1. Introduction
Equilybrium ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our wellness monitoring platform — including our web application, mobile app (iOS and Android), desktop agent and browser extension.
2. Information We Collect
2.1 Health Data
- Stress and fatigue levels from device sensors
- Activity patterns and work break frequency
- Sleep quality and duration (if connected)
- Digital wellness scores and burnout risk indicators
- Browser usage patterns and digital behavior
- Productivity metrics and focus patterns
2.2 Personal Information
- Full name and email address
- Job title and department
- Company/organization affiliation
- Contact preferences and settings
- Account credentials (encrypted)
- Profile preferences and customizations
2.3 Mobile App Data Sources
When you install the Equilybrium iOS or Android app and grant the corresponding permissions — always with your explicit, revocable consent collected before any data is gathered — the app collects the following data sources directly from your device. All processing happens locally on your phone: your wellbeing score is computed on-device, and, by default, only the score and derived wellness indices are transmitted to our servers. Raw health data is transmitted only if you explicitly opt in to our research programme — a separate, revocable consent you can give or withdraw at any time in Settings → Privacy. Without that opt-in, no raw health data leaves your device.
- Health data via Apple HealthKit (iOS) or Health Connect (Android): sleep stages, heart rate variability, steps, active calories, exercise minutes
- Screen Time via DeviceActivity / Family Controls (iOS) or UsageStatsManager (Android): total daily screen time and time buckets (morning, afternoon, evening, night). App names are processed in memory only — never persisted or transmitted
- Calendar via EventKit (iOS) or CalendarProvider (Android): meeting counts, durations, and back-to-back patterns. Meeting titles, attendees, and locations are NEVER read or stored
- Motion via CMMotionActivity (iOS) or ActivityRecognition (Android): activity patterns (walking, stationary, exercise) used only for wellness context
- Notification engagement counts on Android (via NOTIFICATION_SEEN events, API 28+): aggregate counts of mail and messaging notifications seen. Notification content is never read
- Anonymous device identifier (identifierForVendor on iOS, secure hash of ANDROID_ID on Android) for device registration only — not linked to any cross-app tracking
3. How We Use Your Information
- Detect and fix technical problems using Desktop Agent diagnostics: anonymized error reports sent automatically (no personal data — you can turn this off in the agent's Privacy settings) and log bundles you choose to send to our support team
- Provide personalized wellness analytics and insights
- Detect early signs of burnout and stress patterns
- Generate reports and recommendations for you and your organization
- Improve our AI algorithms and predictive models
- Communicate important updates and wellness alerts
- Ensure platform security and prevent fraud
- Comply with legal obligations and regulatory requirements
4. Data Security
- End-to-end encryption for sensitive health data
- TLS/SSL encryption for all data in transit
- AES-256 encryption for data at rest
- Role-based access controls and authentication
- Regular security audits and penetration testing
- SOC 2 Type II compliance processes
- Multi-factor authentication for admin access
5. Data Retention
| Data | Retention policy |
|---|---|
| Diagnostic Data | Agent error reports retained 90 days; support log bundles retained 30 days |
| Account Data | Retained while account is active |
| Health & Wellness Metrics | Retained for 3 years after collection |
| Browser Extension Data | Retained for 90 days after collection |
| Research Data (opt-in only) | Raw research bundles retained for 90 days |
| Aggregated Analytics | Retained indefinitely in anonymized form |
| Backup Data | Retained for 30 days after deletion request |
| Legal Compliance Data | Retained as required by law |
6. Your Rights
Under GDPR, LGPD, and other privacy regulations, you have the right to:
- Access: Request a copy of your personal data
- Rectification: Correct inaccurate or incomplete data
- Erasure: Request deletion of your personal data
- Portability: Receive your data in a structured format
- Restriction: Limit how we process your data
- Objection: Object to certain types of processing
- Withdraw consent: Revoke consent at any time — health data collection stops immediately when consent is withdrawn (in-app: Settings → Privacy)
Data export and deletion are available directly in the mobile app (Settings → Privacy) and web application, or by contacting dpo@equilybrium.health.
7. Data Sharing
We may share data only:
- With your organization (aggregated and anonymized data only)
- With service providers under strict data processing agreements
- With law enforcement when legally required
- With your explicit consent for specific purposes
- During business transfers with equivalent privacy protections
- To protect our rights and prevent fraud or abuse
8. Professional Data Access
When you voluntarily share your wellness indicators with a licensed mental health professional, the following data-protection rules apply:
- Scope: the professional sees only the indicators you have explicitly toggled on (score, trend, behavioral drivers), for the time window and history depth you selected.
- Nature: the professional accesses observational well-being data, not clinical records. Equilybrium is not a Software as a Medical Device under FDA, ANVISA, or Health Canada classifications.
- Audit trail: every access is logged with timestamp, endpoint accessed, and an immutable snapshot of the professional's name and license number. You can review this log at any time in Settings → My Shares.
- Retention: audit logs are retained for 90 days after consent revocation, for compliance verification under LGPD, HIPAA, and PIPEDA. Wellness indicators stop flowing immediately on revocation.
- Revocation: a single click revokes any share. Revocation takes effect immediately and the professional loses access at their next request.
- Legal basis: explicit consent under LGPD art. 7º, II + art. 11 (Brazil); PIPEDA Principle 4.3 — Consent (Canada); applicable US state privacy laws (United States). Equilybrium is a wellness platform and does not operate as a HIPAA-covered entity. Equilybrium acts as data controller; the professional acts as an authorized read-only viewer.
- Cross-border: if you share with a professional in a different jurisdiction than yours, your data will be processed under both jurisdictions' laws; this is disclosed at consent time.
9. International Data Transfers
If we transfer data internationally, we ensure appropriate safeguards including:
- Standard Contractual Clauses (SCCs) approved by the European Commission
- Adequacy decisions for transfers to approved countries
- LGPD, GDPR, CCPA, and PIPEDA-compliant data processing agreements
- Regular assessments of international transfer safeguards
- Encryption during all international data transfers
10. Children's Privacy
Our service is not intended for children under 16. We do not knowingly collect data from children without parental consent.
11. Contact Information
For privacy-related questions or to exercise your rights, contact:
- Privacy inquiries: privacy@equilybrium.health
- Data Protection Officer: dpo@equilybrium.health
Supervisory authorities:
- Canada: Office of the Privacy Commissioner of Canada
- European Union: Your local Data Protection Authority
- Brazil: National Data Protection Authority (ANPD)
- California, USA: California Privacy Protection Agency (CPPA)
- United Kingdom: Information Commissioner's Office (ICO)
12. Changes to This Policy
We may update this policy periodically. We will notify you of any material changes via email or in-app notification.