This Privacy Policy explains how NeurAlly Care Inc. collects, uses, discloses, protects and retains personal information when parents and legal guardians use KeenSpire, including the KeenSpire mobile application, related account services, authorized partner registration pages, support services and associated communications.
KeenSpire is designed for families. We recognize that information about children deserves particular care. This Policy has been written to reflect the current operation of KeenSpire, including mandatory account creation, email-and-password authentication, parent-managed Child Profiles, optional medication information, the Keen AI Parenting Coach, individual subscriptions and sponsored access through authorized partners.
This Policy should be read together with our Terms of Use. If there is a conflict between this Policy and a shorter in-app privacy notice, this Policy will govern unless the shorter notice expressly states otherwise.
KeenSpire is developed and operated by NeurAlly Care Inc. ("NeurAlly Care", "we", "us", or "our"), a company based in Quebec, Canada.
For privacy questions, requests or complaints, you may contact our Privacy Officer at privacy@neurallycare.com.
This Privacy Policy applies to personal information processed in connection with KeenSpire and the related services we provide. It applies to:
This Policy does not apply to websites, applications or services operated by Apple, Google, payment processors, insurers, employers, clinics, associations or other third parties. Those third parties are responsible for their own privacy practices.
KeenSpire is a parental support and child skill-development mobile application. It is designed to help families support children as they build everyday skills, autonomy, emotional skills, confidence, concentration, social abilities and life skills.
The Services may include structured programs, activities, progress tracking, parent notes, downloadable resources, medication reminders or tracking features, and the Keen AI Parenting Coach.
KeenSpire provides educational and parental-support tools. It is not a medical device, healthcare provider, mental health service, psychotherapy service, diagnostic tool or emergency service.
The KeenSpire mobile application is distributed exclusively through the Apple App Store and Google Play. NeurAlly Care does not distribute downloadable versions of the mobile application through its website or through partner landing pages.
Our website and authorized partner landing pages may be used to explain the product, verify eligibility, create an account, redeem an invitation or access code, or activate sponsored access. Downloading the mobile application always occurs through the Apple App Store or Google Play.
A KeenSpire account is required to use the Services. A parent, legal guardian or another adult legally authorized to act for the child must create and manage the account.
At this time, KeenSpire accounts are created using a valid email address and password. We currently do not support Sign in with Apple, Sign in with Google, Facebook Login or other third-party identity providers.
Depending on the access pathway, a parent or legal guardian may first be invited to create an account or verify eligibility through a secure NeurAlly Care or authorized partner registration page. After account creation or activation, the parent or legal guardian downloads the application from the Apple App Store or Google Play and signs in using the registered email address and password.
KeenSpire may be made available through programs sponsored or facilitated by employers, insurers, clinics, associations, educational institutions, brokers or other authorized partners. Sponsored access may be activated using an invitation link, access code, eligibility confirmation or partner landing page.
Partner landing pages are used only for account creation, eligibility verification, access activation or program administration. They are not used to distribute the mobile application and are not intended to direct users to an external purchase mechanism from within the mobile application.
If your access is sponsored, we may process information necessary to verify eligibility, activate access, associate your account with the applicable program, manage entitlement status and provide aggregated or de-identified program reporting. We do not share your child's identifiable profile details, Parent Notes, medication information, AI conversations or detailed activity history with the sponsoring organization unless you expressly authorize us to do so or unless required by law.
Parents may also access KeenSpire through an individual subscription purchased through the Apple App Store or Google Play. Where a subscription is purchased through Apple or Google, payment processing, renewal, cancellation and refund requests are governed by the applicable platform policies.
NeurAlly Care does not receive or store complete payment card information processed by Apple or Google. We may receive limited transaction and entitlement information needed to activate and manage access, such as subscription status, purchase confirmation, transaction identifier, renewal status, expiration date, country or region and refund status.
For the purposes of this Policy:
We collect only personal information that is reasonably necessary to provide, operate, secure, improve and support the Services, or as otherwise permitted or required by applicable law. The categories of information we collect depend on how you use KeenSpire.
When a parent or legal guardian creates a KeenSpire account, we may collect:
Parents or legal guardians may create one or more Child Profiles. A Child Profile may include:
Parents decide what information is entered into each Child Profile. Children do not create independent accounts and do not control Child Profiles.
KeenSpire includes parent-facing tools that allow parents to record notes, observations, reflections, successes, challenges, contextual information and reminders. These notes are intended to help parents observe patterns, track situations over time, prepare discussions with qualified professionals or support family reflection.
Parent Notes are not public and are not visible to other users. We recommend avoiding unnecessary sensitive information unless you believe it is useful for your own records or your use of the Services.
KeenSpire allows parents or legal guardians to voluntarily add medication information to a Child Profile. This may include the name of the medication, dosage, schedule, reminders, notes and related observations entered by the parent.
Medication information is sensitive personal information. We collect and use this information only to provide the medication-related features selected by the parent, support the Child Profile, display reminders or tracking information, and maintain the security and operation of the Services.
KeenSpire does not prescribe medication, recommend medication changes, provide medical advice, monitor treatment effectiveness, or replace a physician, pharmacist, psychologist, nurse or other qualified professional. Parents remain responsible for consulting qualified professionals regarding any medication, treatment, diagnosis, side effects or health concern.
As parents and children use the Services, we collect information related to participation in programs and activities, including:
This information helps personalize the experience, display progress and improve the Services.
When parents or legal guardians interact with Keen, we may process questions, prompts, messages, conversation history, relevant context from the account or Child Profile, selected support needs, activity and progress information, medication-related context if voluntarily provided and relevant to the question, feedback, safety signals and error reports.
We use this information to generate responses, provide parental support, improve quality, troubleshoot issues, maintain safety and monitor performance. Keen is intended for parents and legal guardians and should not be used by children without parent involvement.
When you contact us for support, we may collect your name, email address, account identifier, communications, attachments you voluntarily provide and technical information needed to resolve your request.
We automatically collect certain technical information when you use KeenSpire, including device model, operating system, application version, language settings, device identifiers, IP address, approximate region, diagnostic information, crash reports, performance information, timestamps, session duration and security logs.
We collect information about how the Services are used, such as screens viewed, features used, navigation paths, session frequency, time spent, activity completion, notification interactions, feature adoption and performance metrics. Whenever possible, analytics are aggregated or de-identified before being used for reporting or product improvement.
If notifications are enabled, we may send reminders, activity prompts, progress notifications, medication reminders configured by the parent, product updates, subscription notices, service announcements and security notifications. Marketing communications are sent only where permitted by applicable law and may be withdrawn at any time.
Except for medication information voluntarily entered by a parent or legal guardian through the medication feature, KeenSpire is not designed to collect medical diagnoses, clinical reports, treatment plans, prescriptions issued by professionals, health insurance policy numbers, claims information or emergency health information.
If parents voluntarily include other sensitive health-related information in Parent Notes, Child Profiles, customer support communications or conversations with Keen, we process it only as necessary to provide the Services and in accordance with this Policy.
We use personal information to:
We may use aggregated, anonymized or de-identified information for analytics, product improvement, research and development, reporting and business planning. We do not use children's personal information for cross-context behavioral advertising.
Some information processed through KeenSpire may be sensitive, particularly when it relates to a child, medication, support needs, family context or observations entered by a parent.
We process sensitive personal information only for the purposes described in this Policy, including providing the Services, maintaining account functionality, supporting safety, responding to requests, protecting the Services and complying with legal obligations.
KeenSpire is not a healthcare provider and does not provide medical, psychological, psychiatric, therapeutic, pharmaceutical or emergency services. Medication features are organizational tools for parents. They do not constitute medical monitoring, treatment management, medication advice or clinical follow-up.
Where applicable privacy laws require us to identify a legal basis, we process personal information based on one or more of the following:
The Services and our website may use cookies, mobile software development kits (SDKs), local storage, analytics tools and similar technologies. These technologies help operate the Services, remember preferences, improve performance, measure use, detect errors, maintain security, support subscriptions and communicate with users.
These technologies are not used to deliver behavioral advertising to children. You may manage certain permissions and notifications through your device or application settings.
KeenSpire is distributed exclusively through the Apple App Store and Google Play. If you download the application or purchase an individual subscription through either platform, Apple or Google may process information according to their own privacy policies and terms.
We may receive limited information from Apple or Google necessary to manage access, such as subscription status, transaction identifiers, country or region, refund status and entitlement status. We do not receive your complete payment card number from Apple or Google.
We do not sell personal information. We do not sell children's personal information. We do not share children's personal information for cross-context behavioral advertising.
We may disclose personal information to the following categories of recipients:
When access is provided through an employer, insurer, clinic, association or other partner, we may share aggregated or de-identified information such as activation counts, overall utilization or program-level metrics. We do not share identifiable Child Profile details, medication information, Parent Notes, AI conversations or detailed activity history with the sponsoring organization unless you expressly authorize us to do so or the law requires it.
KeenSpire may use artificial intelligence technologies to provide the Keen AI Parenting Coach. Prompts and relevant contextual information may be processed by NeurAlly Care or trusted AI service providers to generate responses.
We implement contractual, technical and organizational safeguards for AI processing. We do not permit AI service providers to use personal information for their own marketing purposes. We may monitor, log, review or process AI interactions for safety, quality, troubleshooting, support and service improvement.
We do not make decisions that produce legal or similarly significant effects about you or your child solely through automated processing. Keen does not determine eligibility for healthcare services, diagnose conditions, prescribe or recommend medication changes, or replace professional judgment.
KeenSpire is designed for use by parents and legal guardians on behalf of their children. Children cannot create independent accounts. Parents control Child Profiles and decide what information to provide.
We take measures designed to:
If you believe that a child has provided personal information to us without parental authorization, please contact us at privacy@neurallycare.com.
We use administrative, technical and organizational safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, loss or destruction. These safeguards may include access controls, encryption in transit where appropriate, secure hosting, monitoring, logging, contractual protections and confidentiality obligations for employees and contractors.
No system can be guaranteed to be perfectly secure. Parents and legal guardians are responsible for keeping their login credentials confidential and for notifying us promptly if they believe their account has been compromised.
If we become aware of a privacy or security incident involving personal information, we will investigate and take appropriate steps to contain, mitigate and remediate the incident. Where required by law, we will notify affected individuals and competent regulatory authorities, including the Commission d'accès à l'information du Québec when applicable.
NeurAlly Care is based in Canada. Our service providers may process personal information in Canada, the United States or other jurisdictions. These jurisdictions may have privacy laws that differ from those in your province, state or country.
Where required by law, we use contractual, organizational and technical measures to protect personal information transferred outside its jurisdiction of origin.
We retain personal information only for as long as reasonably necessary to provide the Services, maintain accounts, administer subscriptions or sponsored access, comply with legal obligations, resolve disputes, enforce agreements and protect the security and integrity of the Services.
We may retain account and Child Profile information for a reasonable period after cancellation, expiry or inactivity so that access can be restored if a parent resubscribes or reactivates access, unless deletion is requested earlier and we are not legally required or permitted to retain the information.
Medication information entered by a parent is retained as part of the Child Profile unless deleted by the parent, the account is deleted, or retention is otherwise required or permitted by law.
Aggregated, anonymized or de-identified information may be retained for longer periods because it no longer identifies a parent or child.
Parents and legal guardians may request deletion of their account or their child's personal information by contacting us at privacy@neurallycare.com or through any account deletion mechanism made available in the Services.
Deleting an account may delete or disable access to Child Profiles, progress history, Parent Notes, medication information and other account content, subject to legal retention requirements, security needs and backup deletion cycles.
Depending on your place of residence, you may have the right to:
We may need to verify your identity before responding to a request. Parents and legal guardians may exercise applicable rights on behalf of their child.
If you are located in Quebec, the processing of your personal information is subject to the Act respecting the protection of personal information in the private sector, as amended by Law 25. You may have rights of access, rectification, withdrawal of consent, portability, de-indexation where applicable and information about transfers outside Quebec.
We will notify the Commission d'accès à l'information du Québec and affected individuals of confidentiality incidents presenting a risk of serious injury when required by law.
Where the GDPR, UK GDPR or similar laws apply, we process personal information based on one or more lawful grounds, including consent, performance of a contract, legitimate interests, compliance with legal obligations and protection of vital interests when necessary.
You may have rights of access, rectification, erasure, restriction, portability, objection and withdrawal of consent. You may also have the right to lodge a complaint with your local data protection authority.
For users located in the United States, we take measures designed to support parental notice, consent, access, correction and deletion of children's personal information consistent with applicable children's privacy laws, including COPPA where applicable.
KeenSpire is not intended to collect personal information from children without parental involvement. Parents control Child Profiles and may request access, correction or deletion of their child's personal information.
KeenSpire is not a healthcare provider, health plan, healthcare clearinghouse or medical device. Unless we enter into a separate written agreement expressly stating otherwise, we do not act as a covered entity or business associate under HIPAA.
We may send service-related communications, such as messages about your account, security, subscription, sponsored access, updates, support and functionality. Where permitted by law and based on your preferences, we may also send product news or marketing communications. You may unsubscribe from marketing communications, but you may still receive service communications necessary to provide the Services.
We may update this Privacy Policy from time to time. If we make material changes, we will provide notice by reasonable means, such as in the application, by email or by posting an updated version. Your continued use of the Services after an update means that you accept the updated Policy, subject to your rights under applicable law.
NeurAlly Care has appointed a Privacy Officer responsible for overseeing privacy compliance and responding to privacy-related questions, requests and complaints.
Privacy Officer
Email: privacy@neurallycare.com
NeurAlly Care Inc.
Quebec, Canada
Requests may be submitted in English or French.
