SilverWise App Privacy Policy

1. Scope and responsibility

This policy applies to the SilverWise native iOS and Android apps from their first public release. It describes the information processed when authorised staff use SilverWise for professional care management. Features depend on your organisation, role and the functions you choose to use. The website and web-platform privacy policy remains available separately.

SilverWise is operated by Lever Design OÜ, registry code 14922370, Katusepapi 4, Tallinn, Estonia. Contact info@silverwise.eu about this policy, privacy choices or deletion requests.

Your care organisation determines the purposes, lawful basis, access and retention rules for care records and organisation-directed employee processing. SilverWise processes those records on its behalf under a data-processing agreement. We are responsible for our own account administration, service security, support and business-contact processing. Contact your organisation about records it controls or its employee-location policy; contact us about your account and our own processing.

2. Information processed and its purposes

Depending on the features used, we process:

Account and organisation information: name, email, user/account identifiers, role, department and organisation details, for authentication, access control, support and service administration.
Care information: client identifiers, health and care records, medication and evaluations, schedules, visits, notes, photographs, documents and audio you submit, to provide the organisation’s care-management functions.
Location information: precise coordinates, capture times, accuracy, motion state, speed and battery information, linked to a worker account, device and organisation, for optional home-care route recording and its technical operation.
Device and notification information: device identifiers, platform, push tokens and delivery preferences, to register your phone and deliver organisation and department notices.
Usage and technical information: feature interactions, activity/security logs, network information and diagnostics, for security, support, service reliability and configured product analytics. Local storage supports sign-in, preferences and offline queues.

Care records and routes may reveal sensitive information, including health information and a client’s home address. They are accessible to authorised organisation users according to their permissions, not to the public.

Our own processing relies on the relevant service contract, legitimate interests in security, support and service improvement, legal obligations, or consent where applicable. The organisation establishes the appropriate basis, including the relevant condition for health information, for processing it directs. Phone permissions and app acknowledgements do not replace those responsibilities.

3. Optional background location

Home-care workers can enable route recording after reading the disclosure and granting the required location permissions on their own phone. Viewing another worker’s records does not require a manager to grant their own background-location permission. Location-dependent features are optional; declining does not block unrelated care, account or settings functions.

Background permission lets SilverWise record locations while the app is in the background or the screen is locked. Motion information supports battery-aware operation. Offline samples can be queued on the device and uploaded when connectivity returns. Samples may be incomplete or inaccurate because of permission changes, battery state, connectivity or operating-system restrictions.

Where your organisation’s schedule-access restrictions apply, recording follows those restrictions and their grace period. If those restrictions do not apply to you, recording continues while you are signed in, including outside scheduled hours. Recording is not automatically limited to visits or shifts. The app explains the applicable mode before you enable recording.

Settings → Phone permissions shows recording status and lets you stop or resume recording. You can also stop recording by signing out or revoking location permission in your phone’s settings. Stopping collection does not itself delete previously uploaded records. Your organisation’s authorised managers can view route records under its access rules; contact it for details about who has access.

Coordinates and capture times have no automatic expiry and remain until removed through account/GPS deletion or the responsible organisation’s deletion process. Additional location diagnostics are retained for up to 30 days. These rules do not authorise collection or retention beyond what is necessary for the organisation’s lawful purpose; requests to delete or restrict records are handled under section 7.

4. Camera, photos, voice and AI assistance

Camera/photo access supports care-record attachments; microphone access supports optional voice input. The app explains the feature before requesting the relevant phone permission. You may decline or revoke permission and continue using functions that do not depend on it. The app does not upload your entire photo library or read your contacts for these features.

Optional dictation or care-documentation assistance sends audio, transcripts and the care information needed for the request through our backend to Microsoft Azure OpenAI Service for transcription or draft suggestions. Input may include personal and health information about you or the person receiving care.

Before this information is sent, the app identifies the provider, explains the data involved and asks for your permission. You choose when to record and submit content; declining leaves manual entry available. A microphone permission alone does not authorise third-party AI processing. Only submit care information your organisation authorises you to process. AI suggestions are identified as such and must be reviewed and corrected before being saved as care records.

Provider processing and retention depend on the configured service and applicable processing terms. We do not promise zero provider retention or that every request remains in one country. Information about processing arrangements and safeguards is available from info@silverwise.eu.

5. Notifications and maps

Native notices use Firebase Cloud Messaging and, on iOS, Apple Push Notification service. Tokens, platform information and preferences are linked to your account/device registration. The relevant provider receives the token and notification payload to deliver notices. Depending on your phone settings, notification content can be visible on the lock screen. You can disable notifications in the app or your phone’s settings without disabling unrelated features.

Map and navigation requests may send addresses, coordinates or route information to Google Maps. An external directions app processes information under its own privacy terms. Displaying a route is not a promise that coordinates go only to SilverWise.

We use providers for hosting, authentication, messaging, maps, optional AI, analytics and diagnostics. Depending on enabled features, these include Firebase/Google, Apple, Google Maps, Microsoft Azure OpenAI, PostHog and Axiom. Our subprocessors information provides additional details about processing services.

We require providers processing information on our behalf to follow contractual confidentiality, security and data-protection obligations providing at least the protection described in this policy. Your organisation’s agreement and data-processing agreement govern its care-service use. Provider processing may take place outside the European Economic Area. Where required, transfers use an applicable adequacy decision or approved contractual safeguards, including European Commission standard contractual clauses and supplementary measures as appropriate. Contact us for the relevant processing locations and safeguards.

We use encrypted connections, role-based access and technical and organisational security measures. We may disclose information where legally required. We do not sell personal information or use care records or worker-location information for advertising or cross-app advertising tracking. Product analytics and diagnostics serve the purposes in section 2.

7. Retention, account deletion and your rights

Account and service information is retained for the relevant account/customer relationship and operational needs, subject to applicable legal obligations. Organisation-held care, employee and audit records follow that organisation’s retention policy. Route and diagnostic retention is described in section 3.

You can initiate account deletion in Settings → Account → Delete my account, reauthenticate and confirm deletion. This removes your sign-in identity, personal account details, notification registrations and GPS history. Access stops when the request is accepted; deletion is processed automatically, normally within a few minutes. Contact info@silverwise.eu if you need confirmation or help with a delayed request.

Deleting your account does not automatically erase care, employee or audit records your organisation is responsible for retaining. Contact that organisation about those records. Deleted information may remain in restricted backups until those backups are replaced under their rotation schedule; it is not used for ordinary service operations. If a backup is restored, applicable deletion instructions must be reapplied. Information retained for a legal obligation is restricted to that purpose.

Depending on the applicable law and circumstances, you may request access, correction, deletion, restriction, portability or object to processing. You may withdraw consent where processing relies on it, without affecting earlier lawful processing. Revoking a phone permission stops that permission’s use but does not itself erase history. Contact us for our processing and your account, or your organisation for records it controls. You may complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or your competent supervisory authority.

8. Changes and contact

We update this policy when relevant practices change and publish its revision date. Material changes are communicated before the relevant processing changes take effect. This mobile policy does not change your organisation’s contractual responsibilities or replace the separate website and web-platform policy.

Lever Design OÜ · Registry code 14922370 · Katusepapi 4, Tallinn, Estonia · info@silverwise.eu