Privacy Policy

hellopearl.app
For Families, Older Adults & Trusted Providers
Effective Date: November 2, 2026 (December 2, 2026 for existing accounts)
Last Updated: November 5, 2026

Provera Care Incorporated, operating under the trade name ProveraCare (“ProveraCare,” “we,” “us,” or “our”), is committed to protecting your privacy and safeguarding your personal information. This Privacy Policy explains how we collect, use, disclose, store, and protect information through the Pearl platform, including The Market.

What's changing with Ask Pearl: We're adding Ask Pearl, the assistant inside Hello Pearl. Sections 4 and 17 and Appendix A now explain what it sees, who processes it and what we keep. We'll ask for your consent before you first use it.

What changed on November 1, 2026: Hello Pearl now runs on servers operated by Google Cloud and Neon in the United States, and we added Pearl AI, which suggests the kinds of help in The Market that fit what you type. This update explains where your information is stored, what Pearl AI sees, and the service providers involved. If you had an account before November 2, 2026, these changes take effect for you on December 2, 2026. Our October 6, 2026 update added The Market, and it takes effect for accounts created before that date on November 5, 2026.

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1. Scope and Application

This Privacy Policy applies to all users of the Pearl platform accessible at hellopearl.app and through related mobile applications (the “Platform”), including Core Members (older adults, or anyone else at the centre of a Circle), Circle Members (family, friends, neighbours), Trusted Providers (service professionals added to a Circle), and Market Partners (businesses and organizations with a Listing in The Market). Capitalized terms that are not defined in this Privacy Policy have the meaning given in our Terms of Service.

This Privacy Policy has been designed to comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable privacy laws. Where multiple legal frameworks apply, we implement safeguards designed to meet or exceed applicable legal requirements.

Provera Care Incorporated is a federal corporation incorporated under the Canada Business Corporations Act (CBCA), with its mailing address at 2150 Winston Park Dr Unit 203 PMB #3024, Oakville, ON L6H 5V1, Canada. Platform data is stored and processed in the United States by our cloud service providers, Google Cloud and Neon. Section 14 and Appendix A explain these transfers, the other service providers involved, and how we protect your information.

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2. Accountability and Privacy Officer

In accordance with PIPEDA’s accountability principle, ProveraCare has designated a Privacy Officer who is responsible for our compliance with this Privacy Policy and applicable privacy legislation. The Privacy Officer oversees all aspects of our personal information management program, including responding to privacy inquiries, access requests, and complaints.

Privacy Officer

Provera Care Incorporated

Email:privacy@hellopearl.app

All inquiries, requests, and complaints related to privacy should be directed to the Privacy Officer at the contact information above.

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3. Information We Collect

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3.1 Information You Provide Directly

We collect the following categories of personal information that you provide when registering for and using the Platform:

  • Account Information: Name, email address, phone number, postal code, date of birth, and account credentials.
  • Profile Information: Profile photos, biographical details, role within a Circle (Core Member, family member, friend, provider), and relationship to the Core Member.
  • Circle Information: Names and contact information of individuals you invite to join a Circle, Circle settings, and permissions.
  • Coordination Content: Requests, tasks, reminders, events, schedules, notes, chat messages, and other coordination-related information shared within Circles.
  • Health-Adjacent Information: Information related to daily wellness, appointments, medication reminders, mobility needs, dietary requirements, and daily check-in responses, shared at your sole discretion. This information may constitute personal health information. Pearl does not require you to share health-related information to use the Platform. Any such information is uploaded voluntarily, and you are solely responsible for its accuracy and for managing who can see it within your Circle.
  • Payment Information: Billing address and payment card details (processed and stored by our PCI-DSS-compliant third-party payment processor; we do not store full payment card numbers).
  • Provider and Market Partner Information: Business name, service type, qualifications, credentials, service area, rates, and availability (for Trusted Providers), and Listing content, business contact details, and billing details (for Market Partners).
  • Market Information: Membership or eligibility details you choose to provide to unlock an offer, and any message, request, or booking details you choose to send to a Market Partner through the Platform.
  • Communications: Correspondence with our support team, feedback you provide about the Platform, and reports you send us about a Listing, Market Partner, Trusted Provider, or other user.

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3.2 Information Collected Automatically

When you access or use the Platform, we automatically collect certain technical and usage information:

  • Device Information: Device type, operating system, browser type, unique device identifiers, and mobile network information.
  • Usage Data: Pages visited, features used, time and date of access, referring URLs, clickstream data, and interaction patterns.
  • Market Activity: Searches, categories browsed, Listings viewed or saved, and offers you open or redeem in The Market.
  • Log Data: IP addresses, server logs, error reports, and diagnostic information.
  • Location Data: General geographic location based on IP address or a postal code you provide, which we use to show Listings near you. We do not collect precise GPS location data unless you explicitly enable this feature and provide consent.
  • Cookies and Similar Technologies: We use cookies and similar tracking technologies as described in Section 12 of this Policy.

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3.3 Information from Third Parties

We may receive information about you from third parties, including:

  • Trusted Providers who share updates about services provided to a Core Member within a Circle.
  • Circle Members who provide information about a Core Member or other Circle Members in the course of using the Platform.
  • Market Partners, for example to confirm that you redeemed an offer or to respond to a request you sent them.
  • Third-party service integrations that you authorize to connect with the Platform.

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3.4 Information Shared by Trusted Providers About Clients

Trusted Providers may invite existing clients to join the Platform and may share updates or information about services provided within a Circle. Trusted Providers are independently responsible for obtaining appropriate consent from their clients before sharing any personal information or Health-Adjacent Information through the Platform. ProveraCare does not direct or control what information Trusted Providers share and is not responsible for verifying that a Trusted Provider has obtained appropriate consent.

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3.5 Market Partner Listings

Information in Listings (such as business name, description, qualifications, prices, offers, and service area) is provided by Market Partners, not by ProveraCare, and is shown to people who use The Market. We do not independently verify Listings. Please see Section 6 of our Terms of Service for important information about The Market, including that we do not vet or endorse Market Partners and that you are responsible for doing your own checks.

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4. Purposes for Collecting, Using, and Disclosing Personal Information

In accordance with PIPEDA’s principle of identifying purposes, we collect, use, and disclose your personal information for the following purposes:

  • Provide and operate the Platform: To create and manage accounts, facilitate Circle coordination, process requests and tasks, enable chat and messaging, deliver The Market, and provide AI Features.
  • Operate The Market: To show Listings and offers relevant to your location and interests, confirm your eligibility for offers you choose to redeem, pass your request to a Market Partner when you ask us to, and give Market Partners aggregated, de-identified statistics about how their Listings perform.
  • Facilitate communication: To enable communication between Circle Members, Trusted Providers, and Core Members, including notifications, alerts, and reminders.
  • Process payments: To process subscription fees paid by users and listing fees paid by Market Partners through our secure payment processor. We do not process payments between users and Trusted Providers or Market Partners.
  • Improve and develop the Platform: To analyze usage patterns, diagnose technical issues, conduct research and analytics, and improve Platform features and user experience.
  • Provide AI-enabled services: To power Pearl AI, which suggests the kinds of help, services, and Listings in The Market that fit what you type, and Ask Pearl, the assistant that answers questions about your Circle and prepares actions you confirm. Section 17 explains what each one sees and who processes it.
  • Ensure safety and security: To detect and prevent fraud, unauthorized access, abuse, and other harmful activity, to review reports about Listings, Market Partners, and Trusted Providers, and to enforce our Terms of Service.
  • Legal compliance: To comply with applicable laws, regulations, legal processes, and government requests, including PIPEDA.
  • Communicate with you: To send service-related notices, updates, security alerts, and support and administrative messages. Marketing communications, including messages about offers in The Market, are sent only with your express consent, and you can unsubscribe at any time.

We will not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as required or permitted by law.

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5. Consent

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5.1 How We Obtain Consent

In accordance with PIPEDA’s consent principle, we obtain your consent for the collection, use, and disclosure of your personal information at the time of collection or before any new use or disclosure. Consent may be:

  • Express consent: Obtained through affirmative action, such as checking a consent box, signing up for the Platform, or providing explicit agreement for specific uses (e.g., marketing communications, sharing Health-Adjacent Information).
  • Implied consent: Inferred from your voluntary provision of information for an obvious purpose (e.g., providing your email address when creating an account implies consent to use it for account-related communications).

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5.2 Sensitive Information

We require express consent for the collection, use, or disclosure of sensitive personal information, including personal health information, financial information, and any information shared by or about a Core Member within a Circle. Health-Adjacent Information shared through the Platform (such as wellness check-ins, appointment details, and medication reminders) may constitute personal health information. We treat all such information with the highest level of protection.

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5.3 Withdrawing Consent

You may withdraw your consent to the collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions, by contacting our Privacy Officer at privacy@hellopearl.app. We will inform you of the implications of withdrawing consent, which may include our inability to provide certain features of the Platform. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

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5.4 Consent on Behalf of Others

If you are providing personal information about another individual (such as a Core Member), you represent and warrant that you have obtained the individual’s informed consent or that you have the legal authority to provide such consent on their behalf (e.g., as a substitute decision-maker under applicable law).

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6. Limiting Collection

We limit the collection of personal information to that which is necessary for the purposes identified in this Privacy Policy. We do not collect personal information indiscriminately and will not deceive or mislead individuals about the purposes for which information is collected.

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7. Limiting Use, Disclosure, and Retention

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7.1 Use and Disclosure

Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. We may disclose your personal information to:

  • Other Circle Members within your Circle(s), in accordance with Circle settings and permissions.
  • Trusted Providers who have been invited to a Circle, limited to information necessary to fulfill their role within the Circle.
  • Market Partners, only when you choose to contact them, send them a request, book with them, redeem their offer, or add them to your Circle, and only the information needed for that purpose (see Section 7.2).
  • Service providers who assist us in operating the Platform (e.g., cloud hosting, payment processing, analytics, customer support), subject to contractual obligations to protect your information.
  • Law enforcement, regulatory authorities, or other third parties when required by law, court order, or legal process, or when we believe disclosure is necessary to protect the rights, property, or safety of ProveraCare, our users, or the public, including to help prevent fraud or financial abuse where the law permits.
  • A successor entity in the event of a merger, acquisition, restructuring, or sale of assets, subject to a commitment by the successor to honour this Privacy Policy.

We do not sell or rent your personal information.

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7.2 Sharing with Market Partners

In plain language: we do not sell your information, and we do not hand it to businesses in The Market. A Market Partner receives your information only when you choose to contact them, book with them, redeem their offer, or add them to your Circle, and only what is needed for that.

When you take one of those actions, we share only the information needed for it, such as your name, your contact details, and the details of your request. Once a Market Partner receives your information, the Market Partner is responsible for it and its own privacy policy applies. ProveraCare does not control and is not responsible for how a Market Partner collects, uses, discloses, or protects your information. Under our Terms of Service, Market Partners must use your information only for the purpose you agreed to and must not add you to marketing lists without the consent the law requires.

We do not share Circle content, chat messages, or Health-Adjacent Information with Market Partners. If you add a Market Partner to your Circle, they become a Trusted Provider in that Circle and can see only what your Circle settings allow. We will not use Health-Adjacent Information to choose which Listings or offers you see, or share it with any Market Partner, without your express consent.

We may give Market Partners aggregated or de-identified statistics, such as how many times their Listing was viewed or an offer was redeemed. These statistics do not identify you.

Using The Market is optional. You can use Pearl’s core features without using The Market.

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7.3 Third-Party Websites and Connected Services

The Market may link to websites, apps, and services operated by others, or let you connect them to Pearl. When you leave Pearl or use a connected service, that third party’s privacy policy applies, not ours. If you connect a third-party service, we share only the information needed for the connection you authorize, and you can disconnect it, or ask us to disconnect it, at any time.

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7.4 Reports and Safety Concerns

If you report a concern about a Listing, Market Partner, Trusted Provider, or another user, we collect the information you give us and may review related information on the Platform. We may share relevant details with the person or business involved so they can respond, and we try not to reveal who made the report unless that is needed to address it or is required by law. Where the law allows, we may share information with law enforcement, regulators, or a person’s family member or authorized representative to help prevent fraud, financial abuse, or other harm.

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7.5 Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Specific retention periods include:

  • Account information: Retained for the duration of your account and for a period of two (2) years following account closure, unless a longer retention period is required by law.
  • Coordination Content (requests, tasks, messages): Retained for the duration of the Circle’s existence and for one (1) year after the Circle is closed or the Core Member’s account is terminated.
  • Health-Adjacent Information: Retained for no longer than necessary to fulfill the purpose for which it was collected.
  • Payment and transaction records: Retained for seven (7) years in accordance with Canadian tax and financial record-keeping requirements.
  • Market activity: Retained for up to two (2) years, or less if no longer needed to operate and improve The Market.
  • Reports and safety records: Retained for as long as reasonably needed to review the report, protect users, and meet our legal obligations.
  • Usage and log data: Retained for up to two (2) years for analytics and security purposes.

When personal information is no longer required, we will securely destroy, erase, or anonymize it in accordance with our data destruction procedures.

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8. Accuracy

We take reasonable steps to ensure that personal information in our custody is accurate, complete, and up to date for the purposes for which it is used. You are responsible for notifying us of any changes to your personal information. You may update your account information at any time through your account settings or by contacting us at privacy@hellopearl.app.

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9. Safeguards

We protect your personal information with administrative, technical, and physical security measures proportionate to the sensitivity of the information:

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9.1 Technical Safeguards
  • Encryption of data in transit using TLS 1.2 or higher and encryption of data at rest using AES-256 encryption.
  • Secure cloud infrastructure operated by Google Cloud and Neon in the United States.
  • Role-based access controls ensuring that only authorized personnel can access personal information.
  • Multi-factor authentication for administrative access to systems containing personal information.
  • Regular security assessments, penetration testing, and vulnerability scanning.
  • Automated monitoring and logging of system access and activities.

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9.2 Administrative Safeguards
  • Privacy and security training for all employees and contractors who handle personal information.
  • Confidentiality agreements with all employees, contractors, and third-party service providers.
  • Documented incident response and breach notification procedures.
  • Regular reviews and updates of security policies and practices.
  • Privacy impact assessments for new features and significant changes to data processing activities.

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9.3 Physical Safeguards
  • Platform data is hosted in data centres in the United States operated by our cloud service providers, Google Cloud and Neon (which runs on Amazon Web Services).
  • Physical access to these data centres is restricted and monitored by our cloud service providers, which are independently audited against standards such as SOC 2 and ISO 27001.

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10. Breach Notification

In the event of a breach of security safeguards involving personal information that creates a real risk of significant harm, we will:

  • Notify affected individuals as soon as feasible, providing information about the breach, the personal information involved, steps we have taken or intend to take, and recommended steps the individual can take to mitigate potential harm.
  • Report the breach to the Office of the Privacy Commissioner of Canada as required under PIPEDA.
  • Report the breach to the appropriate privacy regulator where required by law.
  • Notify affected individuals and authorities outside Canada where their laws require it.
  • Maintain a record of all breaches of security safeguards, regardless of whether they meet the threshold for notification.

ProveraCare is not responsible for a breach that occurs in the systems of a Market Partner or other third party after you have chosen to share your information with them, although we will cooperate with reasonable requests to help address it.

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11. Openness and Transparency

In accordance with PIPEDA’s openness principle, we make information about our privacy policies and practices readily available. This Privacy Policy is available at hellopearl.app/privacy-policy and can be provided in an accessible format upon request. We will notify users of material changes to this Privacy Policy by email and through a prominent notice on the Platform at least thirty (30) days before such changes take effect.

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12. Cookies and Similar Technologies

We use cookies and similar tracking technologies to operate, customize, and improve the Platform. Categories of cookies we use include:

  • Strictly Necessary Cookies: Required for the Platform to function properly, including authentication, security, and session management. These cannot be disabled.
  • Functional Cookies: Used to remember your preferences and settings, such as language selection and display preferences.
  • Analytics Cookies: Used to understand how users interact with the Platform, which pages are visited most frequently, and to measure the effectiveness of our communications. We use privacy-focused analytics tools.

Some links from The Market to Market Partner websites may include a referral tag that tells the Market Partner the visit came from Pearl. A referral tag does not include your name or contact details.

We do not use advertising or tracking cookies. You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform.

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13. Your Rights

Under PIPEDA and applicable privacy legislation, you have the following rights with respect to your personal information:

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13.1 Right of Access

You have the right to request access to the personal information we hold about you. We will respond to your request within thirty (30) days or as required by applicable law. In limited circumstances, we may be unable to provide access (for example, if the information contains references to other individuals or cannot be disclosed for legal or security reasons).

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13.2 Right of Correction

You have the right to request the correction of any inaccurate or incomplete personal information we hold about you. If we disagree with the requested correction, we will note your request in our records.

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13.3 Right to Withdraw Consent

You may withdraw your consent to the collection, use, or disclosure of your personal information at any time, as described in Section 5.3 above.

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13.4 Right to Deletion

You may request the deletion of your personal information, subject to our legal obligations to retain certain information (such as financial records for tax purposes). We will process deletion requests in accordance with applicable law and our data retention schedule. Deleting your Pearl account does not delete information you previously chose to share with a Market Partner. To ask a Market Partner to delete it, please contact that Market Partner directly.

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13.5 Right to Complain

If you are not satisfied with our response to your privacy inquiry or complaint, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca or the Information and Privacy Commissioner of Ontario at ipc.on.ca.

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13.6 Exercising Your Rights

To exercise any of these rights, please contact our Privacy Officer at privacy@hellopearl.app. We may require you to verify your identity before processing your request. We will respond to all requests within thirty (30) days. If we require additional time, we will notify you of the extension and the reasons for it.

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14. International and Cross-Border Transfers

Platform data is stored and processed in the United States by our cloud service providers. When personal information is transferred outside Canada, we remain accountable for it under PIPEDA, and each service provider is bound by contract to protect it to a level comparable to Canadian privacy law. Personal information may be stored or processed outside Canada:

  • By our cloud service providers and the other service providers listed in Appendix A, which process it on our behalf.
  • Where you choose to share information with a Market Partner or connect a third-party service, which may store or process that information outside Canada under its own privacy policy.
  • Where required by law or court order.

Information processed in another country may be accessible to that country’s courts, law enforcement, and national security authorities under its laws. Appendix A lists our service providers outside Canada, what they process, and where.

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15. Additional Provisions for U.S. Users

If ProveraCare provides services to U.S.-based healthcare organizations and handles health information on their behalf, we agree in writing how that information is protected, including:

  • Implementing administrative, physical, and technical safeguards to protect health information.
  • Signing a written agreement with each organization before we handle its health information.
  • Reporting breaches of unsecured health information as required by law.
  • Limiting the use and disclosure of health information to the minimum necessary to accomplish the intended purpose.
  • Ensuring that subcontractors who access health information agree to the same restrictions and conditions that apply to ProveraCare.

U.S. users may also have additional rights under state privacy laws. If you believe you have rights under specific state privacy legislation, please contact our Privacy Officer.

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16. Additional Provisions for Health Information

Pearl may collect, use, or disclose personal health information. Where the Platform processes personal health information:

  • We obtain express consent before collecting, using, or disclosing personal health information, except where implied consent is permitted by law.
  • We limit the collection, use, and disclosure of personal health information to the minimum amount necessary to fulfill the identified purpose.
  • We maintain audit logs that record access to personal health information, including the date, time, identity of the person accessing the information, and the nature of the access.
  • We notify the Information and Privacy Commissioner of Ontario of any theft, loss, or unauthorized access to or disclosure of personal health information.
  • We obtain consent before using an individual’s personal health information.
  • We do not disclose personal health information to Market Partners unless you expressly direct us to.

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17. Pearl AI, Ask Pearl and Automated Decision-Making
17.1 Pearl AI in The Market

Pearl AI suggests the kinds of help, services, and Listings in The Market that fit what you type. You decide what to do with any suggestion.

  • What Pearl AI sees: only the words you type into Pearl AI, such as a Market search, and your language setting. It does not see your Circle’s chats, notes, documents, calendar, or check-ins, and it is not sent your name or account details.
  • Before your words are sent, we remove email addresses, phone numbers, links, and long numbers, such as health card or account numbers.
  • If what you type sounds like an emergency, Hello Pearl shows you how to get emergency help, and nothing is sent to Pearl AI.
  • Who processes it: Pearl AI uses Gemini, a Google Cloud service (Vertex AI). Google processes the text to produce the suggestion, may keep it for a short time to run and secure its service, and is bound by contract to protect it. This processing may happen in the United States or other countries where Google operates.
  • Google does not use this text to train its AI models. We do not sell personal information, for AI training or for any other purpose.
  • Pearl AI does not make decisions that have legal or similarly significant effects on anyone.
  • A Pearl AI suggestion is not an endorsement of any Market Partner.
  • If Pearl AI is unavailable, the regular Market search still works.
  • We regularly review Pearl AI for accuracy, fairness, and compliance with privacy law.
17.2 Ask Pearl

Ask Pearl is the assistant inside Hello Pearl. It answers questions about your Circle and prepares actions, such as a reminder, a request or a message, that happen only when you tap to confirm them. We ask for your consent before you first use Ask Pearl. A plain-language summary is at Ask Pearl and your privacy.

  • What Ask Pearl sends to our AI provider: the words you type or say; your Circle's name and time zone; the names of the people in your Circle, how each is related to the Core Member, and an internal identifier for each; and the step you are on if you are answering one of Pearl's questions. It does not send your Circle's chats, notes, documents, calendar, check-ins, private information, email addresses or phone numbers. What you type or say is sent as you wrote or said it, so please leave out details you don't want shared.
  • Answers about your Circle: when Pearl tells you about your calendar, messages, requests or check-ins, the answer comes from Hello Pearl and follows your permissions in that Circle. That information is not sent to our AI provider.
  • Voice: when you speak to Pearl, your browser's own speech service may convert your voice to text (for example, Google in Chrome or Apple in Safari). If it cannot, we send up to 8 seconds of audio, with the names of people in your Circle as spelling hints, to Google Speech-to-Text, or to Gemini if that fails. We do not keep the recording.
  • Reading replies aloud: if you turn on "Read replies aloud", the text of Pearl's replies is sent to Google Text-to-Speech. Anything marked private is not read aloud unless you ask.
  • Who processes it: Ask Pearl uses Gemini and Google's speech services. Google processes this information to provide the service, may keep it for a short time to detect misuse, does not use it to train its AI models, and is bound by contract to protect it. This processing may happen in the United States or other countries where Google operates.
  • What we keep: we do not store your conversation with Pearl. For each request we keep its type, its risk level and whether it was completed, without your words, to run the service and keep it safe. Anything you confirm is saved in your Circle like any other content.
  • Your confirmation: Pearl does not add, send or change anything until you tap to confirm it. A prepared action expires after 15 minutes.
  • Emergencies: if what you type or say sounds like an emergency, Hello Pearl shows you how to get emergency help, and nothing is sent to our AI provider.
  • Ask Pearl does not give medical, legal or financial advice and does not make decisions that have legal or similarly significant effects on anyone.
  • Ask Pearl is optional. You can withdraw your consent at any time by no longer using it or by contacting our Privacy Officer at privacy@hellopearl.app.

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18. Children’s Privacy

The Platform is not directed at children under the age of eighteen (18). We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly. If you believe a child has provided us with personal information, please contact us at privacy@hellopearl.app.

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19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. If we make material changes, we will notify you by email and through a prominent notice on the Platform at least thirty (30) days before the changes take effect. The “Last Updated” date at the top of this Policy indicates when the most recent revision was made. Your continued use of the Platform after the effective date of the revised Privacy Policy constitutes your acceptance of the changes.

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20. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or our privacy practices, please contact our Privacy Officer:

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Provera Care Incorporated

(operating as ProveraCare)

Privacy Officer

Email:privacy@hellopearl.app

Report a concern about a Listing or provider:trust@hellopearl.app

Website:hellopearl.app

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If you are not satisfied with our response, you may contact:

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Office of the Privacy Commissioner of Canada

30 Victoria Street, Gatineau, Quebec K1A 1H3

Toll-free: 1-800-282-1376

Website: priv.gc.ca

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Information and Privacy Commissioner of Ontario

2 Bloor Street East, Suite 1400, Toronto, Ontario M4W 1A8

Toll-free: 1-800-387-0073

Website: ipc.on.ca

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Appendix A: Service Providers Outside Canada

Platform data is stored and processed in the United States. The service providers below help us run Hello Pearl and process personal information outside Canada. Each is bound by contract to protect your information. Information processed in another country may be accessible to that country’s courts, law enforcement, and national security authorities under its laws.

  • Cloud hosting and storage (United States): All Platform data, including accounts, Circles, coordination content, any Health-Adjacent Information you choose to share, photos, and documents.
  • Database (United States): The same Platform data, held in our database.
  • Sign-in (United States): Your name, email address, password (stored only as a protected hash), and, if you use Continue with Google, your Google sign-in details.
  • Pearl AI and Ask Pearl (United States and other countries where Google operates): For Pearl AI, the words you type, with contact details removed. For Ask Pearl, the words you type or say, your Circle's name and time zone, and the names and relationships of the people in your Circle; short voice recordings when your browser can't convert them to text; and the text of replies you choose to hear read aloud (see Section 17).
  • Email delivery (United States): Your name, email address, and the content of emails we send you, such as account notices, notifications, and digests.
  • Text messages (United States): Your phone number and the text of notifications we send you by SMS.
  • Payment processing (United States): Billing name, billing address, payment card details, and transaction records for subscription fees and listing fees.
  • In-app help and feedback (European Union): What you send us through the help button, such as messages and screenshots, with basic device details.
  • App analytics (United States): Pages visited and actions such as signing up, without your name, email address, or Circle content.
  • Public website hosting and forms (United States): Information you submit through forms on our public website at hellopearl.app, such as waitlist or contact forms, and basic website visit data.

We will update this appendix if we add or change a service provider that processes personal information outside Canada. Where a change is material, we will give notice as described in Section 19.