Privacy Policy

1. Introduction

This Privacy Policy explains how QSWP Consulting LLC, doing business through LyvvOut Connect (“LyvvOut Connect,” “QSWP,” “we,” “us,” or “our”), collects, uses, discloses, retains, and protects information associated with the LyvvOut Connect service.

LyvvOut Connect is separate from LyvvOut.

LyvvOut Connect is a business-to-business resident engagement and AI companion-call platform designed for senior living communities and organizations. This Privacy Policy applies specifically to LyvvOut Connect and should not be interpreted as the privacy policy governing the separate consumer-facing LyvvOut service.

2. Scope

This Policy applies to information collected through:

• The LyvvOut Connect website;
• Resident enrollment and onboarding;
• Inbound LyvvOut Connect calls;
• Scheduled outbound LyvvOut Connect calls;
• Call recordings and transcripts;
• Resident profiles and personalization features;
• Surveys;
• Community administrative tools and dashboards;
• Safety and support features;
• Demo requests and contact forms;
• Communications with LyvvOut Connect; and
• Related LyvvOut Connect services.

3. Our Relationship With Participating Communities

Senior living communities contract with QSWP Consulting LLC to make LyvvOut Connect available to their residents.

Depending on the circumstances, information may be provided directly by a resident, by an authorized representative, or by the participating community.

Certain privacy obligations may therefore be allocated between QSWP Consulting LLC and the participating organization under applicable law and the parties' written agreement.

Residents may contact their community or LyvvOut Connect with questions regarding information associated with their participation.

4. Information We Collect

A. Resident Profile Information

We may collect information such as:

• Name and preferred name;
• Telephone number;
• Preferred language;
• Preferred voice option;
• Calling preferences;
• Preferred call schedule;
• Interests and hobbies;
• Conversation preferences;
• Important people, relationships, or events voluntarily shared for personalization;
• Other information provided by the resident or participating community.

B. Conversation Information

When a resident uses LyvvOut Connect, we may process:

• Audio recordings;
• Conversation transcripts;
• Statements made during calls;
• Topics discussed;
• Conversation summaries;
• Information used for conversational continuity;
• Resident preferences learned through conversations;
• Call date, time, duration, and status;
• Survey responses;
• Other information voluntarily communicated during the call.

Residents should understand that conversations may contain personal or sensitive information depending on what they choose to discuss.

C. Safety and Well-Being Information

LyvvOut Connect may process resident-reported information that could indicate a potential safety or well-being concern.

Examples may include statements concerning:

• A fall;
• Confusion or disorientation;
• A medication concern;
• Physical discomfort or illness;
• Emotional distress;
• An unsafe situation;
• A request for assistance; or
• Other information suggesting that staff attention may be appropriate.

This information may be used to generate an alert or notification for authorized community personnel.

LyvvOut Connect does not independently verify resident statements and is not a medical-monitoring or emergency-response service.

D. Community and Staff Information

We may collect:

• Staff names;
• Professional titles;
• Work email addresses;
• Business telephone numbers;
• Community name and location;
• Facility type;
• Administrator credentials;
• Designated escalation contacts;
• Service configuration information;
• Account activity.

E. Website and Technical Information

When someone visits the LyvvOut Connect website or uses online administrative features, we may automatically receive information such as:

• IP address;
• Browser type;
• Device type;
• Operating system;
• Pages viewed;
• Approximate location derived from technical information;
• Date and time of access;
• Referral information;
• Cookies and similar technologies where used;
• Security and diagnostic logs.

F. Demo and Business Inquiry Information

When someone requests a demonstration or contacts us, we may collect information including:

• Name and title;
• Organization;
• Work email address;
• Telephone number;
• Facility type;
• Number of residents;
• Message or inquiry details;
• Scheduling information.

5. Call Recording and Transcription

LyvvOut Connect calls may be recorded and transcribed.

Where required, residents receive notice concerning recording and/or transcription.

Recordings and transcripts may be used to:

• Provide the companion-conversation service;
• Maintain conversational continuity;
• Remember resident preferences and meaningful details;
• Generate summaries and authorized community insights;
• Detect resident-reported concerns;
• Generate safety notifications;
• Maintain service quality;
• Investigate technical problems;
• Protect platform security;
• Meet legal or contractual requirements.

We recognize that voice recordings and transcripts can contain highly personal information and therefore require appropriate safeguards.

6. Artificial Intelligence Processing

LyvvOut Connect uses artificial intelligence and automated technologies to provide conversations and certain platform functions.

Information may be processed to:

• Understand resident speech;
• Generate conversational responses;
• Convert speech to text;
• Generate voice responses;
• Maintain conversational context;
• Personalize future conversations;
• Generate summaries;
• Identify topics or engagement patterns;
• Detect statements that may warrant staff attention;
• Support surveys and service features.

AI-generated results may be inaccurate and should not be treated as medical or professional conclusions.

7. How We Use Personal Information

We may use information to:

• Provide LyvvOut Connect;
• Personalize resident conversations;
• Maintain continuity between calls;
• Place authorized scheduled calls;
• Process resident-initiated calls;
• Generate authorized summaries and insights;
• Identify resident-reported concerns;
• Notify designated community personnel when appropriate;
• Administer resident profiles;
• Operate community dashboards;
• Provide customer support;
• Troubleshoot technical issues;
• Maintain platform security;
• Prevent fraud or misuse;
• Improve service reliability and functionality;
• Communicate with participating organizations;
• Comply with contractual obligations;
• Comply with applicable law.

We will not represent that information is being used only for one purpose while secretly using it for a materially different purpose.

8. AI Training and Product Improvement

LyvvOut Connect will handle conversation information according to its disclosed purposes, contractual commitments, and applicable law.

Resident conversations will not be sold to data brokers or advertisers.

We will not use identifiable resident conversations to train unrelated commercial AI models unless we have a lawful basis and provide any notice or obtain any consent required by applicable law and our contractual commitments.

We may use appropriately deidentified or aggregated information to understand service performance, improve reliability, evaluate features, and develop the LyvvOut Connect service where permitted by law and contract.

9. How We Disclose Information

We may disclose information to the following categories of recipients when reasonably necessary.

Participating Senior Living Communities

Authorized community personnel may receive information such as:

• Resident participation information;
• Call activity;
• Conversation summaries;
• Engagement information;
• Survey responses;
• Resident-reported concerns;
• Safety alerts;
• Other information made available through the community's authorized service configuration.

Service Providers

We may use service providers that support:

• Telecommunications;
• Voice processing;
• Artificial intelligence;
• Speech recognition and transcription;
• Cloud hosting;
• Databases;
• Communications;
• Security;
• Analytics;
• Scheduling;
• Customer support.

Service providers receive information only as necessary to perform services for LyvvOut Connect and are subject to applicable contractual obligations.

Legal and Safety Disclosures

We may disclose information when reasonably necessary to:

• Comply with law, regulation, subpoena, court order, or legal process;
• Protect the rights or security of LyvvOut Connect, QSWP Consulting LLC, residents, participating communities, or others;
• Investigate fraud or misuse;
• Respond to an immediate safety concern when disclosure is legally permitted or required.

Business Transactions

Information may be transferred as part of a merger, acquisition, financing, restructuring, sale of assets, or similar business transaction, subject to applicable law and appropriate protections.

10. We Do Not Sell Resident Personal Information

LyvvOut Connect does not sell resident personal information to advertisers or data brokers.

We do not sell resident conversation recordings or transcripts for advertising purposes.

We do not use resident conversations for targeted advertising.

If these practices ever materially change, this Privacy Policy will be updated and any notice or consent required by applicable law will be provided before the new practice begins.

11. Sensitive Information

Because residents may choose to discuss personal matters, LyvvOut Connect may process information that could be considered sensitive under applicable law.

We limit sensitive information to uses reasonably necessary to provide, secure, administer, and support LyvvOut Connect or as otherwise authorized by law and applicable consent.

Residents are not required to disclose information unrelated to their use of the service.

12. Health-Related Information and HIPAA

LyvvOut Connect may receive information concerning a resident's health or well-being during a conversation.

However, the presence of health-related information does not by itself mean that every piece of information processed through LyvvOut Connect constitutes Protected Health Information under the Health Insurance Portability and Accountability Act (“HIPAA”).

Where QSWP Consulting LLC is required to act as a Business Associate of a participating covered entity under HIPAA, applicable Protected Health Information will be handled in accordance with the parties' Business Associate Agreement and applicable HIPAA requirements.

Nothing in this Privacy Policy is intended to reduce protections required by HIPAA or another applicable privacy law.

13. Data Retention

We retain information for only as long as reasonably necessary for the purposes for which it was collected, including providing the service, maintaining conversational continuity, fulfilling contractual obligations, maintaining security, resolving disputes, and complying with legal requirements.

Different categories of information may have different retention periods.

Where a participating organization's agreement establishes a specific retention or deletion requirement, we will handle information in accordance with that agreement and applicable law.

When information is no longer reasonably required, we may delete, deidentify, or aggregate it as appropriate.

14. Data Security

We maintain reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, or misuse.

Safeguards may include access controls, authentication, encryption where appropriate, restricted administrative access, logging, security monitoring, vendor controls, and other measures appropriate to the nature of the information.

No electronic system can be guaranteed to be completely secure, and we cannot promise absolute security.

15. Privacy Rights

Depending on where an individual resides and which laws apply, the individual may have rights concerning personal information, including rights to:

• Confirm whether personal information is being processed;
• Access certain personal information;
• Correct inaccurate information;
• Request deletion;
• Obtain a portable copy of certain information;
• Withdraw consent where processing relies on consent;
• Opt out of certain processing where applicable;
• Appeal certain privacy-request decisions; and
• Exercise other rights provided by applicable law.

Texas law, for example, provides qualifying consumers with rights involving access, correction, deletion, portability, and certain opt-outs, subject to statutory exceptions.

We will not unlawfully discriminate against an individual for exercising an applicable privacy right.

16. Privacy Requests

Privacy requests may be submitted through LyvvOut Connect's designated privacy contact method.

We may need to verify the requester's identity before fulfilling a request.

Where information is controlled by a participating senior living organization and QSWP Consulting LLC processes the information on that organization's behalf, we may refer the request to or coordinate with the participating organization.

Requests will be handled within the timeframe required by applicable law.

17. Outbound Call Consent and Preferences

Scheduled outbound LyvvOut Connect calls are made only through authorized service arrangements.

Because AI-generated voices are treated as artificial or prerecorded voices under federal telecommunications law, appropriate consent must be obtained when required before covered outbound calls are initiated.

Residents may request that future scheduled calls stop.

Withdrawal from scheduled outbound calls does not prevent a resident from using available inbound calling features unless the resident or community separately ends participation in the service.

18. Cookies and Website Technologies

The LyvvOut Connect website may use cookies or similar technologies necessary for website functionality, security, analytics, and user experience.

Where legally required, users will be provided appropriate choices concerning non-essential cookies.

19. Children's Privacy

LyvvOut Connect is designed for senior living communities and is not directed toward children.

We do not knowingly offer LyvvOut Connect to children under 13 or knowingly collect children's personal information through the service as an intended part of its operation.

20. Third-Party Links

The LyvvOut Connect website may contain links to third-party websites or services.

Their privacy practices are governed by their own policies. QSWP Consulting LLC is not responsible for the privacy practices of unrelated third parties.

21. Changes to This Privacy Policy

We may update this Privacy Policy as LyvvOut Connect evolves or as legal, technical, or operational requirements change.

The current version will display its effective date and last-updated date.

If we make a material change requiring additional notice or consent, we will provide that notice or obtain consent as required by applicable law.

22. Contact Us

Questions, concerns, or privacy requests concerning LyvvOut Connect may be directed to: