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Privacy Policy

Last updated: March 29, 2026

SmallWins ("SmallWins", "we", "us", or "our") operates the SmallWins mobile application (the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Service, and describes your privacy rights.

SmallWins Health Inc. is the data controller responsible for your Personal Data.

If you have any questions about this Privacy Policy, please contact us at parth@smallwins.health.

Interpretation and Definitions

Interpretation

Words with capitalized first letters have meanings defined below. These definitions apply whether the terms appear in singular or plural.

Definitions

Account
A unique account created for you to access the Service.
Application
The SmallWins mobile application.
Company
SmallWins Health Inc., 25 Telegram Mews, Unit 4808, Toronto, ON M5V 3Z1, Canada
Device
Any device capable of accessing the Service, such as a smartphone, tablet, or computer.
Personal Data
Information that identifies or can reasonably be used to identify an individual.
Service
The SmallWins mobile application and related services.
Service Providers
Third-party companies or individuals that process data on behalf of SmallWins in order to operate or support the Service (for example cloud infrastructure providers).
Usage Data
Data collected automatically when using the Service.
You
The individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

When you create an account or use the Service, we may collect the following information:

  • Email address
  • First and last name
  • Account information

Health Data (Apple Health / HealthKit)

With your explicit permission, the SmallWins app may access certain health and activity data from Apple Health (HealthKit), including metrics such as:

  • Activity data (e.g., steps, stand hours)
  • Heart-related metrics (e.g., resting heart rate, HRV)
  • Sleep data
  • Other wellness metrics available through Apple Health

This data is used solely to:

  • analyze trends in your health and activity
  • generate personalized insights
  • help you build healthier daily habits

Important commitments regarding HealthKit data:

  • Health data is used only to provide insights to you within the app
  • Health data is never sold
  • Health data is never used for advertising
  • Health data is not shared with third parties for marketing or data mining

You can revoke HealthKit permissions at any time through your device settings.

Health data access is entirely optional and requires your explicit permission through Apple's permission system.

Usage Data

Usage Data may be collected automatically when you use the Service and may include:

  • device type
  • operating system
  • application usage statistics
  • diagnostic and crash information
  • IP address and related technical information for security monitoring

This information helps us maintain and improve the reliability of the Service.

How We Use Your Data

We may use your Personal Data for the following purposes:

To provide and maintain the Service: Including generating insights and maintaining your account.

To analyze and improve the Service: Usage data helps us understand feature usage and improve product quality.

To provide customer support: To respond to questions, support requests, or troubleshooting issues.

To maintain security and prevent misuse: Including monitoring for abuse, fraud, or unauthorized access.

To comply with legal obligations: Where required by law or regulatory authorities.

We do not sell your Personal Data.

Sharing of Personal Data

We may share Personal Data only in limited circumstances:

With Service Providers: We may use trusted infrastructure providers (such as cloud hosting providers) to operate and maintain the Service. These providers process data only as necessary to provide their services.

Business Transfers: If SmallWins undergoes a merger, acquisition, or asset sale, Personal Data may be transferred as part of that transaction.

Legal Requirements: We may disclose Personal Data when required to comply with applicable law or valid legal requests from authorities.

We do not share your health data with advertisers or marketing partners.

Data Retention

We retain Personal Data only for as long as necessary to provide the Service and fulfill legal obligations.

Typical retention periods include:

Account Information

User accounts are retained for the duration of your account and up to 24 months after account closure to resolve disputes or support issues, unless you request deletion earlier.

Customer Support Data

Support communications may be retained for up to 24 months to track service quality and respond to follow-up requests.

Usage Data

Application usage statistics and server logs may be retained for up to 24 months for security monitoring and service improvements.

Where possible, we may anonymize or aggregate data so that it can no longer be linked to an individual.

Data Security

We take the protection of your Personal Data seriously.

SmallWins implements industry-standard security measures and follows industry best practices to safeguard your data, including:

  • secure encrypted communication (HTTPS)
  • restricted system access
  • secure cloud infrastructure
  • monitoring for unauthorized access

While we strive to protect your data using commercially reasonable measures, no method of transmission or storage can be guaranteed to be completely secure.

Data Transfers

Your information may be processed and stored on servers located in jurisdictions outside of your province or country.

When data is transferred internationally, we ensure appropriate safeguards are in place to protect your information consistent with applicable privacy laws.

Your Privacy Rights

You have the right to:

  • access your Personal Data
  • correct inaccurate data
  • request deletion of your data
  • withdraw consent to health data access

You may revoke Apple Health permissions directly through your device settings.

Account and Data Deletion

You may request permanent deletion of your account and associated health data at any time through the deletion option available within the app.

Once you submit a deletion request:

  • your account will be permanently deleted
  • associated Personal Data and health data will be removed from our systems
  • any remaining backup copies will be deleted according to our backup retention schedule, unless retention is required by law

If you have questions or need assistance related to deletion, you may also contact: parth@smallwins.health

Children's Privacy

The Service is not intended for individuals under the age of 16. We do not knowingly collect Personal Data from individuals under 16.

If we become aware that such data has been collected without parental consent, we will take steps to remove it promptly.

Website Analytics and Cookies

Our website (smallwins.health) uses Google Analytics, a web analytics service provided by Google LLC, to help us understand how visitors interact with the site.

Google Analytics uses cookies — small text files stored on your device — to collect information such as:

  • Pages visited and time spent on each page
  • Referring website or source
  • Browser type and device information
  • Approximate geographic location (based on IP address)

This data is collected in aggregate and does not personally identify you. It is used solely to improve our website experience.

You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on, or by adjusting your browser's cookie settings.

For more information on how Google processes this data, see Google's Privacy Policy.

Third-Party Links

The Service may contain links to third-party websites. We are not responsible for the privacy practices of those external sites.

We recommend reviewing the privacy policies of any third-party services you visit.

Medical Disclaimer

SmallWins provides informational insights based on health data. The Service does not provide medical advice, diagnosis, or treatment.

You should consult a qualified healthcare professional before making medical decisions based on information provided by the Service.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If changes are made, the updated policy will be posted within the Service and the "Last updated" date will be revised.

We encourage you to review this Privacy Policy periodically.

Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, you can contact us at: parth@smallwins.health

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