Privacy Policy

1. Overview and scope

Filo Health provides a unified customer-communications platform: a single inbox plus AI agents that businesses ("Customers") use to send, receive, route, and respond to messages and calls across multiple communication channels. Our service connects, on behalf of our Customers, to third-party platforms including WhatsApp and Instagram (Meta Platforms), Gmail (Google), Outlook (Microsoft), generic IMAP/SMTP email servers, and telephony and SMS networks (via Telnyx), including AI voice agents and automated appointment reminders.

This Privacy Policy explains how we access, use, store, share, and retain personal data when you use our website, applications, and services (collectively, the "Service"). It applies to:

• Customers: the businesses and their authorized users who subscribe to and configure the Service.
• End Users: the individuals (e.g., a Customer's patients, clients, or contacts) who communicate with a Customer through channels connected to the Service.
• Website visitors: anyone who visits https://www.filohealth.io.

2. Our role: controller vs. processor

For most communications data that flows through the Service on behalf of a Customer (messages, emails, call content, contact records, and related metadata), Filo Health acts as a data processor (a "service provider" under U.S. law) that processes data under the instructions of the Customer, who is the data controller. The Customer is responsible for having a lawful basis and the necessary notices and consents in place for the End User data they route through the Service.

For our website, account administration, billing, marketing, and product analytics, Filo Health acts as the data controller. Where we act as a processor, our Data Processing Addendum (DPA) governs that processing in addition to this policy.

3. Data we collect

Account and Customer data

• Name, business name, email address, phone number, role, and password/authentication credentials.
• Billing and payment information (processed by our payment provider; we do not store full card numbers).
• Configuration data: connected channels, AI agent settings, routing rules, and team membership.

Communications content and metadata (processed on behalf of Customers)

• Message bodies, attachments, email subjects/bodies, and call audio, recordings, and transcripts.
• Contact identifiers: phone numbers, email addresses, WhatsApp/Instagram handles and IDs, profile names.
• Metadata: timestamps, delivery/read status, call duration, direction (inbound/outbound), and routing data.

Technical and usage data

• IP address, device and browser information, log data, and product usage events.
• Cookies and similar technologies on our website (see our cookie disclosures / banner).

4. Platform-specific data handling

The table below summarizes what we access, why, and how long we keep it for each integrated platform. Platform-specific compliance disclosures follow in sections 5 through 10.

5. WhatsApp and Instagram user data (Meta Platforms)

Filo Health integrates with the WhatsApp Business Platform and the Instagram Messaging API provided by Meta Platforms, Inc. ("Meta"). When a Customer connects a WhatsApp Business or Instagram account, we access and process the messages and related data necessary to deliver the messaging features of the Service. Our use of data obtained through Meta platforms complies with applicable Meta Platform Terms, Developer Policies, and the WhatsApp Business Solution Terms.

• What we access: message content and attachments, the sender's WhatsApp/Instagram profile name and ID, phone number (WhatsApp), conversation and delivery metadata, and timestamps.
• How we use it: solely to display, route, send, and respond to messages within the unified inbox, to enable AI-assisted and automated replies configured by the Customer, and to provide support and security.
• How we store it: encrypted in transit and at rest; access is restricted to authorized personnel and the Customer's authorized users.
• How we share it: we do not sell Meta platform data and do not use it for advertising. We share it only with subprocessors that support the Service and as directed by the Customer (see section 13).
• Retention and deletion: we retain Meta platform data only as long as needed to provide the Service or as configured by the Customer, and we delete it upon account disconnection, Customer instruction, or a valid deletion request (see section 19).

6. Google and Gmail data: Limited Use disclosure

When a Customer connects a Gmail account, Filo Health requests access to Google user data through Google APIs to display, send, and organize the Customer's email within the unified inbox. We request the minimum OAuth scopes necessary for these features and do not request broader access than the Service needs.

Customers and End Users can revoke our access to Google data at any time by disconnecting the account in the Service or through their Google Account permissions.

7. Microsoft Graph data (Outlook)

When a Customer connects an Outlook or Microsoft 365 account, Filo Health accesses email data through the Microsoft Graph API using delegated permissions granted via Microsoft's OAuth consent flow. We request only the scopes needed to read, send, and organize the Customer's email within the unified inbox.

• What we access: email messages, headers, attachments, folders/labels, and permission to send mail on the connected mailbox's behalf.
• How we use it: solely to provide the inbox features the Customer has enabled; we do not use Microsoft data for advertising and do not sell it.
• Compliance: our handling of Microsoft data follows the Microsoft APIs Terms of Use and Microsoft's app and data-use requirements. We do not use Microsoft user data to train generalized AI/ML models.
• Revocation: access can be revoked at any time by disconnecting the account in the Service or via the user's Microsoft account permissions.

8. IMAP / SMTP email

For email providers connected via generic IMAP/SMTP, Filo Health uses the mailbox credentials or app-specific passwords supplied by the Customer to fetch and send email. Credentials are encrypted at rest and used only to operate the connection the Customer configured. We access email content and metadata only to provide the inbox features and do not use this data for advertising or model training. Access ends when the Customer disconnects the mailbox or deletes their account.

9. Telephony, SMS, and AI voice (Telnyx)

Filo Health provides voice and messaging features using telecommunications infrastructure from Telnyx LLC ("Telnyx") and, where applicable, downstream carriers. This includes inbound and outbound calls, SMS/MMS texting, AI voice agents that answer or place calls, and automated appointment reminders and notifications.

• What we process: caller/recipient phone numbers, call audio, call recordings, transcripts, SMS/MMS content and delivery status, call duration and direction, and related metadata.
• How we use it: to connect and route calls and messages, power AI voice agents, send reminders/notifications the Customer configures, provide analytics to the Customer, and ensure deliverability, security, and compliance.
• Carrier processing: phone numbers and message content are transmitted to Telnyx and carriers as required to deliver communications. SMS sender registration (10DLC/A2P) data may be shared with carriers and The Campaign Registry.
• Consent and opt-out: Customers must obtain the consent required to call or text End Users and must honor opt-outs. SMS recipients can reply STOP to opt out and HELP for help; standard message and data rates may apply.

10. Call recording and transcription: disclosure and consent

Where enabled by a Customer, the Service can record and transcribe phone calls, including calls handled by AI voice agents. Recordings and transcripts are processed to provide the Service (e.g., to operate the AI agent, create call summaries, enable quality review, and maintain records for the Customer).

Recordings and transcripts are encrypted in transit and at rest, access-controlled, and retained per the Customer's configuration and section 14. AI voice agents are disclosed as automated/AI where required by applicable law.

11. How we use data

• Provide, operate, maintain, and secure the Service and the unified inbox.
• Route, send, receive, record, transcribe, and respond to communications as configured by the Customer.
• Operate AI agents (text and voice) and automated workflows (e.g., appointment reminders).
• Authenticate users, manage accounts, process billing, and provide customer support.
• Monitor for fraud, abuse, and security incidents, and enforce our terms.
• Analyze aggregated, de-identified usage to improve the Service.
• Comply with legal obligations and respond to lawful requests.

12. AI agents and automated processing

The Service uses AI models to draft replies, summarize conversations, transcribe calls, and operate conversational text and voice agents. AI processing occurs to deliver features the Customer has enabled. We do not use Customer or End User communications content from connected platforms to train generalized or foundation AI/ML models, and we do not permit our AI subprocessors to use such content to train their general models, except as expressly permitted by the Customer or required for the contracted service. Where Customer-specific model tuning is offered, it is limited to that Customer's environment and governed by the DPA.

13. How we share data

We do not sell personal data. We share data only as follows:

• Subprocessors / service providers: cloud hosting, communications infrastructure (e.g., Telnyx), AI model providers, analytics, and support tools, under contracts that restrict their use of the data. A current list of subprocessors is available at https://www.filohealth.io/subprocessors or on request.
• Integrated platforms: Meta, Google, Microsoft, email servers, and carriers, as necessary to deliver communications you direct through the Service.
• The Customer: End User communications are shared with the Customer (and its authorized users) on whose behalf we process the data.
• Legal and safety: to comply with law, enforce agreements, or protect the rights, safety, and security of users and the public.
• Business transfers: in connection with a merger, acquisition, or sale of assets, subject to this policy.

14. Data retention

We retain personal data only as long as necessary to provide the Service, comply with legal obligations, resolve disputes, and enforce agreements. Communications content and recordings are retained according to the Customer's configured retention settings (default: 12 months) and are deleted when a channel is disconnected, the account is closed, or a valid deletion request is honored. Aggregated, de-identified data may be retained longer. Backups are purged on a rolling schedule of up to 35 days.

15. Security

We implement technical and organizational measures appropriate to the risk, including encryption in transit (TLS) and at rest, access controls and least-privilege, network protections, logging and monitoring, and regular reviews. No method of transmission or storage is completely secure; we cannot guarantee absolute security. We maintain an incident response process and will notify affected parties of breaches as required by law.

16. International data transfers

We may process and store data in countries other than where you are located, including the United States and the European Economic Area. Where required, we use appropriate safeguards for international transfers, such as the European Commission's Standard Contractual Clauses and, where applicable, the UK International Data Transfer Addendum.

17. Your rights under the GDPR (EEA/UK)

If you are in the European Economic Area, the United Kingdom, or Switzerland, you have the following rights regarding your personal data, subject to legal limits:

• Access, rectification, and erasure ("right to be forgotten").
• Restriction of processing and objection to processing.
• Data portability.
• Withdrawal of consent at any time (without affecting prior processing).
• The right to lodge a complaint with a supervisory authority.

Lawful bases for processing

Where Filo Health is a controller, we rely on the following lawful bases:

• Contract: to provide the Service to Customers and their users.
• Legitimate interests: to secure, maintain, and improve the Service, prevent abuse, and run our business, balanced against your rights.
• Consent: for marketing communications and certain cookies, where required.
• Legal obligation: to comply with applicable laws.

Where we act as a processor on behalf of a Customer, please direct GDPR requests to that Customer (the controller); we will assist them as required. To exercise rights for data we control, contact danablend@gmail.com. Filo Health is established in Denmark (an EEA Member State), so a separate EU representative under GDPR Article 27 is not required. UK data subjects may also contact us at the email above.

18. Your rights under the CCPA/CPRA (California)

If you are a California resident, you have the right to:

• Know/access the categories and specific pieces of personal information we collect, use, and disclose.
• Delete personal information we have collected, subject to exceptions.
• Correct inaccurate personal information.
• Opt out of the "sale" or "sharing" of personal information.
• Limit use of sensitive personal information.
• Non-discrimination for exercising your rights.

Categories of personal information we collect

In the preceding 12 months, we have collected the following CCPA/CPRA categories of personal information:

• Identifiers: name, email address, phone number, account ID, IP address, device identifiers.
• Customer records (Cal. Civ. Code § 1798.80(e)): business contact details and billing information.
• Commercial information: subscription plan, usage records, and transaction history.
• Internet or other electronic network activity: log data, product usage events, and interactions with our website.
• Geolocation data: approximate location derived from IP address.
• Audio, electronic, visual, and similar information: call recordings, voice audio, transcripts, and message attachments processed on behalf of Customers.
• Professional or employment-related information: role and business affiliation of Customer users.
• Inferences: limited inferences drawn from the above to operate and secure the Service.

Categories of sources

• Directly from Customers and their authorized users (account setup, configuration, support).
• From End Users when they message or call a Customer through a connected channel.
• From the integrated platforms listed in section 4 (Meta, Google, Microsoft, IMAP/SMTP servers, Telnyx).
• Automatically from devices and browsers (cookies, log data) when you use our website or the Service.
• From service providers and subprocessors that support the Service.

Business or commercial purposes for which we use personal information

• Providing, operating, securing, and supporting the Service (see section 11).
• Routing, sending, receiving, recording, and transcribing communications as configured by the Customer.
• Authenticating users, processing billing, and preventing fraud and abuse.
• Analyzing aggregated, de-identified usage to maintain and improve the Service.
• Complying with legal obligations and enforcing our terms.

Categories of personal information disclosed for a business purpose

In the preceding 12 months, we have disclosed each of the categories listed above for the business purposes described, to the categories of recipients listed in section 13 (subprocessors/service providers, integrated platforms, the Customer, and, when required, legal/safety recipients).

Sensitive personal information

To the extent communications content (such as account credentials shared in messages, government identifiers, precise location, or health-related information) constitutes sensitive personal information under the CPRA, we use and disclose it only for the purposes permitted by Cal. Civ. Code § 1798.121 and the CCPA regulations (e.g., to provide the Service the Customer requested, to ensure security and integrity, and as otherwise allowed by law). We do not use sensitive personal information to infer characteristics about you.

"Sale," "sharing," and opt-out preference signals

We do not sell or share personal information as those terms are defined under the CCPA/CPRA, and we have not done so in the preceding 12 months. When we process Customer and End User communications data, we act as a service provider and use the data only to perform the Service. We honor recognized browser-based opt-out preference signals, including the Global Privacy Control (GPC), as a valid opt-out request to the extent required by applicable law.

How to exercise your rights

To exercise your rights, contact danablend@gmail.com. You may use an authorized agent, and we will verify requests as required by law. We will respond within the timeframes required by the CCPA/CPRA. We will not discriminate against you for exercising your rights.

19. Data deletion requests

You may request deletion of personal data by emailing danablend@gmail.com, by using the in-product controls, or by following the data-deletion instructions at https://www.filohealth.io/data-deletion. For End User data processed on behalf of a Customer, we will route the request to the relevant Customer and assist them in fulfilling it. Disconnecting a connected platform (WhatsApp, Instagram, Gmail, Outlook, IMAP/SMTP, or a Telnyx number) revokes our access and triggers deletion of the associated data per section 14, except where retention is required by law.

We will acknowledge a valid deletion request promptly and complete deletion within 30 days of receipt (or sooner where required by applicable law), and we will confirm completion. Residual copies in encrypted backups are purged on the rolling schedule described in section 14.

20. Children's privacy

The Service is intended for businesses and is not directed to children under 16 (or the age defined by local law). We do not knowingly collect personal data from children. If you believe a child has provided us data, contact danablend@gmail.com and we will delete it.

21. Cookies and tracking technologies

We and our service providers use cookies and similar technologies (such as local storage, pixels, and SDKs) on our website and in the Service. We use the following categories:

• Strictly necessary: required to deliver the Service, authenticate users, maintain sessions, and protect against fraud and abuse. These cannot be turned off.
• Functional: remember preferences such as language, locale, and theme.
• Analytics: help us understand how the website and Service are used so we can improve them. Where required, these are set only with your consent.
• Marketing: used to measure and (where applicable) target our own marketing. We do not use marketing cookies to share data with third parties for their own advertising purposes. Where required, these are set only with your consent.

In the EEA, the United Kingdom, and other jurisdictions that require it, non-essential cookies are set only after you give consent through our cookie banner, and you can change or withdraw consent at any time by reopening the cookie banner from our website footer. You can also control cookies through your browser settings; blocking some categories may affect site functionality. We honor recognized opt-out preference signals where required by applicable law (see section 18).

22. Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated version with a new "Last updated" date and, where required, provide additional notice. Continued use of the Service after changes take effect constitutes acceptance.

23. Contact us

Filo Health
Email: danablend@gmail.com
Website: https://www.filohealth.io
Privacy contact: danablend@gmail.com