Privacy Policy

    Last update: August 9, 2026

    1. Introduction

    This privacy policy describes Amical's practices regarding the collection, use, retention, and sharing of your personal information when you use our AI phone service designed to provide social and cognitive support to seniors.

    Amical is operated by 9526-1061 Québec inc., a company registered in Québec, Canada. Our head office is located at 200-125 Boulevard Charest E Québec QC G1K 3G5 Canada. You can contact us for any questions related to this privacy policy by email at info@amical-ai.com.

    1.1 Roles and responsibilities

    Data controller (Law 25): For the purposes of Quebec's Act respecting the protection of personal information in the private sector (Law 25) and other applicable privacy laws, the organization accountable for Amical's processing of personal information in connection with the Service is 9526-1061 Québec inc., 200-125 Charest E, G1K 3G5, Québec, QC, Canada.

    That designation identifies who is accountable for how personal information is hosted, secured, and processed through the Service. It does not mean Amical is responsible for clinical decisions, duty of care, or actively monitoring conversations. Amical does not listen to calls in real time and has no obligation to review call content or to take action based on what is said during a conversation. Where the product surfaces signals, reports, or optional alerts to authorized users, the establishment or the family remains responsible for reviewing and acting on them.

    Depending on the deployment scenario, other parties also determine purposes related to care and consent. Roles by scenario:

    • B2B residence (general): The establishment determines the care-related purposes of processing and manages consent for residents. Amical acts as a service provider (processor / sous-traitant) for those care purposes, while remaining the organization accountable under Law 25 for how the Service hosts, secures, and processes personal information, and an independent controller for its own operational purposes (for example, security, infrastructure, billing metrics, and product operations).
    • Common areas: Consent is obtained at the establishment level (often integrated into admission). The establishment informs users of the Service and remains responsible for supervising use of the shared device. Amical's roles are as described for B2B residences generally.
    • Private rooms (B2B): The establishment (or an authorized representative acting through the establishment) manages consent for the personalized device. The establishment remains responsible for care oversight. Amical processes resident profile and call data to deliver the Service under the roles described above.
    • B2C (families): The family member or subscriber who sets up the Service is responsible for the care relationship and for confirming appropriate consent. Amical is accountable under Law 25 for operating the Service and processing personal information as described in this policy. Amical is not a substitute caregiver; the family remains responsible for monitoring the portal and taking any action they deem necessary.
    • Research: Research uses require a specific written research agreement and the explicit additional written consent of the residence and of the residents (or their representatives). General product data is not used for research by default. Roles for research data are defined in that agreement; Amical processes research data only as provided in the agreement.

    2. Data Collection

    At Amical, we collect and use data to improve user experience, ensure the quality of our services, and ensure the safety of users.

    2.1 Types of data collected

    • Personal data:
      • First and last name.
      • Date of birth.
      • Contact details (address, email, phone number).
      • Data provided by the residence (for example, via the "Life Book").
      • Data submitted via our online form.
      • Any other information voluntarily shared by family members or caregivers, including medical information deemed necessary.
    • Health data:
      • Type and level of cognitive impairment (e.g., Alzheimer's, vascular aphasia, dementia level, Lewy body).
    • Biometric data:
      • The user's voice, captured in audio recordings and processed during conversations with the AI companion, constitutes behavioral biometric information collected in the course of providing the Service.
    • Financial data:
      • Billing and payment information processed when necessary to manage subscriptions or payments, such as the payer's identity, billing address, subscription and transaction history, and payment card information processed by our payment provider (Stripe).
    • Usage data:
      • Complete recordings and transcripts of conversations between the resident and the AI companion (when recording is enabled).
      • Phone usage statistics (call frequency, duration of interactions).
    • Technical data:
      • IP address and connection data.
      • Performance information for diagnosing and troubleshooting technical issues.
      • Location data.
      • Network and connectivity information required to deliver our services, such as Wi-Fi network names and passwords.

    Due to the conversational nature of the Service, conversations with the AI companion may incidentally contain other categories of personal information that the user chooses to share spontaneously, such as information about family life, opinions, beliefs, or health and social services information. This information is protected by the same measures as the other data described in this policy and is used only for the purposes described herein.

    2.2 Methods of collection

    Amical collects data in the following ways:

    1. User-initiated conversations: Data is collected when using the AI phone, such as conversations or incoming calls. The device does not passively listen; audio data is only captured when the handset is lifted or when the speaker function is enabled.
    2. Scheduled calls: Conversations can be programmed to be initiated by the AI to interact with the user by ringing the phone. During those conversations, the AI can ask for specific, user-defined questions. For example, the companion can ask if the resident is hungry, or remind the resident to go to an appointment.
    3. Initial onboarding: Information is collected at the time of setting up the service, including data provided by the residence or via our online form.
    4. Direct communications: Data can be collected through direct communications with Amical or by installation technicians in person.

    2.3 Consent

    We collect data only after the appropriate consent has been obtained. Consent for care-related purposes is managed by the party responsible for the care relationship, as described in section 1.1. For shared phones deployed in common areas, consent is obtained at the establishment level and is integrated into the consent provided at admission, and the establishment informs users of the presence of the Service. For personalized phones, consent is managed by the establishment or by the family member who sets up the device, who confirms that the user has been informed and, where the user is able to consent, has consented; where the user is unable to consent, an authorized representative acts on behalf of the user in accordance with the service agreement. You may withdraw consent at any time by contacting info@amical-ai.com.

    2.4 Call recording

    By default, all calls between our AI companion and the resident are recorded and transcribed, whether initiated by the user or by the AI, and whether the device is in a common area or a private room. Calls where our AI is not part of the conversation (for example, when a relative calls the Amical device from their own phone to speak with the resident) are not recorded, unless written explicit consent is obtained from the relative and from the residence, and only in the context of specific scientific studies. Clients can choose in their settings to delete recordings sooner or not to make recordings at all; disabling recording or choosing zero retention removes certain product features and limits Amical's ability to provide support.

    3. Use of Data

    The data collected by Amical is used exclusively to provide, improve, and personalize our services. We are committed to limiting the use of data to the purposes described below:

    3.1 Data purposes

    The data collected by Amical is used for the following purposes:

    1. Provision and personalization of the Service: Delivering the core Service: enabling and personalizing conversations with the AI based on preferences and the information provided, so the Service can offer the social and cognitive support it is designed to deliver.
    2. Technical support and maintenance: Analyzing technical performance, diagnosing and resolving issues. Continuous update and improvement of features.
    3. Proactive communication: Scheduled calls by the AI. Where enabled by the establishment or family, the Service may send notifications or optional alerts to authorized relatives or caregivers (for example, signals that authorized users may choose to review). Amical does not actively monitor calls and does not assume responsibility for acting on such notifications.
    4. Insights and optional alerts: Producing reports and optional insight or alert features for authorized caregivers or relatives. These tools are made available to help the establishment or family exercise their own oversight; they do not constitute continuous monitoring by Amical, and Amical has no duty to listen to, review, or intervene in conversations.
    5. Research and analyses: De-identified studies to understand the impact of Amical, improve the AI, and develop new services. Possible sharing with academic research partners (e.g., CRIUGM, CIUSSS). Data used for such purposes requires the explicit additional written consent of the residence and of the residents. General user data is not used for research unless there is a specific research agreement in place with the care facility and the residents or their representatives. Roles for research are described in section 1.1.

    3.2 Sharing data with third parties

    We may share certain data with trusted third parties who help us provide and improve the Amical service. The current list of subprocessors (versioned) is:

    List version: 9 August 2026

    • Google: Cloud infrastructure, Gemini LLM services, Maps and Places for address and location data, and optional Google OAuth for client portal login.
      Information concerned: Conversation transcripts and content processed by the Gemini LLM services (analysis performed in Canada, under a zero-retention agreement), addresses and location data (Maps and Places), account identifiers (email) for the optional Google OAuth sign-in, and Service data hosted on the cloud infrastructure.
    • Meta (Facebook): Used solely for optional OAuth sign-in to the client portal via Supabase Auth. Not used to process call audio, transcripts, or care data.
      Information concerned: Account identifiers (email) related to the optional OAuth sign-in only; no call audio, transcripts, or care data.
    • Amazon Web Services (AWS): Cloud infrastructure and secure storage, including call recordings.
      Information concerned: Service data hosted and stored securely, including call audio recordings.
    • Stripe: Payment and billing infrastructure for applicable users.
      Information concerned: Financial and billing information (payer identity, billing address, payment card information, subscription and transaction history).
    • Twilio: Voice and messaging communications related to the Service.
      Information concerned: Call audio in transit, phone numbers, and call metadata (duration, timestamps).
    • Supabase: Database, authentication, and backend infrastructure.
      Information concerned: Account and profile data, authentication identifiers, and Service data stored in the database, hosted in Canada (ca-central-1 region).
    • ElevenLabs: Conversational voice AI used for live phone conversations. At the end of each call, the transcript is transmitted to Amical; ElevenLabs then retains neither the audio nor the transcript (zero-retention agreement).
      Information concerned: Live call audio, processed in real time in the United States under a zero-retention agreement; neither audio nor transcript is retained after the call.
    • Sentry: Application monitoring and error tracking. Events may include technical context and identifiers needed to investigate incidents.
      Information concerned: Technical context and identifiers needed for incident investigation; no clinical content.
    • Datadog: Centralized observability, logging, and alerting. Operational logs may include user email addresses and other operational identifiers, but not clinical content.
      Information concerned: Operational logs and technical metadata, which may include email addresses and other operational identifiers; no clinical content.
    • HubSpot: CRM, marketing automation, and support workflows, including contact and deal data and support requests.
      Information concerned: Contact details, deal data, and support requests.
    • SendGrid: Transactional email delivery (notifications, invitations, and operational messages).
      Information concerned: Email addresses and the content of transactional emails.
    • Intuit (QuickBooks Online): Accounting integration for customers who connect QuickBooks Online.
      Information concerned: Billing and accounting data of customers who connect QuickBooks Online.
    • Hologram: Cellular IoT connectivity management for clients who rely on cellular connectivity for their devices.
      Information concerned: Device identifiers and cellular connectivity metadata.
    • GDMS (Grandstream): Centralized configuration and management of phones deployed to residences.
      Information concerned: Device identifiers and configuration of the phones deployed in residences.

    The same list is published and kept up to date on our Compliance subprocessors page.

    We take steps to ensure that these third parties adhere to high standards of data security and privacy. We only share the data necessary for the performance of their services and require that they use it only for the specified purposes.

    Where applicable, we enter into data processing agreements with these providers and apply safeguards such as data minimization. ElevenLabs (real-time voice processing) and Google (conversation analysis) operate under zero-retention agreements; other providers retain data only as needed to deliver their services and as described in our retention practices.

    3.3 Usage limits

    • No targeted advertising: Data is never used for advertising or external marketing purposes.
    • No data re-selling: We do not re-sell your data to other companies for the purpose of selling a product or service to end users.

    3.4 Security and compliance

    All data is used in accordance with Law 25 in Quebec, PIPEDA in Canada, the GDPR in Europe, HIPAA in the United States, and other applicable data privacy regulations.

    4. Data security

    The security of your data is a top priority for Amical. We are committed to strictly adhering to the requirements of Law 25 on the protection of personal information and implementing strict technical and organizational measures to protect your information from unauthorized access, misuse, disclosure, alteration, or destruction.

    Our security measures include:

    • Compliance with Law 25: Amical is committed to strictly adhering to the requirements of Law 25 on the protection of personal information. All data collected will be processed in accordance with this law and the highest standards of privacy.
    • Data encryption (Encryption at Rest): Sensitive user data, such as conversation transcripts, personal information, and health data, will be encrypted when stored on our servers, thus ensuring protection against unauthorized access.
    • Controlled access to data: Access to the data is strictly limited to authorized personnel, and each access is logged to ensure traceability. Client portal login is passwordless via Supabase Auth: email one-time codes (magic link / OTP), with optional Google or Facebook OAuth sign-in. There is no password-based login for the client portal.
    • Infrastructure isolation (VPC): Amical's infrastructure will be isolated within a virtual private cloud (VPC) to minimize the risks of cyber attacks and unauthorized access.
    • Monitoring and alerts: A continuous monitoring system will be in place to detect any suspicious activity. Alerts will be generated in real-time in case of anomalies or intrusion attempts.
    • Vulnerability management: Regular vulnerability scans will be conducted to identify and fix potential security flaws. We use cutting-edge tools and techniques to ensure the security of our system.
    • Security updates: Security updates will be applied regularly to protect the system against the latest threats and vulnerabilities.
    • Transmission security: We use the HTTPS protocol to encrypt data during transmission between your device and our servers, thus ensuring the confidentiality and integrity of your information.
    • Voice data security: Voice recordings are processed and stored with strict security measures, and access is limited to authorized personnel. Because a voice recording is itself identifying, audio is not anonymized; where transcripts are used for product improvement, direct personal identifiers are removed (de-identification) before analysis.

    Data management for different purposes:

    • Legal protection: Data collected for legal protection purposes, such as recordings and transcripts of conversations, as well as voice data, are retained with identifiers. Access to this data is restricted and controlled, reserved for key employees and used only for control, prosecution, or defense purposes in case of litigation.
    • Product and AI improvement: Data used to train our AI, such as anonymized recordings and transcripts, do not contain any information that could identify users. Access to this data is restricted to the technical team and used only to improve the performance and accuracy of the AI.

    Categories of persons authorized to access information

    Access to personal information is limited, following the principle of least privilege, to the following categories of persons:

    • Authorized management of the partner healthcare establishment and its employees: the establishment's administrators decide which employees they invite and which granular permissions they grant them: inviting users and managing their permissions; downloading the organization's data (metadata export); editing the organization's settings; accessing the transcripts and audio recordings of all calls (access granted call by call); accessing only the transcripts and recordings of calls that generated an alert; generating API keys for partner integrations. Access is restricted per account and segregated by establishment.
    • Authorized family members (personalized phones): restricted access to the number, duration, dates, and topics of calls as well as notifications, and editing of the resident's life story and preferences; no access to recordings or full transcripts.
    • Onboarding staff: Amical staff who access the profile and configuration information needed to set up the account, the devices, and the initial personalization of the Service.
    • Technical support and customer service (Amical): access needed to resolve issues reported by customers and to monitor usage (for example, identifying inactive devices); no access to non-deidentified voice transcripts.
    • Quality assurance (Amical): targeted review of flagged calls to improve the system's oversight and safeguards; consulting recordings requires a documented reason.
    • Development teams (Amical): access to production systems (including the database) needed for development, debugging, and maintenance; consulting recordings or transcripts requires a documented reason and is never systematic; a significant part of development is done in a test environment with synthetic data.
    • System administrators (Amical): access to the hosting and operations infrastructure needed to maintain the security, availability, and performance of the Service.
    • Person responsible for the protection of personal information: access needed to handle access and rectification requests and complaints, and to oversee the Service's compliance.

    All access by the Amical team is controlled and logged. Consulting recordings and transcripts requires a documented reason, recorded in the audit log, and the authorization is only valid for a limited time; each new consultation requires a new documented request.

    5. Data retention

    We retain your data for as long as necessary to achieve the purposes described in this privacy policy, and for a maximum of 7 years, unless a longer duration is stated in writing in a separate agreement.

    • Shorter retention policy: Users and establishments may set a shorter data retention policy. However, we may not be able to provide specific optional features, such as alerts made available to authorized users, if the data retention period is too short or if no data is kept on our end.
    • Call durations and call costs: Call durations and call costs are kept indefinitely by Amical to monitor product usage and business performance.

    6. User rights

    You have certain rights concerning your personal data, including:

    These rights, including the rights of access and rectification, cannot be exercised through the client portal or any other technological interface. All requests must be sent by email to info@amical-ai.com.

    • Right of access: You can request access to the personal data we hold about you by contacting us by email at info@amical-ai.com. We will respond within 30 calendar days.
    • Right of rectification: You can request the correction of any inaccurate or incomplete information by contacting us by email at info@amical-ai.com.
    • Right of deletion: You can request the deletion of your personal data, subject to certain legal exceptions, by contacting us by email at info@amical-ai.com.
    • Right of opposition: You can oppose the processing of your personal data in certain circumstances by contacting us by email at info@amical-ai.com.
    • Right to portability: You can request to receive your personal data in a portable format by contacting us by email at info@amical-ai.com.
    • Right to lodge a complaint: You may file a complaint about our handling of your personal information with the Commission d'accès à l'information du Québec (CAI).

    7. International data transfers

    Your personal information is hosted and stored in Canada: all Service data — including call recordings, transcripts, and databases — is hosted with Amazon Web Services and Supabase in the Canada Central region (ca-central-1, in the greater Montréal area, Québec), and backups remain in Canada with our hosting providers. No permanent storage of Service data (recordings, transcripts, databases) takes place outside Canada. Conversation analysis (transcripts) is performed exclusively in Canada by Google's LLM services, under a zero-retention agreement.

    Some specific processing nevertheless involves processing or transit in the United States, with the following providers:

    • ElevenLabs (conversational voice AI): live call audio, processed in real time; zero-retention agreement — neither audio nor transcript is retained after the call.
    • Twilio (telephony and messaging): call audio in transit (partly processed in the United States), phone numbers, call metadata, and SMS messages related to the Service.
    • SendGrid (transactional email): email addresses and notification content, following a minimal-content principle.
    • Datadog and Sentry (application monitoring): technical context and technical identifiers needed for monitoring and error tracking; no clinical content.
    • Business service providers (Stripe, HubSpot, Intuit QuickBooks): billing and payment information, contact details, and support requests, stored in the United States.
    • Meta (optional OAuth sign-in): sign-in credentials (account email address) related to the optional OAuth sign-in to the client portal.
    • Hologram (cellular connectivity): cellular connectivity information, device location, and device usage statistics.
    • GDMS (Grandstream device management — Oregon, United States): device technical configuration only; no personal information.

    Before transferring personal information outside Québec, we conduct an assessment to confirm that the information will receive protection equivalent to that required under Quebec law (Law 25), and we enter into written data processing agreements with the providers concerned. We also apply additional safeguards such as data minimization and the zero-retention agreements described above.

    8. Minors

    Our services are not intended for individuals under the age of 18.

    9. Policy updates

    We may update this privacy policy from time to time to reflect changes in our practices or legislation. We will inform you of any significant changes by posting the new version on our website or by other appropriate means.

    10. Contact

    If you have any questions or concerns regarding this privacy policy, please contact us at:

    Amical

    Email: info@amical-ai.com.

    For the Law 25 designation of the organization accountable for Amical's processing of personal information, and for roles by deployment scenario, see section 1.1. Legal entity: 9526-1061 Québec inc., 200-125 Charest E, G1K 3G5, Québec, QC, Canada.

    Person responsible for the protection of personal information (Responsable de la protection des renseignements personnels, Law 25): Tony Aubé, President, reachable at privacy@amical-ai.com.