Privacy Policy

1. Who This Notice Applies To

This Privacy Notice applies to all individuals who interact with the Xtralp platform, including:

• Members — individuals who use the platform to find and book companion care and lifestyle support services for themselves
• Care Circle Members — family members or trusted persons who join a Care Circle to coordinate care on behalf of a Member
• Paid Companions — independent contractors who offer non-medical support services in exchange for compensation
• Volunteer Companions — individuals who offer non-compensated social companionship and lifestyle assistance voluntarily
• Administrators — individuals who manage the platform on behalf of Xtralp

All Companions — whether paid or volunteer — are subject to the same background screening, privacy obligations, and data handling practices described in this Policy.

2. Information We Collect

2.1 Information You Provide Directly

When you create an account or use our services, we collect:

• Identity information: full name, date of birth, and profile photo
• Contact information: email address, phone number, home address, and postal code
• Account credentials: username and encrypted password
• Role selection: Member, Paid Companion, Volunteer Companion, or Care Circle Member
• Care recipient profiles: service preferences, care notes, and support needs
• Companion information: professional background, qualifications, service offerings, availability, and rates
• Government-issued ID photos (front and back) — for all Companion identity verification
• Billing information: payment method details processed securely by Stripe — we do not store full card numbers
• Messages: communications exchanged through our in-app messaging system
• Ratings and reviews submitted following completed bookings

2.2 Information We Do NOT Collect

2.3 Information Collected Automatically

When you use our platform, we automatically collect: device and browser information, log data including IP address and access times, usage patterns, approximate location data (derived from IP address) to match you with local helpers, and app performance data.

2.4 Information From Third Parties

We may receive information from Stripe (payment processing and payout identity verification), our approved background check partner (check completion status and consent confirmation), authentication providers (if you sign in via a third-party login), and other Care Circle members.

3. How We Use Your Information

We use your personal information for:

• Service delivery: enabling booking, scheduling, and management of services between Members and Companions
• Care Circle coordination: allowing authorized family members to manage appointments and messaging on behalf of a Member
• Provider matching: connecting Members with qualified local companions based on needs, availability, and location
• Billing and payments: processing payments, managing invoices, and facilitating earnings via Stripe
• Identity and background verification: initiating background check screening for all Companion onboarding
• Communication: appointment confirmations, booking updates, in-app messages, and important notices
• Marketing communications: optional promotional emails (you may opt out at any time)
• Platform improvement: analyzing usage, troubleshooting issues, and enhancing platform safety
• Safety and compliance: detecting and preventing fraud, enforcing Terms of Service, and complying with Florida mandatory reporting requirements under Chapter 415, Florida Statutes

4. Legal Bases for Processing

We process your personal data based on: contract performance (delivering services you requested), legitimate interests (improving the platform, preventing fraud, ensuring safety), legal obligation (complying with Florida and federal laws), and consent (where explicitly given, such as for marketing or background check authorization — you may withdraw consent at any time).

5. How We Share Your Information

We do not sell your personal information. We share information only in the following circumstances:

5.1 Within the Platform

Companions can see the service details and care needs of Members they are booked to assist. Care Circle members can view appointment details and booking history within permissions granted by the primary account holder. Administrators have access to platform-wide data to manage operations and ensure compliance.

5.2 With Third-Party Service Providers

We share data with trusted vendors including Stripe (payment processing), our approved background check partner (screening upon consent), cloud hosting providers, and analytics tools. All vendors are contractually required to protect your data.

5.3 Legal Requirements and Mandatory Reporting

We may disclose information if required by law or if we believe in good faith that disclosure is necessary to protect safety or prevent fraud. This includes mandatory reporting under Chapter 415, Florida Statutes, where there is reasonable cause to suspect abuse, neglect, or exploitation of a vulnerable adult. Florida Abuse Hotline: 1-800-962-2873.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred. We will notify you before your data becomes subject to a different privacy policy.

6. Sensitive Information About Care Recipients

We apply heightened protections to care recipient information. Access is strictly limited to those directly involved in care delivery. We do not use care recipient information for advertising or share it with third parties beyond what is strictly necessary. Companions are bound by confidentiality obligations in their provider agreements.

7. Data Retention

We retain your personal information for as long as your account is active or as needed to provide services and comply with legal obligations. When you close your account, we will delete or anonymize your personal data within 30 days, except where retention is required by law. Government-issued ID documents are not retained beyond the period necessary to complete verification.

8. Data Security

We implement appropriate technical and organizational measures to protect your information, including encrypted data transmission (TLS/HTTPS), access controls, secure cloud infrastructure, and third-party processing (Stripe and our background check partner) to keep the most sensitive data off our platform entirely. In the event of a data breach affecting your rights, we will notify you as required by the Florida Information Protection Act (Fla. Stat. § 501.171).

9. Your Rights and Choices

Depending on your jurisdiction, you may have the right to:

• Access: request a copy of the personal information we hold about you
• Correction: request correction of inaccurate or incomplete information
• Deletion: request deletion of your personal information (subject to legal retention requirements)
• Portability: request a structured, machine-readable copy of your data
• Objection: object to certain types of processing, such as direct marketing
• Withdraw consent: withdraw consent at any time without affecting prior lawful processing
• Opt-out of marketing: unsubscribe from promotional emails at any time

To exercise any of these rights, contact us at privacy@xtralp.com. We will respond within 30 days.

10. Florida and Federal Privacy Compliance

• Fair Credit Reporting Act (FCRA): Background checks are performed by FCRA-compliant partners. Companions have the right to receive a copy of their consumer report and dispute inaccurate information.
• Florida Information Protection Act (FIPA — Fla. Stat. § 501.171): We comply with Florida's data breach notification law.
• Florida Adult Protective Services Act (Chapter 415, Fla. Stat.): As a platform serving vulnerable adults, Xtralp and its Companions are subject to mandatory reporting requirements. Florida Abuse Hotline: 1-800-962-2873.
• COPPA: Our Platform is not directed to children under 13. We do not knowingly collect personal information from children.

11. Children's Privacy

Xtralp is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal information, contact us at privacy@xtralp.com.

12. International Data Transfers

Our platform may be accessed and data may be processed in countries other than your country of residence. We take steps to ensure appropriate safeguards are in place for any such transfers in accordance with applicable privacy law.

13. Third-Party Links

The Platform may contain links to third-party websites or services. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party services you interact with.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make significant changes, we will notify you by posting the updated policy and, where appropriate, sending an email or in-app notification. Your continued use of Xtralp after the effective date constitutes acceptance of the revised Privacy Policy.

15. Contact Us

If you have questions or requests regarding this Privacy Policy, contact us at: