Teton Platform Privacy Notice

1. Introduction

We at Teton.ai ApS, Teton.ai Inc., Teton.ai Ltd and Teton.ai GmbH (“Teton”, “we”, “us”) have created this Privacy Notice to explain how personal data is handled when the Teton care-monitoring platform, including the sensors and edge devices installed in care environments (the “Platform”), is used in your community.

This notice applies to residents, their relatives and visitors, and care staff who may appear in data processed by the Platform. It does not cover our website, which has its own privacy notice at www.teton.ai. This notice is the reference document for the Resident Disclosure, Consent and Authorization Form and forms part of that disclosure.

2. Who is responsible for your data

Your care community, meaning the care provider that operates your residence, is the data controller for personal data processed through the Platform, including data used to keep the Platform accurate. The community holds the relationship with you and decides the purposes of the processing. In the United States, where the community is a HIPAA covered entity, the community is the covered entity and Teton is its business associate.

Teton is the data processor. We process data only on the community’s documented instructions, under a data processing agreement, and we do not use it for our own purposes. If you have questions, requests or complaints about your data, please contact your community first. You can also reach us at privacy@teton.ai and we will assist.

3. What the Platform collects

The Platform works with two categories of data. Operational data is the data used to deliver the care service itself: care monitoring, alerts and care-quality insights. Training data is the limited set of event clips used to improve detection accuracy and ensure the quality of the system at your site. Training data is collected only where a separate improvement permission has been granted.

The in-room sensor processes images locally on the device in your room. Images that are not needed for your care are deleted on the device immediately. When the Platform detects an event that needs attention, such as a possible fall, it sends a de-identified rendering to authorized care staff so they can respond. It also generates non-image summary data, such as alert response times and sleep, activity and respiration trends, to support care planning. This is the Operational data.

Where the improvement permission has been granted, short event-related video clips of roughly 30 to 60 seconds may be securely transferred to Teton. This is the Training data, described in section 4.

The Platform records no audio and offers no live video streaming. It identifies people in a clip only by type and role in the care event, for example resident, staff or visitor. It performs no facial recognition, no identification of specific individuals, and no profiling. Clips carry only minimal metadata: a site acronym, the recording date and the device ID. They contain no names or other identifiers beyond the image itself.

4. How data is used

The two categories serve two distinct purposes. Operational data delivers the care service. Training data is to ensure detection accuracy and overall in-site quality:

Operational data: care monitoring and alerts. The Platform detects falls and other situations that need attention, alerts care staff, and generates care-quality insights to support care planning. In HIPAA-covered communities, in-facility quality remediation of the system delivering your care is carried out as part of the community’s health care operations.

Training data: improving detection accuracy and site quality. When the Platform makes an error or detects a safety event, one or more short event clips may be securely transferred to Teton, viewed by a small number of trained Teton reviewers, and used to improve detection accuracy and ensure the quality of the system at your site. Because the detection models are shared, these improvements may benefit other communities. Only event-related clips are used, which is roughly 1 to 2% of events. This happens only where the resident or their legal representative has granted the separate improvement permission. Without that permission, no Training data is collected for that room and the care service runs in full.

People other than the resident who appear in a clip, such as staff, relatives or visitors, are labelled only by their role in the care event and never by their own health state. We also use data to provide customer support, monitor the performance and security of the Platform, and comply with our legal obligations.

5. Legal basis

The legal basis for the processing depends on who the data relates to and where you are.

Residents. In the UK, the basis is the community’s legitimate interest in accurate and safe care technology, which is assessed and documented, together with the health and social care condition under UK GDPR Article 9(2)(h) paired with the Data Protection Act 2018. You may object at any time under Article 21, and the improvement permission for your room can be declined or revoked at any time. In the EU, the basis is the applicable care-law basis or legitimate interest, as documented with your community. In US communities covered by HIPAA, in-facility quality remediation is carried out as health care operations under the community’s business associate agreement, and the transfer of event clips to Teton rests on your signed authorization under 45 CFR §164.508. In US communities not covered by HIPAA, the basis is your opt-in consent to the processing of sensitive data under applicable state privacy law.

Care staff. The basis is the employment relationship with the community and the community’s legitimate interest in safe, high-quality care, supported by workplace notice. Staff appear in data only in their role in the care event and are never evaluated for performance through the Platform.

Relatives and visitors. The basis is legitimate interest in accurate and safe care technology. A system that can reliably tell a visitor from a resident produces fewer false alarms for everyone. This interest is assessed and documented, and is supported by signage at the community. In the UK and EEA you may object at any time under Article 21. See section 9.

6. Retention

Operational data is retained to support the resident’s ongoing care. Training data is retained only for as long as necessary to keep the relevant detection capability accurate, which in practice is the operational life of the deployed model. Retention is not tied to the term of any commercial agreement.

When data is no longer needed for these purposes, we follow a de-identification first approach. Wherever possible, data is anonymised or de-identified so that it can no longer be linked to an identifiable person; once de-identified, it is no longer personal data. Where de-identification is not possible, the personal data is returned to the community or deleted, as instructed by the community in its role as controller and, in the US, covered entity.

On move-out, death or revocation of the improvement permission, the community, as controller, instructs Teton to de-identify or delete the relevant data. If the improvement permission is revoked, no new Training data is collected, and stored clips are de-identified or deleted within 30 days. Improvements already built into the system are not reversed.

Where the law requires us to retain data for longer, for example to comply with a legal obligation or resolve a dispute, we retain only what is required and only for as long as required.

7. Sharing and international transfers

We do not sell personal data. We disclose it only to service providers acting on our documented instructions, such as cloud hosting and IT support providers, and, where the community uses them, the electronic health record systems the Platform integrates with. All are bound by contract to protect the data. We may also disclose data where required by law or by valid requests from public authorities.

Platform data is hosted by AWS in the EU North data centers. Data is not stored outside the EU/EEA. Where personal data is accessed or otherwise processed from outside the EU, the EEA or the UK, that processing rests on an adequacy decision, the European Commission’s Standard Contractual Clauses, or, for the UK, the ICO’s International Data Transfer Agreement or the UK Addendum. You may request a copy of the applicable safeguards.

8. Security

We apply technical and organizational measures appropriate to the sensitivity of the data. These include encryption in transit and at rest, strict role-based access with logging, on-device deletion of unneeded images, and confidentiality undertakings for everyone who handles the data. Access to improvement clips is limited to a small number of trained reviewers and every access is logged. If a breach creates a risk to you, we support the community in notifying the relevant authority and affected individuals as required by law.

9. Your rights

These rights apply to everyone who appears in the data: residents, staff and visitors alike. Subject to applicable law, you may access the personal data held about you and receive a copy, have inaccurate data corrected, have your data deleted, restrict processing, receive your data in a portable format, and object to processing based on legitimate interests under UK/EU GDPR Article 21. If you object, processing of your data stops unless compelling legitimate grounds are shown:

9.1 Right of access (Article 15 GDPR). You have the right to obtain confirmation as to whether we process your personal data and, if so, to request access to that data and receive a copy, along with information about the processing.

9.2 Right to rectification (Article 16 GDPR). You have the right to request correction of inaccurate or incomplete personal data concerning you.

9.3 Right to erasure (Article 17 GDPR). You have the right to request deletion of your personal data in certain circumstances, including where the data is no longer necessary for the purposes for which it was collected, you withdraw consent and there is no other legal basis for processing, you object to processing based on legitimate interests and there are no overriding legitimate grounds, the data has been unlawfully processed, or erasure is required to comply with a legal obligation.

9.4 Right to restriction of processing (Article 18 GDPR). You have the right to request that we limit how we use your data in certain circumstances, including where you contest the accuracy of the data, the processing is unlawful and you oppose erasure, we no longer need the data but you require it for legal claims, or you have objected to processing pending verification of whether our legitimate grounds override yours.

9.5 Right to data portability (Article 20 GDPR). Where processing is based on consent or contract and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another controller.

9.6 Right to object (Article 21 GDPR). You have the right to object at any time to processing of your personal data based on legitimate interests, unless we demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for legal claims. You also have the right to object to processing of your personal data for direct marketing purposes, including profiling related to such marketing, in which case we will cease processing for such purposes.

9.7 Rights related to automated decision-making (Article 22 GDPR). You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning you, unless such decision is necessary for entering into or performing a contract, is authorized by applicable law, or is based on your explicit consent.

9.8 Right to withdraw consent. Where processing is based on your consent, you may withdraw it at any time, without affecting the lawfulness of processing carried out before its withdrawal.

9.9 Teton does not currently engage in solely automated decision-making, including profiling, that produces legal effects concerning data subjects or similarly significantly affects them within the meaning of Article 22 GDPR. Where the Platform incorporates automated features or algorithms, these are used solely to support and assist human decision-making and do not produce decisions based solely on automated processing. If Teton introduces any such automated decision-making or profiling in the future, we will update this Privacy Notice to provide full disclosure and will ensure that appropriate safeguards are in place, including the right to obtain human intervention, to express your point of view, and to contest the decision.

Where processing rests on consent or a HIPAA authorization, you may withdraw or revoke it at any time. Withdrawal operates going forward and does not affect processing already carried out. Your care is never conditioned on consent. Your care is also never conditioned on the improvement permission, which may be revoked at any time with effect going forward.

Because the Platform does not identify specific individuals, we may need additional information from you, such as the date, time and location of a visit, to locate data relating to you. Requests can be made through your community or to privacy@teton.ai, free of charge. We respond within the timelines required by applicable law, at most 30 days in the EU and UK and 45 days under US state laws, and we may verify your identity first.

You may complain to Teton at privacy@teton.ai. You also have the right to complain to a supervisory authority: in Denmark, Datatilsynet (dt@datatilsynet.dk); in the UK, the Information Commissioner’s Office (ico.org.uk); elsewhere in the EEA, your local supervisory authority; and in the US, your state attorney general.

10. Jurisdiction-specific notices

United States. Teton does not sell personal information. Where the Platform processes sensitive data, including health-related data, in states with comprehensive privacy laws such as Texas, Florida and Oklahoma, it does so on the basis of opt-in consent as those laws require, except where the data is governed by HIPAA, in which case HIPAA applies instead. In HIPAA-covered communities, the signed Resident Disclosure, Consent and Authorization Form is the authorization under 45 CFR §164.508 for the improvement use. It cannot be conditioned on your care and may be revoked prospectively.

United Kingdom. Where UK residents’ data is processed, we comply with UK GDPR and the Data Protection Act 2018. Where the community relies on the health and social care condition, it does so paired with Schedule 1 of the DPA 2018 and maintains the required appropriate policy document. UK transfers use the IDTA or the UK Addendum. The ICO is the supervisory authority.

EU and Denmark. Teton.ai ApS is established in Denmark and subject to the supervision of Datatilsynet. Processing of residents’ health data rests on the applicable care-law basis or legitimate interest, as documented with your community.

11. Children

The Platform is designed for adult care settings and is not directed at children. We do not knowingly process children’s data through the Platform. Please contact us if you believe this has occurred.

12. Changes to this Privacy Notice

12.1 We may update this Privacy Policy from time to time to reflect changes in our data processing practices or services, changes in applicable data protection law or regulatory requirements, technological developments or industry best practices, or feedback from users, regulators, or other stakeholders.

12.2 When we make material changes to this Privacy Policy, we will notify you by posting the updated policy on our website with a new “Last Updated” date, sending you an email notification at the email address associated with your account (where we have your contact details and the change materially affects your rights), or displaying a prominent notice on our website or within the Platform prior to the changes taking effect.

12.3 We will provide you with at least 30 days advance notice of any material changes that adversely affect your rights or significantly alter how we process your personal data.

12.4 The “Last Updated” date at the top of this Privacy Policy indicates when it was most recently revised. We encourage you to review this policy periodically to stay informed about how we protect your personal data.

12.5 If you do not agree to the changes, you should discontinue use of our services and contact us to discuss your options, which may include account closure or data deletion, subject to our legal obligations.

13. Contact

For questions, requests or complaints, contact privacy@teton.ai or write to Teton.ai ApS, Copenhagen, Denmark.