As of September 2025, the objectives are to:
1.1 – To provide the Reader with a plain language summary of the Privacy Policy, which can be found found at the end of this section.
1.2 – To have this Privacy Policy outline LLA Technologies Inc.’s (“LLA”, “We”, “Us”, “Our”) practices regarding the collection, use, disclosure, and protection of your personal information when you use Our Services, including our mobile application, website, cardiac sensor, and related features (“Service”).
1.3 – To inform you of your privacy rights and how the law protects those rights in accordance with applicable privacy legislation, including:
1.3.1 – Personal Information Protection and Electronic Documents Act (PIPEDA)
1.3.2 – Personal Health Information Protection Act (PHIPA)
1.3.3 – Applicable U.S. state laws such as the California Consumer Privacy Act (CCPA)
1.4 – To have have the reader understand after reviewing this Privacy Policy that We process your personal data on the following legal bases:
To perform our contractual obligations (e.g., provide and maintain the Service)
With your explicit consent (e.g., for location access, personal health information)
To comply with legal obligations (e.g., safety, regulatory compliance)
To protect your vital interests or those of others
To pursue legitimate business interests in ways that do not override your fundamental rights and freedoms
1.5 – By using the Service, you agree to the collection, use, and disclosure of your information in accordance with this Privacy Policy.
Before engaging or committing with LLA Technologies, the reader should have discovered that the Privacy Policy is posted on the app stores or our website. This allows for review before a product is purchased, and before your information is collected. Below is an outline of how LLA Technologies uses your data.
Personal Info: Like your name, email, and date of birth—only when you give it to us.
Device & Usage Info: Like your IP address, browser type, and how you use the app.
Location (BLE only): We ask for permission to access location data, but only for connecting your device—not for GPS tracking.
Health Info: If you use our sensor, it may collect information related to your heart activity.
We use your data to:
Provide and improve the Service
Communicate with you
Ensure your device works properly
Fulfill our legal and safety responsibilities
We may share your data with:
Trusted service providers (like cloud hosting)
Healthcare regulators (if required)
Business partners (with your consent)
We never sell your personal information.
Your data may be stored in secure servers globally, using industry-standard security. We do our best to store it close to where you live, when possible.
We only keep your information as long as needed to:
Provide the Service
Meet legal requirements
Prevent fraud
You can ask us to delete your information by contacting us.
We do not use AI in live features of the app or sensor.
We may use de-identified data for research or product improvements.
You are not subject to automated decisions.
We don’t knowingly collect data from anyone under 13. If you’re a parent and your child used Our Service, please contact us.
Email us anytime at [email protected]
For the full policy, scroll down or review it in the app store before using our products.
This Privacy Policy applies to all users of LLA Technologies Inc.’s (“LLA”) services, including the mobile application (LLA Recordis), the associated cardiac sensor, and the website. It governs the collection, use, and disclosure of personal data, including personal health information, across all platforms where the Service is made available.
2.1 – The Policy is designed to comply with:
2.1.1 – Personal Information Protection and Electronic Documents Act (PIPEDA), which includes the following Principles:
2.1.1.1 – Accountability
2.1.1.2 – Identifying Purpose
2.1.1.3 – Consent
2.1.1.4 – Limiting Collection
2.1.1.5 – Limiting Use, Disclosure, and Retention
2.1.1.6 – Accuracy
2.1.1.7 – Safeguards
2.1.1.8 – Openness
2.1.1.9 – Individual Access
2.1.1.10 – Challenging Compliance
2.1.2 – Personal Health Information Protection Act (PHIPA) (Ontario)
2.1.3 – Applicable U.S. state privacy laws, such as the California Consumer Privacy Act (CCPA) and related regulations
2.2 – This Policy is made publicly available to ensure that users are informed prior to engaging with the Service. It is intended to be posted on all app distribution platforms, such as the Google Play Store and Apple App Store, where LLA’s mobile application is offered for download.
2.3 – The Policy covers the following:
2.3.1 – Personal data and health information collected directly from users
2.3.2 – Automatically collected usage and device data
2.3.3 – Information shared with third parties, including service providers and business partners
2.3.4 – Cross-border data transfers and applicable safeguards
2.3.5 – User rights, including how they can access, correct, or delete their information
2.3.6 – Methods of obtaining and revoking consent
2.3.7 – Data security measures and retention practices
2.3.8 – Age restrictions and parental consent requirements
2.3.9 – Disclosure of any AI-based processing where applicable
3.1 – LLA Technologies Inc. is responsible for the personal information under its control and is committed to ensuring compliance with applicable privacy legislation.
3.2 – We have appointed a Privacy Officer to oversee data protection strategies and ensure compliance with this Privacy Policy and related privacy obligations.
3.3 – The Privacy Officer is responsible for:
3.3.1 – Monitoring compliance with this Policy and applicable laws (e.g., PHIPA, PIPEDA, CCPA)
3.3.2 – Responding to privacy inquiries and data subject access requests
3.3.3 – Investigating privacy incidents and breaches
3.3.4 – Managing relationships with third parties that process personal data on our behalf
3.3.5 – Maintaining records of data processing activities, where applicable
3.3.6 – Ensuring staff are trained on privacy practices and security protocols
3.4 – All employees, contractors, and service providers who handle personal data on behalf of LLA are required to adhere to this Policy and report any suspected privacy concerns or violations to the Privacy Officer.
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
For the purposes of this Privacy Policy:
5.1.1.1 – We collect the following categories of personal information to provide and improve Our Service. Some of this data is collected directly from you, while other information is collected automatically.
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
5.1.1.2.1 – Email address
5.1.1.2.2 – First name and/or last name
5.1.1.2.3 – Date of Birth
5.1.1.2.4 – Sex
5.1.1.2.5 – This information may be collected when:
5.1.1.2.5.1 – You create an account
5.1.1.2.5.2 – You communicate with us
5.1.1.2.5.3 – You use specific features of the Service
5.1.1.3 – The legal basis of collecting this data occurs:
5.1.1.3.1 – With your consent (you do not need to provide this information, but some services may not function as intended or at all).
5.1.1.3.2 – As necessary for the performance of a contract
5.1.1.3.3 – To fulfill our legal or regulatory obligations
5.1.1.4 – Withdrawal or correction of data collection:
5.1.1.4.1 – The above data can be corrected or withdrawn by contacting [email protected] , at which point the request will be triaged.
5.1.1.5.1 – Usage Data is collected automatically when using the Service.
5.1.1.5.2 -Usage Data may include information such as:
5.1.1.5.2.1 -Your Device’s Internet Protocol address (e.g. IP address),
5.1.1.5.2.2 – Browser type, browser version,
5.1.1.5.2.3 – The pages of Our Service that You visit,
5.1.1.5.2.4 – The time and date of Your visit,
5.1.1.5.2.5 – The time spent on those pages,
5.1.1.5.2.6 – Unique device identifiers,
5.1.1.5.2.7 – Other Service data that is directly related to Your use of the Device, such as Crash Reports, and other diagnostic information
5.1.1.5.2.8 – Mobile device information such as:
5.1.1.5.2.8.1 – The type of mobile device You use
5.1.1.5.2.8.2 – Your mobile device unique ID,
5.1.1.5.2.8.3 – Your mobile operating system,
5.1.1.5.2.8.4 – Service-related data that is directly associated to Your use, including data from the cardiac sensor.
5.1.1.5.2.8.5 – Any of the above listed usage data items that are available as part of cross-platform access (e.g., browser information from a phone versus desktop)
5.1.1.5.3 -The legal basis of collecting this data collection occurs:
5.1.1.5.3.1 -For legitimate business purposes such as security and analytics
5.1.1.5.3.2 -For improving service functionality and user experience
5.1.1.6.1 – While using Our Application, and in order to provide features of Our Application, We may collect, with Your prior permission:
5.1.1.6.1.1 – Information regarding your location for Bluetooth Low Energy (BLE) services. This data is used solely for technical purposes and does not include GPS or real-time location tracking unless explicitly stated.
5.1.1.6.1.1.1 – This data is collected only with your prior, explicit consent when first downloading the Application. You will be prompted to allow or deny this permission when the application requests it.
5.1.1.6.2 – We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company’s servers and/or a Service Provider’s server or it may be simply stored on Your device.
5.1.1.6.3 – You can enable or disable access to this information at any time, through Your Device settings. If these settings are disabled, We cannot guarantee that Our Service will function properly for You.
5.1.1.6.4 – The legal basis for this data collection occurs:
5.1.1.6.4.1 – For legitimate business purposes such as security and analytics for Bluetooth Services, and other diagnostic information between the Application and the cardiac sensor
5.1.1.7.1 – Personal Health Information is the result of using Our Service. With respect to an individual, company or other legal entity (see definition of “You”), who has used Our Service, personal health information can be identifiable information about your physical and/or mental health that includes:
5.1.1.7.1.1 – Information concerning physical health, including cardiac activity
5.1.1.7.1.2 – Information concerning a health service provided to an individual, because the individual’s health service provider is using Our technology
5.1.1.7.1.3 – Information that may be collected in the course of providing health services
5.1.1.7.1.4 – Information that may be collected incidentally to the provision of health care services, because Our technology enables supporting health-related functions.
5.1.1.7.2 – The Company does not have direct knowledge outside of Our Service provisions, of other health services being provided to You or by You. We only know that Our Service is being used under the guidance of a qualified health professional. The Company does not have direct knowledge outside of Our Service, of any information generated directly as a result of-, or incidentally to-, the health services provided to You, or by You.
5.1.1.7.3 – The legal basis for this data collection occurs:
5.1.1.7.3.1 – As the result of using Our Service, which may include personal data and usage data.
5.1.1.7.4 – Withdrawal or correction of data collection:
5.1.1.7.4.1 – The above data can be corrected or witrhdrawn by contacting [email protected] , at which point the request will be triaged.
5.2.1 – The Company will de-identify Your data prior to use whenever possible and/or practical. The Company may use Personal Data for the following purposes:
5.2.1.1 – To provide and maintain Our Service, including to monitor the usage of Our Service.
5.2.1.2 – To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
5.2.1.3 – For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
5.2.1.4 – To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
5.2.1.5 – To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
5.2.1.6 – To manage Your requests: To attend and manage Your requests to Us.
5.2.1.7 – For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about Our Service users is among the assets transferred.
5.2.1.8 – For disclosure to Regulatory Agenicies: LLA may transfer Personal Data to third parties (e.g., Health Canada, the FDA). This includes without limitation, law enforcement agencies and consumer reporting agencies, in the normal course of business, subject to service of lawful process or your written consent. If you breach the Terms of Service, or if Linode is under a duty to disclose your Personal Data in order to comply with any legal obligation, LLA may disclose your information to the relevant authority.
5.2.1.9 – For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve Our Service, products, services, marketing and your experience.
5.2.1.1 – We may share Your personal information in the following situations:
5.2.1.1.1 – With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of Our Service, to contact You.
5.2.1.2 – For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
5.2.1.3 – With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
5.2.1.4 – With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
5.2.1.5 – With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
5.2.1.6 – With Your consent: We may disclose Your personal information for any other purpose with Your consent.
5.3.1 – The security of Your Personal Data is important to LLA, which is this Policy outlines Our commitments. But remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
5.3.2 – The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
5.3.3 – The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
5.3.4 – Your personal information may be deleted from LLA’s databases, with the exception of:
5.3.4.1 – Network access logs, which may be stored for any duration of time at LLA’s discretion,
5.3.4.1 – Cases where financially fraudulent or otherwise illegal activity is deemed to have occurred (as determined by Linode management or law enforcement officials), in which case personal information may be retained indefinitely for purposes of ongoing investigation and prevention of fraud recurrence,
5.3.4.1 – Cases where a violation of the Terms of Service has resulted in cancellation of your account (as defined by revocation of your permission to utilize LLA’s services), in which case personal information may be retained indefinitely for purposes of prevention of further use of services in the future by the offending individual.
5.3.5.1 – LLA uses Akamai Technologies for server “infrastructure as a service”and for “software as a service”. Akamai Technologies has servers all around the world, which means that LLA will make commercially reasonable efforts to store your data in your country within the bounds of: existing laws and regulations, your location when accessing and using LLA’s Services, type of data collected, and level of encryption.
5.3.5.2 – LLA periodically reviews Akamai Technologies’ cybersecurity records to ensure their global compliance for physical and digital safeguards.
5.3.6.1 – Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located, including those locations claimed by Akamai Technologies. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
5.3.6.2 – Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. LLA will make commercially reasonable efforts to store your data in your country without requiring transfer.
5.3.6.3 – The Company will take all steps reasonably necessary to ensure that Your data is encrypted and treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place. Security control assessments are conducted periodically.
5.4.1.1 – If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
5.4.2.1 – Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
5.4.3.1 – The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
5.4.3.2.1 – Under California Civil Code Section 1798 (California Shine the Light Law), California Residents with an established business relationship can request information once a year about sharing their Personal Data with Third Parties for the Third Parties’ direct marketing Purposes.
If You would like to request more information under the California Shine the Light Law, and if You are a California Resident, You can contact Us using the contact information provided below.
5.4.3.3.1 – California Business and Professions Code section 22581 allow California Residents under age of 18 who are registered users of online sites, services, or applications to request and obtain removal of content or information they have publicly posted.
5.4.3.3.2 – To request removal of such data, and if you are a California Resident, You can contact Us using the contact information provided below, and include the email address associated with Your Account.
5.4.3.3.3 – Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
5.5.1 – Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
5.5.2 – If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.
5.6.1 – Upon discovery of a data breach, LLA Technologies will:
5.6.1.1 – Promptly assess the scope and nature of the incident
5.6.1.2 – Contain and mitigate the breach where possible
5.6.1.3 – Notify affected individuals as soon as feasible if the breach poses a real risk of significant harm
5.6.1.4 – Report the breach to applicable privacy regulators, such as the Office of the Privacy Commissioner of Canada (PIPEDA), or provincial/federal bodies as required by law
5.6.1.5 – Maintain records of all privacy breaches and the remedial actions taken
5.6.2 – If you believe your data may have been compromised, you are encouraged to contact us immediately using the contact information provided in this Policy.
5.6.3 – LLA reviews all security incidents post-resolution and updates our internal processes as needed to reduce the likelihood of future occurrences.
5.7.1 – Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
5.8.1 – LLA Technologies does not use Artificial Intelligence (AI) in the delivery of core Service features of the cardiac sensor with relation to signal acquisition or analysis. Cardiac signal analysis is performed with proprietary algorithms that compare seismocardiography to echocardiography. The data transmission and data handling is also programmed without inclusion of AI.
5.8.2 – AI or machine learning technologies may be used offline, in a research or development context for cardiac signal analysis, strictly on anonymized or de-identified data that cannot reasonably be used to identify any individual.
5.8.3 – LLA Technologies may use trained AI for customer inquiries that may require non-personal health information types of data for optimal engagement. You will not be subject to decisions based solely on untrained automated processing, including profiling, that produces legal or similarly significant effects.
5.9.1 – We may update Our Privacy Policy from time to time. You should check back frequently for any changes to this document, wherever it is posted. A change can be verified by You, by checking that date of publication.
5.9.2 – We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.
5.9.3 – You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
5.10.1 – If you have any questions about this Privacy Policy, You can contact us:
5.10.1.1 – By e-mail: [email protected]