Hilo Consumer Health Data Privacy Policy
Effective date: 21 July 2026
This Consumer Health Data Privacy Policy explains how Aktiia SA d/b/a Hilo (“Hilo”, “we”, “us”, or “our”) collects, uses, shares, and protects “consumer health data” as defined under applicable U.S. state laws, including the Washington My Health My Data Act and Nevada’s consumer health data law, and the privacy rights and choices you have with respect to such data, in connection with our websites, the Hilo mobile application, our devices, and other products and services (collectively, the “Services”). Hilo products are offered in the United States by Aktiia Inc. Certain processing activities are performed by Aktiia SA and affiliated entities.
This Consumer Health Data Privacy Policy supplements our Privacy Policy. In the event of a conflict between our Privacy Policy and this Consumer Health Data Privacy Policy with respect to consumer health data, this Consumer Health Data Privacy Policy controls. This Consumer Health Data Privacy Policy does not apply to “protected health information” governed by the Health Insurance Portability and Accountability Act (“HIPAA”). If you receive access to the Services through a hospital, clinic, or other third-party healthcare facility that is responsible for your information, please refer to the privacy notice of that facility.
1. Categories of Consumer Health Data We Collect
“Consumer health data” is personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health status. Because our products and Services measure blood pressure and related physiological data, some of the information we collect is consumer health data. We collect the following categories of consumer health data:
Information about your bodily functions, vital signs, symptoms, or measurements, such as blood pressure readings, wrist-signal and pulse data, heart rate, movement, temperature, respiration, sleep-related data, and other physiological measurements collected through the Services or connected devices.
Health-, wellness-, and lifestyle-related information you provide, such as manually entered information about your health, lifestyle, habits, routines, wellbeing, and related notes.
Information about your use of prescribed medications, such as medication-adherence information you record in the Services.
Demographic and profile information relevant to health measurements, such as your age, sex, height, and weight.
Data identifying you as a person seeking health care services, such as your registration for the Services, device pairing and calibration data, and survey or questionnaire responses.
Health information that is derived or inferred from other data, such as sleep stages, activity levels, readiness or recovery indicators, stress or other wellbeing indicators, body mass index (BMI), and other personalized health insights we generate from the data you provide or that is collected through the Services.
2. Categories of Sources of Consumer Health Data We Collect
We collect consumer health data from the following categories of sources:
Directly from you, when you create an account, enter profile information, manually enter health- or wellness-related information, complete surveys or questionnaires, or contact us for support.
From your use of our devices and applications, which generate blood pressure readings, wrist-signal data, and other physiological measurements.
Derived or generated through the Services, such as insights and indicators our algorithms derive from the information described above.
3. Our Purposes for Collecting and Using Consumer Health Data
We collect and use consumer health data for the following purposes:
To provide you with the Services, including to generate, display, and store your measurements and insights, pair and calibrate your devices, personalize your experience, and provide customer support.
To improve and develop the Services, including research, validation, product improvement, algorithm and model training, quality management, and regulatory documentation. As part of these activities, we may create aggregated, de-identified, or other anonymous data from the consumer health data we collect.
To protect against or deter fraudulent, illegal, or harmful actions and maintain the safety, security, and integrity of the Services.
To comply with our legal obligations, resolve disputes, and enforce our terms and agreements.
At your direction or with your consent, if you choose to provide consumer health data to us for any other purpose, as disclosed at the time you provide such information.
We do not use your consumer health data for marketing or advertising.
4. How We Share Consumer Health Data
We may disclose the categories of consumer health data described above to:
Service providers and processors that assist us in providing the Services and are contractually required to protect your information and use it only on our instructions, including providers of cloud hosting and health-data processing (such as Amazon Web Services), analytics and product improvement, and authentication and messaging services.
Our affiliates: Aktiia Inc, Aktiia B.V. and Aktiia Australia Pty.
Third parties at your direction or with your consent, such as healthcare providers or insurers, if you choose to share your information with them.
Law enforcement, government agencies, or other third parties, where we believe in good faith it is necessary or appropriate to comply with applicable laws or protect our legitimate interests.
Business transferees, in the event of a merger, sale, acquisition, bankruptcy, or other transaction in which a third party assumes control of our business or data (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your consumer health data becomes subject to different privacy and security policies and practices.
We do not sell consumer health data. We do not sell your consumer health data, and we will not sell it without first obtaining your valid authorization.
5. Your Rights Regarding Your Consumer Health Data
Depending on your state of residency, you may request the following:
Confirm and access. Confirm whether we collect, share, or sell your consumer health data, access your consumer health data, and receive a list of the third parties and affiliates with whom we have shared it.
Withdraw consent. Withdraw your consent to our collection or sharing of your consumer health data.
Delete. Request that we delete your consumer health data.
Submitting a request. To submit a request regarding any of the rights described above, please email us at legal@aktiia.com legal@aktiia.com, submit our online request form at us.hilo.com/pages/contact-us, or call us at +1 555 971 3663. We will respond within the time required by applicable law. We will not discriminate against you for exercising your rights described above.
How to appeal. If your request to exercise any of the rights described above is denied, you may appeal this decision by emailing us at legal@aktiia.com. We will inform you of the outcome within 45 days of receiving your appeal, including an explanation of the reasons for our decision. If your appeal is denied, you may raise a complaint with the appropriate regulatory enforcement authorities, including the Washington or Nevada attorney general.
6. Changes to This Consumer Health Data Privacy Policy
We reserve the right to make changes to this Consumer Health Data Privacy Policy at any time. If we do so, we will notify you by updating the date of this Consumer Health Data Privacy Policy and posting it on our website. If we are required by law to provide notification of changes in another way, such as by email, we will do so.
7. Contact Us
If you have any questions or comments about this Consumer Health Data Privacy Policy or our privacy practices, please contact us by email at legal@aktiia.com or by mail at:
Aktiia Inc, 75 State Street, Ste 100, Boston, MA, 02109, USA