ElevmiTM Application Privacy Notice
Last Updated: December 16, 2025
PRIVACY NOTICE
Welcome to the Otsuka Precision Health, Inc. (“OPH/we/us/our”) Privacy Notice (“Privacy Notice”) for the ElevmiTM smartphone application and associated online services (“Application”). This Application is intended for use by individuals caring for loved ones with Alzheimer’s, dementia, or similar conditions. This Privacy Notice applies to users of the Application (“you/your”) and explains how your information is collected, used, shared, and protected by OPH.
This Application is not subject to the Health Insurance Portability and Accountability Act and is instead governed by the terms of this Privacy Notice.
This Privacy Policy applies to personal information we collect, use and share when you use the Application. OPH may also process your personal information using AI Tools, which are any software application that incorporates AI technology, and this Privacy Notice provides you with information about how our AI Tools treat and protect the information they process, including any personal information.
Please read this Privacy Notice carefully, as it describes how we may use and disclose your personal information (“PI”). From time to time, we may supplement this Privacy Notice with additional information about our privacy practices related to a particular feature of the Application. We may also request express consents related to certain uses and disclosures of your PI, such as when you register an account in the Application. If you do not agree with the terms of this Privacy Notice, please refrain from using the Application. Please see our Terms of Use regarding your legal rights in any dispute involving our Application.
The Application must be installed on your mobile device for use and certain PI
as described in this Privacy Notice will be received by OPH, its third-party
partners; and services providers, as described in this Privacy Notice. To begin
using the Application, you will need to enter your email address and verify
your email address by entering the one-time password (OTP) access code provided
to you. You will then be prompted to create a user account with your first name
and ZIP Code. In order to protect your privacy, do not share your mobile phone passwords, PIN, pattern
lock codes, or the Application one-time password (OTP) access codes sent to
your verified email address with anyone.
As part of the onboarding process in the Application, you will have the option to consent to participate in receiving notifications via push notifications. Where you have consented to receive such notifications, you authorize us to make or initiate notifications to your mobile phone. You acknowledge and understand that any push notifications you consent to receive from OPH may be unencrypted and carry some risk that the information in the messages could be read by an unauthorized person. You further acknowledge and understand that we cannot guarantee the security and confidentiality of the unencrypted communications that we send to you, and we are not responsible for any unauthorized access that occurs during or after the transmission of the communications to you.
We collect a few categories of PI through the Application, including: (1) information you affirmatively provide to us about you and your Loved One; and (2) device and user activity information that is automatically collected by the Application, as further described below.
We may also collect your personal information using AI Tools (software applications that incorporate AI technology). Our AI Tools may be used to collect your personal information, such as when you directly provide it using prompts or questions, or uploading documents or other content into an AI Tool. The AI Tool may process this personal information. Our AI Tools also capture some information about you automatically when you use them. As previously mentioned, automatically collected information may include browser type, operating system, Internet Protocol (IP) address, domain name, and/or a date/time stamp for your visit.
We use and share your PI outside OPH, including with third-party partners and service providers, as described in this Privacy Notice, in a manner consistent with your consent choice, and otherwise pursuant to the Terms of Use.
Specifically, we may use and share your PI consistent with applicable laws for the following purposes:
With your consent, or as otherwise disclosed at the
time your personal information may be collected by AI Tools in connection with
our Services, we may use your personal information processed by AI Tools for
the following purposes:
· To process payments and to provide and improve user support;
· To understand your preferences and tailor your responses in connection with our Services;
· To operate, customize, and improve our AI Tools, including analytics;
· To provide product-related assistance to users;
· To transcribe voice and text-based interactions with users;
· To detect fraudulent and suspicious transactions and activities;
· With the consent of our users, or as otherwise disclosed at the time information is collected.
Ø For Attribution and Analytics. We use certain user and device data (e.g., device information, IP address, advertising IDs, App usage data) for attribution, analytics, and measurement purposes. For example, we may use third parties, such as AppsFlyer, for mobile analytics and performance tracking and understanding the efficacy of our advertising efforts.
Ø To Develop Other Products and Services. With your consent, we may use and disclose your PI to engage in research and development activities to develop new features of the Application or other products or services. For example, we may collect data regarding your experience with the Application to better understand how it works for you and other users in order to conduct market or product research, research and develop new products and services that could benefit from such insights.
Ø To Create De-Identified Information. With your consent, we may use your PI to create De-Identified Information to conduct research and development activities to develop new features of the Application or other products or services; conduct and publish scientific research; or for other purposes permitted by applicable law. As discussed above, this Privacy Notice does not apply to De-Identified Information.
We may also use PI as we believe to be necessary or appropriate for certain essential purposes, including:
Ø To Investigate or Address Suspected Wrongdoing. We may use and share PI with third parties when we believe it is necessary to investigate, prevent or take action regarding safety and security issues, illegal activities, suspected fraud or situations involving potential threats to the physical safety of any person.
Ø In Connection with Corporate Changes. We may use and share your PI with third parties if OPH is involved in a merger, acquisition, sale of all or a portion of its assets, bankruptcy, or other corporate restructuring.
We use and share your PI as described in this Privacy Notice and the Terms of Use for the Application, and otherwise pursuant to your consent or direction. Specifically, we may use and share your PI consistent with applicable laws for the following purposes:
Ø We may share your PI using AI tools and with our third parties. Our AI tools may use language models and technology licensed from third parties, or our Application may include third-party software that uses, stores, and processes language models. To operate our AI Tools, we may share data you entered into them with these third parties. We require these third parties to keep your personal information secure, and we do not permit them to use or share your personal information for any purpose other than for the Application.
We are committed to protecting the privacy and security of your information. We may use and share your Application data for the purposes described in this notice and in a manner consistent with your privacy choices.
Ø Accessing your Application Information. You can access almost all the information you have input into the Application at your convenience once you have completed the onboarding process and you start using the Application under the “Care Log” icon in the main navigation menu. The main navigation menu is always accessible at the bottom of each screen. You can access, edit, update, or remove any information you entered during the onboarding process by tapping the “More” option in the main navigation menu, and clicking on ‘Personal Profile’ and ‘Your Loved One’ option under the Settings menu. You can also request a copy of all of the PI you input into the Application and your privacy choices made in the Application by calling us at 1-833-468-7852 or emailing us at privacyofficer@otsuka-oph.com.
Ø Withdrawing Consent. If you disagree with the terms in this Privacy Notice, your sole and exclusive remedy is to discontinue your use of the Application. Your continued use of the Application constitutes your acceptance of this Privacy Notice. Where you have consented to OPH processing your PI in the Application, you may withdraw those consents at any time, as indicated below in the “In-Application Consent Changes” section below or by submitting a privacy request to OPH by calling us at 1-833-468-7852 or emailing us at privacyofficer@otsuka-oph.com. We will process your request to withdraw your consent choices, in our reasonable discretion subject in all cases to the deadlines and other requirements of applicable laws. Any PI collected prior to the processing of your withdrawal request may be used or shared by OPH in accordance with your consent choices and as described in this notice. Users in certain states have the right to appeal our decisions on these requests. To appeal our decision on your request, you may contact our Privacy Office at 1-833-468-7852 or emailing us at privacyofficer@otsuka-oph.com.
Ø Withdrawal from Future Collection of PI. You can stop future processing of your PI Application by selecting “Delete Account” in the Application under “More” by tapping the “Personal Profile” option on the main Settings menu or discontinuing your use of the Application. Uninstalling the Application from your device using the standard uninstall process available on your device will not operate to delete your account and any PI collected prior to your uninstall may continue to be retained by us and used or shared as described in this notice, unless you delete your account in the Application as described above and then contact us to request that we delete the prior information as indicated below in the “Deletion of Application Account Information” section, we have processed prior to your uninstallation of the Application.
Ø In-Application Consent Changes. You can change your privacy choices in the Application, once you have completed the onboarding process and you start using the Application under “More” by tapping the “Your Privacy Choices” option in the main Settings menu. You can also change any of your privacy choices made in the Application by calling us at 1-833-468-7852 or emailing us at privacyofficer@otsuka-oph.com. As noted in the Terms of Use for the Application, some Application features and services may not be accessible at certain times and periods, for any reason, which include if your smartphone is not connected to an internet service. Where your smartphone is not connected to the internet and you modify or withdraw your consent elections in the Application, the Application will process such requests once your smartphone is re-connected to the internet. We will process these requests in our reasonable discretion subject in all cases to the deadlines and other requirements of applicable laws. Any PI collected prior to the processing of your offline request may be retained by us and used or shared in accordance with your consent choices and as described in this notice.
Ø Updating User Information. Within the Application you will be able to update or edit most your profile information and your Loved One’s information, once you have completed the onboarding process and you start using the Application under “More” and then tapping the “Personal Profile” and “Your Loved One” option in the main Settings menu. You can tap the “Care Log” icon in the main navigation menu to modify any previously logged Observations, completed Check-ins, Appointments, or information in Notes. If you want to update or modify the email address you use to set up your Application account, you must contact customer support at 1-833-468-7852. If you want to delete the email address you used to set up your Application account, your sole and exclusive remedy is to delete your account in the Application as indicated below in the “Deletion of Application Account Information” section and create a new account.
Ø Deletion of Application Account Information. At any time after you have elected to delete your account in the Application, you can contact us to request that we delete the PI that was processed during your use of the Application. We will process your request to delete your Application Account PI, including any backup copies automatically generated by the Application, in our reasonable discretion, subject in all cases to the deadlines and other requirements of applicable laws. Note that deletion requests are subject to a number of limitations, for example, we may keep PI as permitted by law, such as for tax, legal, or other record keeping purposes, to maintain your account, and for other internal business purposes as permitted by law and described in this Privacy Notice. Users in certain states have the right to appeal our decisions on these requests. To appeal our decision on your request, you may contact our Privacy Office at 1-833-468-7852 or emailing us at privacyofficer@otsuka-oph.com.
Ø Application-Notification Changes. If after you have consent to receive push notification you do not want to receive future notification messages from the Application, using your mobile device, you should locate the settings menu in your mobile phone, tap the “Notifications” icon, and disable push notifications for the Application. If you require live technical support to opt-out of push notifications, reach out to customer support at 1-833-468-7852.
Ø Commercial Email Opt-out. To the extent we are permitted by law to send you any market research or promotional emails, you can opt-out of such communications by following the instructions contained in the communication Application or notifying us via the contact information for our privacy officer provided below. If you do opt-out of receiving messages from us, we may still send you important messages related to your use of the Application and new features or updates.
Ø Other Privacy Practice Questions. You can also ask other questions about OPH’s privacy practices by contacting our Privacy Office at 1-833-468-7852 or emailing us at privacyofficer@otsuka-oph.com.
Ø Agent Designation. You may authorize another person (your "Agent") to submit a request to withdraw or modify your privacy elections, by submitting any such privacy requests by calling us at 1-833-468-7852 or emailing us at privacyofficer@otsuka-oph.com. Shortly after you (or your Agent) submit a request, we will contact you (usually via email) with instructions on how to verify the submitted request before we fulfill it.
In addition to your privacy choices as described in the section above, we provide any additional privacy rights with respect to our collection, use or disclosure of your PI afforded by applicable laws (including but not limited to the California Consumer Privacy Act and similar laws in other states):
You can submit any such privacy requests by calling us at 1-833-468-7852 or email at privacyofficer@otsuka-oph.com. Shortly after you (or your Agent) submit a request, we will contact you (usually via email) with instructions on how to verify the submitted request before we process your request. We will fulfill these requests in our reasonable discretion subject in all cases to the deadlines and other requirements of applicable laws. Users in certain states have the right to appeal our decisions on these requests. To appeal our decision on your request, you may contact our Privacy Office using the contact information provided below. We may not, and will not, discriminate against anyone for exercising their privacy rights. We do not provide a financial incentive or a price or service difference to anyone in exchange for collection, retention, or sale of their PI.
For Nevada residents, please note that we do not sell PI as defined by Nevada law, but you can submit any privacy requests to us via the contact information provided below.
We will retain the PI described in this Privacy Notice for as long as necessary for the purposes for which it was collected, to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Our application is primarily intended for use within the United States. While our primary data centers are in the United States, we may transfer information outside of the United States. By providing your PI, you consent to any transfer and processing in accordance with this Privacy Notice and understand that we operate under applicable laws within the United States.
Ø Application Safeguards. The security of PI provided to OPH is important to us, and we take reasonable steps designed to protect your PI. We maintain safeguards intended to protect your PI. The Application was designed to include physical, administrative, and technical safeguards.
Ø Risk of Security Incidents. Although we endeavor to secure PI, we cannot guarantee such security because no systems are invulnerable to all security threats. In the event we discover a security incident impacting your PI, where required, we will provide notice to you and to applicable regulators as required by applicable law. To the extent the law allows us to provide such notification to you via e-mail, you agree to accept notice in that form.
Ø Your Responsibilities. The Application does not have a smartphone device-level PIN or password. If you are logged out, access can be granted through a one-time password (OTP) sent to the verified email address linked to your Application account. You are responsible for the security of your password. Do not share your password with anyone. You are also responsible for safeguarding and securing your smartphone. If you leave your smartphone unattended, or if it is lost or stolen, you understand that your PI in the Application may be accessible to others.
As noted in our Terms of Use, the Application is only intended and permitted for use by individuals at least 18 years of age. Minor children are not eligible to use the Application, and we ask that they do not submit any PI to us. We do not knowingly attempt to solicit or receive any information from minor children and if you become aware that a minor has provided us with any PI through the Application, please contact us at privacyofficer@otsuka-oph.com. We will endeavor to delete such information from our files within a reasonable time.
Our Application may contain links to third party websites or applications. Please be aware that we are not responsible for the content or privacy practices of such third parties’ websites, applications, or services, and we encourage you to read the privacy statements of any such parties.
This Privacy Notice may be updated from time to time in our discretion. We will post any revised Privacy Notice to the Application and the changes will be effective upon posting. We encourage you to review the Privacy Notice periodically.
If you have any questions regarding our privacy practices in connection with the Application, contact us either by phone at 1-833-468-7852, via email at: privacyofficer@otsuka-oph.com, or by regular mail to: Otsuka Precision Health, Inc., Attn: Privacy Officer, 508 Carnegie Center Drive Princeton, NJ 08540
December 2025 24US25EUC0080