Privacy Policy

1. Who We Are and What This Covers

Citovelo Solutions LLC ("Citovelo," "we," "us") is a New York company that runs a platform connecting older adults and their families ("Posters" and "Care Recipients") with independent, screened providers ("Concierges") for non-medical help. This policy explains what information we collect, how we use and share it, how we protect it, and the choices you have. It covers our app and website. Citovelo currently operates only in the United States, beginning in New York State.

Please read it carefully. If you have questions, see Section 15.

2. Information We Collect

We keep it to what we need. We collect and keep only the information needed to run the service safely, process payments, meet legal duties, and handle insurance and disputes. If we don't need it, we don't ask for it.

We do not ask Posters for medical records or diagnoses.

3. How We Use Information

We use information to:

• Create and maintain accounts, and provide and improve our services;
• Verify identity, screen and monitor Concierges, and prevent fraud;
• Match Posters with suitable Concierges and schedule tasks;
• Process payments, tips, payouts, refunds, and cancellation fees;
• Provide our insurance program and handle claims;
• Provide safety features and respond to incidents and emergencies;
• Send notifications about tasks, messages, safety, and account activity;
• Provide customer support and resolve disputes;
• Analyze and improve the platform;
• Send marketing communications (only with your consent); and
• Comply with the law and enforce our Terms and policies.

4. Location

Concierge location is collected during active jobs for check-in and check-out, safety support, dispute handling, and insurance. Posters' location is collected only if you use a feature that needs it, such as finding nearby Concierges. You can change location permissions in your device settings. Turning location off may limit features, and a Concierge's insurance eligibility depends on location during active jobs.

5. Sensitive Information About Older Adults

Task details and notes may include sensitive information, such as health-related needs, mobility, routines, and home access details. We use this information only to help a Concierge perform a task safely, to provide support, to handle incidents and claims, and to meet legal duties. We do not sell it, and we do not use it for advertising.

6. How We Share Information

• With the other party to a task: limited to what is needed, such as first name, photo, rating, and the task address and contact details once a task is booked.
• With service providers: Stripe (payments and payouts), Checkr (background screening and monitoring), identity verification, cloud hosting and storage, email, text and notification services, customer support, and analytics providers (if used).
• With insurers and brokers: for coverage and claims.
• With emergency services, Adult Protective Services, and law enforcement: where we believe there is a risk to someone's safety or a legal duty to report.
• For legal reasons: to comply with the law or a legal process, enforce our terms, or protect rights, safety, and property.
• In a business transfer: in a merger, acquisition, or sale of assets, subject to this policy.

We do not sell personal information, and we do not share it with third parties for their own advertising.

7. Cookies and Similar Technologies

We use cookies and similar technologies to remember your preferences and settings, keep you signed in, analyze usage and improve performance, and enable features. You can control cookies in your browser settings. Turning them off may limit how the platform works.

8. Security

We use administrative, technical, and physical safeguards, including encryption in transit and at rest, access controls and authentication, secure payment processing through Stripe, regular security reviews and updates, and staff training on data protection. No system is perfectly secure, and we cannot guarantee absolute security. If a breach affects your information, we will notify you and regulators as the law requires.

9. How Long We Keep Information

We keep information only as long as we need it for the purposes in this policy, and no longer. After you close your account, we keep only what the law and our insurers require, and what is needed for fraud prevention and dispute resolution:

• Financial and transaction records: typically 7 years.
• Screening reports: only as long as the law and our insurance carrier require, as described in our Screening Policy, then securely destroyed.
• Other account, task, and safety records: only as long as needed for the purposes above, then deleted or de-identified.

When we no longer need information, we delete or de-identify it. We also limit who inside Citovelo can see it to the people who need it to do their jobs.

10. Your Choices and Rights

• Access and correction: you can view and update most of your information in your account settings.
• Portability: you can request a copy of your information in a portable format.
• Deletion: you can ask us to delete your account and information. We will keep what we are required or allowed to keep, such as transaction records, safety records, and records needed for disputes or insurance.
• Marketing: you can opt out of marketing messages using the link in each email, by replying STOP to texts, or in the app. Service and safety messages will continue.
• Screening reports (Concierges): your rights to see and dispute a background report are described in the Background Screening Disclosure & Authorization and the Screening Policy.
• State privacy laws: if you live in a state with a privacy law that gives you additional rights, such as California, we will honor them as we expand.

To make a request, contact us as described in Section 15. We may need to verify your identity first, and we will respond within 45 days.

11. Children

Our services are for adults 18 and older. We do not knowingly collect information from anyone under 18. If we learn that we have, we will delete it promptly.

12. Third-Party Links

The platform may link to other websites and services. We are not responsible for their privacy practices, and we encourage you to read their policies.

13. Changes to This Policy

We may update this policy. We will give at least 30 days' notice of material changes by email and in the app, and the updated policy will show a new effective date. Continuing to use the platform after the effective date means you accept the update.

14. Communications and Electronic Signature Consent

Communications. I agree that Citovelo may contact me by email, push notification, phone, and text message about my account, tasks, safety, insurance claims, and policy updates. I will receive marketing messages only if I opt in below. Message and data rates may apply. I can reply STOP to texts or change my preferences in the app.

• Optional: I agree to receive promotional messages.

Electronic records and signatures.

• I agree to sign electronically and to receive agreements, notices, disclosures, and tax forms from Citovelo electronically.
• My electronic signature has the same legal effect as a handwritten signature.
• I may ask for a paper copy of any document at no charge, and I may withdraw this consent by contacting Citovelo, though withdrawing may mean I can no longer use the platform.
• I need a device with internet access, a current browser or the app, and a PDF reader, and I will keep my email and phone number up to date.
• I can download and keep a copy of every document I sign from my account.

15. Contact Us

For privacy questions or to make a request:

16. Acknowledgment and Consent

By signing, I confirm that I have read this Privacy Policy and consent to the collection, use, and sharing of my information as described, and to electronic records, signatures, and communications.