed by the same analytics on/off choice described above and on the Your Privacy Choices page.

Analytics is enabled by default. You can turn it off at any time — on our Your Privacy Choices page, which does not require an account, or through the applicable Amoviti settings once you have an account. A choice made before creating an account is carried into your account settings.

If your device’s time zone indicates that you are in the European Economic Area, the United Kingdom, or Switzerland, or your account address is in Québec, analytics is disabled by default and is activated only when you agree to it. Until you agree, we count visits anonymously: nothing is stored on your device, no identifier is created, and the visit is not linked to you or your account. In the mobile app, nothing is collected in these regions until you agree.

When analytics is disabled, Amoviti does not use these analytics services to collect analytics information from you.

When analytics is enabled, it may include the pages you visit, how you arrived (such as the referring website and campaign tags in the link), your approximate location derived from your network address (country, region, or city), your device and browser type, and actions such as starting or completing the assessment, creating an account, and signing in. It does not include the contents of your documents or records, or one-time codes and links used to sign in.

When analytics is enabled, these services store an identifier in your browser or device to recognize repeat visits. Analytics is never used on pages opened by emergency contacts, shared-document recipients, or invited contacts.

19. Global Privacy Control and Other Privacy Signals

Certain browsers may transmit privacy signals, including Global Privacy Control (GPC) or Do Not Track (DNT).

Amoviti does not sell personal information or use personal information for targeted advertising.

Accordingly, there is currently no sale or targeted-advertising processing for these signals to disable.

If our practices change in a manner that makes a privacy signal legally applicable, Amoviti will honor that signal to the extent required by applicable law and will update this Privacy Policy.

The analytics control in Amoviti Settings is the currently available control for analytics.

20. Children’s Privacy

Amoviti accounts are intended for individuals who are at least eighteen (18) years old.

Amoviti is not directed to children under thirteen (13), and we do not knowingly collect personal information directly from children under thirteen (13) to create accounts.

Children may nevertheless appear in an account because a parent or guardian may voluntarily add information about a child to the parent’s family records.

For example, an account may contain:

• A child’s birth certificate;
• A child’s passport;
• A child’s date of birth;
• Information concerning a child’s citizenship or nationality; or
• Other family information.

The child’s information is provided by the account owner and is processed as part of the household’s records.

Children do not have independent Amoviti accounts under the household account structure.

Where applicable, Amoviti may use a child’s date of birth to support age-appropriate record suggestions within the Family feature.

A child’s information is not used for advertising.

If we learn that an individual under eighteen (18) has created an account in violation of our Terms, we may suspend or close the account and take appropriate steps regarding the information associated with it.

If you believe a child has created an Amoviti account or directly provided personal information to Amoviti, contact:

privacy@amoviti.com

We will investigate and take appropriate action consistent with applicable law.

21. Your Privacy Rights and Choices

Depending on where you live, you may have rights concerning your personal information.

Regardless of location, Amoviti provides the following controls where applicable:

• Access information maintained in your account;
• Correct information through your account;
• Delete individual records;
• Delete your account;
• Export your account information;
• Enable or disable analytics;
• Manage applicable communications; and
• Contact Amoviti regarding privacy concerns.

Export and account deletion are available through:

Settings → Privacy & Data

Security verification may be required before an export or deletion request is completed.

Depending on applicable law, you may also have rights to:

• Access personal information;
• Correct inaccurate personal information;
• Delete personal information;
• Obtain personal information in a portable format;
• Opt out of certain processing;
• Withdraw consent where consent is the legal basis for processing;
• Appeal certain privacy decisions; and
• Lodge a complaint with a privacy regulator.

We may need to verify your identity before fulfilling a request to protect against unauthorized disclosure, modification, or deletion.

To submit a privacy request, contact:

privacy@amoviti.com

22. Colorado Privacy Rights

If you are a Colorado resident and the Colorado Privacy Act (CPA) applies to Amoviti’s processing of your personal data, you may have rights including:

Right to Access

You may request confirmation of whether Amoviti processes your personal data and obtain access to applicable personal data.

Right to Correct

You may request correction of inaccurate personal data.

Right to Delete

You may request deletion of personal data, subject to applicable exceptions.

Right to Data Portability

You may request your personal data in a portable and, to the extent technically feasible, readily usable format.

Right to Opt Out

You may have the right to opt out of:

• Sale of personal data;
• Targeted advertising; and
• Certain profiling that produces legal or similarly significant effects.

Amoviti does not currently sell personal data, conduct targeted advertising, or engage in profiling of the type described above.

Sensitive Data

Colorado law provides additional protections for sensitive data, including certain information relating to citizenship, health, and children under thirteen.

Where applicable law requires consent for sensitive-data processing, Amoviti will obtain the required consent.

Submitting a Colorado Request

Submit requests to:

privacy@amoviti.com

We generally respond within forty-five (45) days as required by applicable law, subject to applicable extensions.

If we deny a request, we will provide an explanation where required and provide information about the applicable appeal process.

23. California Privacy Rights

If you are a California resident and the California Consumer Privacy Act, as amended (CCPA), applies to Amoviti, you may have rights concerning your personal information.

These rights may include:

• The right to know;
• The right to access;
• The right to correct;
• The right to delete;
• The right to opt out of sale or sharing, where applicable;
• The right to limit certain uses or disclosures of sensitive personal information, where applicable;
• The right to non-discrimination for exercising applicable privacy rights; and
• Other rights provided by California law.

Amoviti does not sell personal information.

Amoviti does not share personal information for cross-context behavioral advertising.

Accordingly, there is currently no sale or advertising-sharing activity for California residents to opt out of.

Amoviti will not discriminate against you for exercising rights provided by applicable California law.

California residents may submit requests to:

privacy@amoviti.com

Authorized agents may submit requests on behalf of California residents where permitted by law and subject to applicable verification requirements.

24. California Notice at Collection

This section provides additional information concerning categories of personal information collected by Amoviti, the purposes for which those categories are used, and applicable retention periods.

Identifiers

Examples include:

• Name;
• Email address;
• Telephone number;
• Postal address;
• Account identifier;
• Applicable notification token; and
• Application-generated device identifier.

Purpose: Account creation, authentication, communication, security, and provision of the Services.

Retention: Generally while the account remains active, followed by the deletion and backup periods described in Section 16, unless otherwise required or permitted by law.

Customer Records and Family Information

Examples include:

• Documents;
• Contacts;
• Family relationships;
• Property information;
• Insurance information;
• Financial information;
• Tax information;
• Legal records;
• Estate-planning information; and
• Emergency instructions.

Purpose: Storage, organization, search, reminders, document processing, sharing, and continuity features.

Retention: Generally while maintained in the account or until deleted, subject to applicable deletion and backup periods.

Personal Characteristics

Examples include information such as:

• Date of birth;
• Citizenship;
• Residency status; and
• Marital status.

Purpose: Account profile, applicable product functionality, and record suggestions.

Retention: Generally while maintained in the account or until deleted, subject to applicable retention requirements.

Commercial Information

Examples include:

• Subscription plan;
• Subscription status;
• Billing period;
• Purchase information;
• Refund information; and
• Dispute information.

Purpose: Subscription administration, billing administration, accounting, fraud prevention, and legal compliance.

Retention: Subject to the periods described in Sections 15 and 16.

Internet or Other Electronic Network Activity

Where analytics is enabled, Amoviti may process information concerning interactions with the Services, including:

• Features used;
• Session identifiers;
• Timestamps;
• Platform; and
• Approximate region.

Purpose: Product analytics, troubleshooting, and improvement.

Retention: Generally up to two (2) years.

Sensitive Personal Information

Depending on what you choose to store, this may include certain government identifiers, immigration information, health information, or other information classified as sensitive under applicable law.

Purpose: Providing the Services requested by you and protecting the Services.

Retention: Generally according to the retention period applicable to the underlying account record.

Amoviti does not sell or share sensitive personal information for cross-context behavioral advertising.

Inferences

Amoviti may derive:

• Preparedness Score information;
• Document classifications;
• Document details;
• Expiration information; and
• Relationships between records.

Purpose: Providing the features you use.

Retention: Generally with the underlying records from which the information is derived.

Security and Audit Information

Amoviti maintains records of applicable security and account actions, including who performed an action and when.

Purpose: Security, fraud prevention, investigation, compliance, and accountability.

Retention: Generally seven (7) years.

Amoviti does not intentionally collect precise location information and does not create biometric identifiers from photographs contained in documents.

25. Canadian Privacy

Where the Personal Information Protection and Electronic Documents Act (PIPEDA) applies, Amoviti seeks to handle personal information in accordance with applicable PIPEDA requirements and principles, including:

• Accountability;
• Identifying purposes;
• Consent;
• Limiting collection;
• Limiting use, disclosure, and retention;
• Accuracy;
• Safeguards;
• Openness;
• Individual access; and
• Complaint handling.

The form of consent applicable to processing depends on the nature and sensitivity of the information and the circumstances of collection.

Amoviti uses technical and organizational safeguards appropriate to the sensitivity of the information, including encryption, access controls, confidentiality obligations, and security monitoring.

Access and Correction

Canadian users may request access to their personal information and request correction of inaccurate information, subject to applicable exceptions.

Withdrawal of Consent

Where consent is the applicable legal basis and withdrawal is permitted, you may withdraw consent by contacting:

privacy@amoviti.com

Withdrawal may not be possible where continued processing is necessary to provide the Services, comply with law, maintain security, or satisfy other legal requirements.

United States Processing

For Canadian users, Amoviti stores and processes account information and documents in the United States through Google Cloud’s United States infrastructure.

Information stored in the United States may be subject to lawful access requests by United States courts, law-enforcement agencies, and government authorities under applicable law.

Canadian Privacy Complaints

We encourage you to contact Amoviti first so that we can investigate and attempt to resolve your concern.

If you are not satisfied with our response, you may contact the privacy regulator with jurisdiction over your complaint, including the Office of the Privacy Commissioner of Canada, where applicable.

26. Where Your Information Is Processed

Amoviti operates from the United States.

Amoviti account information, documents, and records are stored and processed in Google Cloud’s United States region.

This applies to Canadian users as well as users in the United States.

Your Amoviti data is associated with the regional environment applicable to the Amoviti site or application you use.

Certain service providers may operate infrastructure globally.

As a result, limited operational information, such as:

• Network connection information;
• Email addresses;
• Payment information; or
• Subscription information

may be processed outside the United States or Canada where necessary for those providers to perform their services.

Your Amoviti documents and core account records are intended to remain within the applicable Amoviti Google Cloud United States environment, subject to the technical operation of the service and the disclosures in this Privacy Policy.

27. Individuals Who Receive Shared Information Without an Amoviti Account

Amoviti allows account owners to share certain documents with people who do not maintain an Amoviti account.

A recipient may be required to verify the email address designated by the account owner.

Amoviti may retain:

• The recipient’s email address;
• Verification information;
• Access information; and
• Security records associated with the shared document.

The underlying document remains associated with the account owner’s account.

Access to a shared document does not give the recipient ownership or authority to delete the underlying document from the account owner’s account.

If you receive an Amoviti shared document without having an Amoviti account, you may request deletion of personal information Amoviti maintains about you in connection with that shared access by contacting:

privacy@amoviti.com

If you believe Amoviti maintains personal information about you within a document belonging to another account holder, contact us.

We will evaluate the request under applicable law while considering the privacy and ownership rights of the account holder and other individuals identified in the document.

28. Security Incidents and Data Breaches

Amoviti maintains processes for identifying, investigating, containing, and responding to security incidents involving personal information.

If we determine that a security incident has occurred, we will take reasonable measures to:

1. Investigate the incident;
2. Contain and remediate the incident;
3. Assess potential risks;
4. Preserve relevant evidence;
5. Implement corrective measures; and
6. Provide legally required notifications.

Where applicable law requires notification to affected individuals, regulators, or other parties, Amoviti will provide the required notification within the applicable timeframe.

For Canadian users subject to PIPEDA, this includes assessing whether a breach of security safeguards creates a real risk of significant harm and complying with applicable reporting, notification, and record-keeping requirements when the statutory threshold is met.

Notifications may describe, as appropriate:

• What occurred;
• The information affected;
• Steps Amoviti has taken;
• Steps you may take to protect yourself; and
• Where to obtain additional information.

29. Changes to This Privacy Policy

Amoviti may update this Privacy Policy from time to time to reflect changes in:

• The Services;
• Technology;
• Security controls;
• Service providers;
• Legal requirements; or
• Our privacy practices.

The Last Updated date at the top of this Privacy Policy identifies the current version.

If we make a material change to this Privacy Policy, we will provide notice as required by applicable law. Depending on the nature of the change, notice may be provided by:

• Email;
• In-app notification;
• Website notice; or
• Other appropriate communication.

Where applicable law requires affirmative acceptance of a material change, we will obtain that acceptance before applying the change.

We will not represent that a privacy or security control is active when it is not.

If a previously described privacy or security capability is materially changed, enabled, or disabled, we will update this Privacy Policy as appropriate.

You may request a copy of a previous version of this Privacy Policy by contacting:

privacy@amoviti.com

30. Contact Us

If you have a privacy question, request, complaint, or concern, please contact our Privacy Officer.

Privacy Officer

Email: privacy@amoviti.com

We encourage you to contact us first so that we can understand your concern, investigate it, and attempt to resolve it.