Privacy Policy

Baba Care, Inc. (“we,” “us,” or “our”) is a healthcare advocacy platform that connects clients with dedicated advocates, including nurses and social workers, to help navigate the healthcare system. Our advocates support clients and their families with services such as insurance appeals, specialist referrals, appointment scheduling, medication management, and care coordination (collectively, the “Advocacy Services”).

In addition to the Advocacy Services, we offer an artificial intelligence-powered voice companion (“Baba Companion”), designed to enhance quality of life for clients through engaging and personalized conversations. Baba Companion is powered by artificial intelligence and may facilitate check-in calls, provide companionship, and help surface information relevant to your care. Information shared with Baba Companion will only be made available to Advocacy Services with the client’s approval. 

This Privacy Policy describes how we process personal information that we collect through our Advocacy Services, through Baba Companion, through our website at callbaba.com, our mobile applications, and our other digital or online properties or services that link to this Privacy Policy, as well as our marketing activities and other activities described in this Privacy Policy (collectively, the “Service”). We may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. Certain services, such as telehealth, may be governed by a separate consent form in addition to this Privacy Policy.

We partner with organizations including but not limited to healthcare providers, long-term care facilities, health systems, assisted living communities, home health agencies, and home care agencies (each, a “Care Entity”) to connect clients with our Advocacy Services and Baba Companion. If you were referred to Baba Care through a Care Entity, we may share information we collect from or learn about you with that Care Entity to support your care, including information regarding your advocacy needs and care coordination activities. Although we may share your information with your Care Entity, Baba Companion may not always share the information you want shared with your Care Entity. If there is information you want to share with your Care Entity, please share it with them directly. If you have questions or concerns regarding information processed by your Care Entity, please direct those concerns to your Care Entity.

Index

• Personal information we collect

• How we use your personal information

• Retention

• How we share your personal information

• Your choices

• Other sites and services

• Security

• International data transfers

• Children

• California residents

• Changes to this Privacy Policy

• How to contact us

  
  

Personal Information We Collect

Information You Provide to Us

Personal information you or your authorized representative provides to us when you sign up for the Service includes:

• Contact data, such as your first and last name, salutation, email address, mailing addresses, and phone number.

• Demographic data, such as your city, state, country of residence, postal code, gender, date of birth, and age.

• Credentials, such as passwords, password hints, and similar security information used for authentication and account access.

• Account information, such as your communication preferences, pre-scheduled times you set to receive calls from Baba Companion, preferred topics of conversation, preferred authentication and account recovery methods, and any other information you provide during the onboarding process.

• Communications data, including our exchanges with you when you contact us through the Service, by phone, email, social media, or otherwise.

• Advocacy and care coordination data, such as information about your healthcare needs, insurance coverage, provider relationships, appointment history, advocacy case notes, insurance appeal records, referral information, equipment or medication needs, and any other information you share in connection with the Advocacy Services.

• Baba Companion data, based on your conversations with Baba Companion and Baba Companion’s memories of your conversations, such as your hobbies and interests, favorite media outlets or sports teams, questions, interests in current events, reminiscences and memories, information concerning your or others’ interpersonal relationships, habits, preferences, and any other information you choose to share while interacting with Baba or that we infer about you.

• Care Entity information, such as the name of the Care Entity where you receive care, information about your living conditions, interactions with staff, feedback on food quality, and any other information or feedback you share about your Care Entity.

• Health-related information, such as your past or present physical or mental health conditions, treatments, diseases, or diagnoses, use or purchase of prescribed medications, or other health-related information you share with us, our advocates, or while interacting with Baba.

• Audio or voice recordings, such as recordings and transcripts of your conversations with our advocates or with Baba.

• Payment data, such as data necessary to process your payment if applicable. All payment data is stored by our payment processor, and you should review its privacy policies and contact the payment processor directly with questions.

• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

  
  

Third-Party Sources

We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Care Entities. We may collect information from Care Entities where you reside or receive services, such as information about your care needs, living conditions, activities, feedback, and interactions with facility staff.

• Authorized representatives, family members, and friends. We may collect information about you from individuals who are authorized to act on your behalf or who assist you in using the Service, such as family members, legal guardians, or friends. This information may include contact information, care preferences, health-related details, and other insights intended to support your experience with the Service.

• Service providers and business partners. We may receive information from vendors and partners that support our operations, such as transcription providers, analytics services, customer support tools, academic institutions, marketing platforms, and cloud hosting providers.

• Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction, such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.

  
  

Automatic Data Collection

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications, and other online services, such as:

• Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information, and general location information such as city, state, or geographic area.

• Usage data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

• Inferences and derived data. We may generate new personal information about you based on your interactions with the Service and with Baba, such as inferred interests, conversational preferences, care needs, engagement patterns, emotional tone, and other insights derived from your use of the Service.

  
  

Cookies and Similar Technologies

Some of the automatic collection described above is facilitated by the following technologies:

• Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place, and “third party” cookies that our third-party business partners and service providers place.

• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.

• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

  
  

How We Use Your Personal Information

We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent. We may use your personal information for the following purposes or as otherwise described at the time of collection:

Communications and Calls

You agree to receiving autodialed, artificial intelligence-driven artificial voice calls from Baba to the phone number you provided to your Care Entity or included on the sign-up form when you or your representative signed you up for the Service. We may also contact you by phone, email, or other means in connection with the Advocacy Services.

Service Delivery and Operations

We may use your personal information to:

• provide, operate, and improve the Service, including the Advocacy Services and Baba Companion, and our business;

• connect you with patient advocates and coordinate advocacy activities on your behalf;

• enable security features of the Service;

• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;

• facilitate communications between you, your advocates, your Care Entity, and your healthcare providers; and

• provide support for the Service and respond to your requests, questions, and feedback.

  
  

Service Personalization

We may use your personal information to:

• understand your healthcare needs, advocacy priorities, and interests while interacting with Baba Companion;

• personalize your experience with the Service, including to tailor advocacy support, generate personalized questions, responses, comments, and statements during your conversations with Baba, and customize our Service-related communications; and

• remember your selections and preferences as you navigate and use the Service.

  
  

Service Improvement and Analytics

We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which features of the Service and Baba Companion are most and least used and enjoyed, as well as user interactions with our emails, and to develop new products and services. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our website here: https://tools.google.com/dlpage/gaoptout?hl=en.

Marketing and Promotional Communications

We may use your personal information to send you marketing and promotional communications about our products and services. You may opt out of our marketing emails at any time by following the unsubscribe instructions in those emails.

Compliance and Protection

We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations, or requests from government authorities;

• protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims);

• audit our internal processes for compliance with legal and contractual requirements or our internal policies;

• enforce the terms and conditions that govern the Service; and

• prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

  
  

Data sharing in the context of corporate changes of control. We may share certain personal information in the context of actual or prospective corporate changes of control — for more information, see How We Share Your Personal Information below.

Retention

Your interactions with the Service, including your conversations with Baba Companion and communications related to the Advocacy Services, may be recorded, transcribed, and retained. You agree to this when you sign up for the Service.

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of providing the Service, satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we have no ongoing legitimate business need to process your personal information, we will either delete it, anonymize it, or isolate it from further processing.

Dormant and Closed Accounts

If your account becomes dormant or is closed, we will retain your personal information in accordance with the retention practices described above. When we determine that your personal information is no longer needed for the purposes for which it was collected, we will delete it, anonymize it, or isolate it from further processing. Please note that even after your account is closed, we may retain de-identified or aggregated data that does not identify you, and we may retain personal information as necessary to comply with our legal obligations, measure efficacy of our services, resolve disputes, and enforce our agreements.

How We Share Your Personal Information

We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations. We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection:

• Your Care Entity. We may share information with the Care Entity that referred you to help coordinate your care and advocacy needs, including information based on your conversations with Baba Companion if authorized by client.

• Your advocates. We share relevant information with the advocates assigned to support you so they can effectively provide the Advocacy Services.

• Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, AI models for Baba Companion, email delivery, marketing, consumer research, and website analytics).

• Third parties designated by you. We may share your personal information with third parties, such as your family members, loved ones, or healthcare providers, where you have instructed us or provided your consent to do so.

• Third-party advertisers. We may use third-party advertising companies to serve ads when you visit our website. These companies may use information about your visits to our website and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.

• Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

• Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in or financing of Baba Care, Inc., public stock offerings, or the sale, transfer, or merger of all or part of our business, assets, or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Baba Care, Inc. as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

  
  

Impact of Data Sharing on Others

When you share information with us — including information about your family members, loved ones, interpersonal relationships, or health-related information — that information may have implications for other individuals. For example, health-related information you share may be relevant to family members or relatives. We encourage you to consider the potential impact on others before sharing such information, and to obtain the consent of any third parties whose personal information you provide to us where appropriate. We are not responsible for any information you choose to share about third parties through the Service.

Your Choices

Cookies

Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. You can also configure your device to prevent images from loading to prevent web beacons from functioning.

Blocking Images/Clear GIFs

Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to Provide Information

We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Withdrawal of Consent

Where we process your personal information based on your consent, you may withdraw your consent at any time by contacting us at help@callbaba.co. Please note that withdrawing your consent does not affect the lawfulness of any processing we conducted prior to your withdrawal, nor does it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. If you withdraw your consent, we may not be able to provide you with certain features or functionality of the Service, including the Advocacy Services and Baba Companion. Upon withdrawal of consent, we will cease processing your personal information for the purposes to which you originally consented, unless we have another legal basis for continuing to do so.

Other Sites and Services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications, or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications, and online services you use.

Security

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information. You should only access the Service within a secure environment.

International Data Transfers

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children

The Service is not intended for use by anyone under 18 years of age. We do not knowingly solicit data from or market to children under 18. By using the Service, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Service. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under 18, please contact us at help@callbaba.com.

California Residents

This section applies solely to California residents under the California Consumer Privacy Act (“CCPA”) and supplements the information in this Privacy Policy.

California law requires us to disclose information regarding the categories of personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes for which the information was collected, and the categories of parties with whom we share personal information.

We or our service providers may collect the categories of information described above in this Privacy Policy for the following business or commercial purposes:

• Providing the Service (e.g., account servicing and maintenance, patient advocacy, care coordination, customer service, advertising and marketing, analytics, and communication about the Service);

• Our or our service providers’ operational purposes;

• Auditing consumer interactions on our site (e.g., measuring ad impressions);

• Detecting, protecting against, and prosecuting privacy and security incidents and fraudulent or illegal activity;

• Bug detection, error reporting, and activities to maintain the quality or safety of our Service;

• Investigating compliance with, enforcing, and/or complying with the law;

• Short-term, transient use, such as customizing content that we or our service providers display on the Service;

• Improving our existing Service and developing new services (e.g., by conducting research to develop new products or features); and

• Other uses that advance our commercial or economic interests, or other uses about which we notify you.

  
  

If you are a California resident, you may have certain rights. California law may permit you to request that we:

• Provide you the categories of personal information we have collected or disclosed about you in the last twelve months, the categories of sources of such information, and the business or commercial purpose for collecting your personal information.

• Provide access to and/or a copy of certain personal information we hold about you.

• Delete certain personal information we have about you.

  
  

You may have the right to receive information about the financial incentives that we offer to you, if any. You also have the right not to be discriminated against for exercising certain of your rights.

If you would like to exercise any of these rights, please email us at help@callbaba.com. You will be required to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Service to you. If you ask us to delete it, you may no longer be able to access or use the Service.

We do not sell personal information as defined under the CCPA and have not done so in the preceding twelve months.

Changes to This Privacy Policy

We may update this Privacy Policy at any time, and any changes will be effective upon posting. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or through other appropriate means. We may also notify you by email, in our discretion. However, we will use your personal information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless you consent to the new or revised policy. In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to Contact Us

If you have questions or comments about this Privacy Policy, you may email us at help@callbaba.com.