Privacy Policy

Effective date: 10 August 2026
Last updated: 12 October 2026

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1. Introduction and scope

1.1 This Privacy Policy ("Policy") describes how 17967519 Canada Inc., a corporation incorporated under the laws of Canada, having its registered address at 240 Richmond St. W., Toronto, Ontario M5V 1V6, Canada ("Company", "we", "us", "our"), collects, uses, discloses, retains and safeguards Personal Information.

1.2 The Company operates the brands, products and services known as Perimenopause Bestie, the websites located at alja.app and perimenopausebestie.com, and the software application known as ALJA (collectively, the "Services"). Perimenopause Bestie and ALJA are trading names and product names of the Company; they are not separate legal entities.

1.3 The Company is the organization accountable for Personal Information under the Personal Information Protection and Electronic Documents Act (Canada) ("PIPEDA") and applicable provincial privacy legislation. Where the UK GDPR or EU GDPR applies to a particular processing activity, the Company is the "data controller" in respect of that activity.

1.4 This Policy applies to:

(a) the marketing websites at alja.app and perimenopausebestie.com, including the self-assessment quiz, free guide registration, newsletter registration, the contact form, and waitlist registration; and

(b) ALJA, including all information a User records, tracks, saves, generates or submits within the application, and any information a User elects to import into ALJA from a connected health source (section 5.5).

1.5 This Policy forms part of, and is incorporated by reference into, the Terms of Service.

1.6 Age restriction. The Services are intended solely for individuals aged 18 years or older. See section 16.

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2. Definitions

2.1 "Personal Information" means information about an identifiable individual, as that term is defined under PIPEDA and, where applicable, equivalent terms under other applicable privacy legislation.

2.2 "Health-Related Information" means Personal Information concerning an individual's physical or mental health, reproductive or cycle status, symptoms, medications, supplements, health history, or health goals, including information about health that is derived, inferred, generated or classified by the Services from information the User provides. Health-Related Information is treated as sensitive Personal Information for all purposes under this Policy.

2.3 "User", "you" and "your" mean an individual who accesses or uses the Services.

2.4 "Service Provider" means a third party engaged by the Company to process Personal Information on the Company's behalf and under contract.

2.5 "Account" means a registered ALJA user account.

2.6 "Connected Health Source" means a third-party platform, device or application from which a User elects to import health measurements into ALJA, such as Apple Health, Google Health Connect, or a wearable manufacturer's service (for example Oura, Fitbit, WHOOP or Garmin), as made available from time to time.

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3. Accountability and Privacy Officer

3.1 The Company has designated a Privacy Officer who is accountable for the Company's compliance with this Policy and with applicable privacy legislation.

3.2 Enquiries, access requests, correction requests, deletion requests and complaints may be directed to:

Privacy Officer
17967519 Canada Inc.
240 Richmond St. W., Toronto, Ontario M5V 1V6, Canada
hello@alja.app

3.3 The Company remains accountable for Personal Information transferred to a Service Provider for processing, and uses contractual and other means to require a comparable level of protection while the information is being processed by that Service Provider.

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4. Personal Information we collect

4.1 Information provided directly by you.

4.1.1 Where you provide a full name at waitlist registration, it is recorded as separate given and family name fields in the Company's waitlist record and is disclosed to our email service provider as set out in section 8. The waitlist record also keeps the wording you agreed to, the date, and the page you joined from, so that the Company can demonstrate your consent to receive email.

4.1.2 ALJA collects a first name only. No family name is collected, stored or associated with your ALJA health record.

4.2 Information collected automatically. Standard technical and log data, including IP address, browser type, device type, operating system, pages accessed, referring URL, and access timestamps.

4.3 Cookies and similar technologies. As described in section 11.

4.4 Information we do not collect. The Company does not request, and Users should not submit, government identification numbers, complete medical records, or payment card details by email or through any form on the Services. Payment card details, where paid membership is offered, are transmitted directly to our payment processor and are not received, processed or stored on Company systems.

4.5 Product research responses. Our marketing website includes an optional "How fragmented is your health?" tool and short research questions. If you choose to send your answers, you send them by email (or, before 12 October 2026, through the perimenopausebestie.com contact form) together with your email address, so that we can follow up. Responses record only the categories of places you keep health information (for example "a sleep app" or "my memory"), your free-text answers about what health tools you wish existed, and the types of health or wellness subscriptions you pay for. No symptom, cycle or other Health-Related Information is requested, and Users are asked not to include any. Responses are received in the Company's email inbox, are used solely to inform product development and to reply to you, are not sold or shared with advertisers, and are deleted on request to the address in section 18.

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5. Health-Related Information

5.1 From the self-assessment quiz on alja.app and perimenopausebestie.com. The quiz presents questions concerning sleep, menstrual changes, mood, cognition, weight, cardiac sensations, vasomotor symptoms and other physical symptoms.

(a) Individual quiz responses are scored locally within your browser and are neither transmitted to nor stored by the Company.

(b) Where you submitted your email address with your result on perimenopausebestie.com, the Company collects and retains the resulting classification category assigned by the quiz. That classification constitutes Health-Related Information and is disclosed to Service Providers as set out in section 8.

(c) You may view your quiz result without submitting an email address. Submission of an email address is what causes the classification to be retained and disclosed. The quiz on alja.app does not request an email address with your result, and no classification is retained from it.

5.2 From ALJA. Where you create an Account and elect to provide it, the Company collects Health-Related Information which may include: your set-up answers concerning your periods, contraception, hormone therapy, surgery and the symptoms you are noticing; menstrual cycle and bleeding data; symptoms and self-reported severity; sleep; energy; mood; physical activity; nutrition; alcohol consumption; stress; pelvic health; medications, supplements and hormone therapy status; health history; laboratory results you record; appointments; health goals; content entered within guided programs; free-text notes; and the content of your conversations with the Bestie feature.

5.3 Information generated by the Services. The Services analyse information you provide and generate further Health-Related Information about you, including counts and comparisons of what you have logged, observed patterns and co-occurrences, written summaries, and statements extracted from your conversations and stored in your Memory Vault. Each such statement records where it came from (your set-up answers, a conversation, your logged data, or your own edit) and can be viewed, edited and deleted by you. Such derived, inferred and generated information is Health-Related Information and is protected under this Policy on the same basis as information you enter directly. The Services do not generate a diagnosis, a score of your health, or a prediction of menopause.

5.3.1 Safety records. Where text you enter matches one of the Company's safety rules (for example, a description of chest pain or of thoughts of self-harm), the Services show you a message directing you to appropriate care and record the rule that matched, the screen, and the words that matched it. These records exist so that the Company can review whether its safety rules work. They are retained for the life of your Account, are not used for any other purpose, and, because they may contain the words of a person in distress, are not included in the self-serve data export; you may request a copy from the Privacy Officer.

5.4 Voluntary provision. Provision of Health-Related Information is voluntary. You may decline to provide any field. You may review and amend the contents of your Memory Vault, and you may request deletion in accordance with section 13.

5.5 From Connected Health Sources. Where the Company makes a Connected Health Source available and you elect to connect it:

(a) you choose, by category, what ALJA may read — sleep; heart rate and recovery; activity; and, only if you turn it on, weight and temperature. ALJA requests from the source only the permissions those categories require, and does not request any category it cannot explain the use of;

(b) the Company receives and retains the measurements the source supplies (for example sleep duration and timing, resting heart rate, heart-rate variability, breathing rate, steps, workouts, and the source's own scores such as an Oura Readiness score), the source's own record of each measurement, and the identity of the device or application that produced it. Each measurement is stored with its source so that a value you entered yourself is never confused with a value a device recorded;

(c) a value you enter or correct yourself takes precedence over a device value. Nothing is combined across sources without recording which source was used;

(d) the credentials that permit ALJA to read from a source are encrypted with keys held outside the database and are never provided to your browser or to any other party;

(e) you may change the categories, disconnect the source, or delete everything it imported, at any time in Settings. Disconnecting revokes ALJA's access at the source where the source permits it; and

(f) information from a Connected Health Source is Health-Related Information under this Policy, is never sold, shared or used for advertising, and is disclosed to Anthropic only to the extent described in section 9.

A Connected Health Source is not a Service Provider of the Company. Your use of it is governed by its operator's own terms and privacy policy. ALJA is fully functional without one.

5.7 Prohibited uses. The Company does not and will not: sell Health-Related Information; disclose Health-Related Information to advertisers, advertising networks or data brokers; use Health-Related Information for targeted or cross-context behavioural advertising; use Health-Related Information for automated decision-making producing legal or similarly significant effects; or disclose Health-Related Information to insurers or employers.

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6. Purposes of collection, use and disclosure

6.1 The Company collects, uses and discloses Personal Information only for the following identified purposes:

6.2 The Company does not use Personal Information for any purpose materially different from those identified above without first obtaining your consent, save where use or disclosure without consent is permitted or required by law.

6.3 Where the UK GDPR or EU GDPR applies, Health-Related Information constitutes special category data. In such cases the Company relies upon a lawful basis under Article 6 (performance of a contract, or consent, as applicable) and, separately and additionally, upon the condition in Article 9(2)(a) (explicit consent). This subsection applies only to the extent that the UK GDPR or EU GDPR applies to you.

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7. Consent and withdrawal of consent

7.1 Consent to processing of Health-Related Information. You consent to the Company's collection and use of Health-Related Information by creating an Account and electing to enter Health-Related Information into ALJA, having been informed by this Policy of the nature of that information, the purposes for which it is used, and the Service Providers to which it is disclosed. That consent is specific to the purposes identified in section 6.1 and does not extend to any other purpose.

7.2 Marketing consent is separate. Consent to receive marketing communications is sought and given separately from consent under section 7.1. Withdrawal of one does not withdraw the other.

7.3 Withdrawal of consent. You may withdraw consent at any time by written notice to the Privacy Officer, subject to legal and contractual restrictions and reasonable notice.

7.4 Consequences of withdrawal. Withdrawal of consent under section 7.1 will cause the Company to cease processing in reliance on that consent. As a consequence, Services features dependent upon Health-Related Information — including tracking, pattern detection, summaries, plans, and the memory functions of the Bestie feature — will cease to be available to you.

7.5 Withdrawal is not deletion. Withdrawal of consent does not, of itself, effect deletion of previously collected Health-Related Information. Where you require deletion, you must request it, and the Company will act in accordance with section 12 and section 13.

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8. Service Providers and other disclosures

8.1 The Company engages the following Service Providers, each of which processes Personal Information on the Company's behalf, under contract, and solely for the purposes the Company specifies. As at the effective date of this Policy:

8.2 ALJA Health-Related Information is not disclosed to Klaviyo, to Shopify, or to any advertising, marketing or analytics system. Health-Related Information recorded within ALJA resides with Supabase and is disclosed to Anthropic only as described in section 9.

8.2.1 First-party usage records. ALJA records, in the Company's own database, the names of features you use and the screens on which you use them (for example "check-in completed", "pattern receipt opened"). These records contain no symptom, cycle, measurement, note or other health value, are never sent to a third party, and are used solely to understand which parts of the Service are used. They are included in your data export.

8.3 Other permitted disclosures. The Company may disclose Personal Information: (a) where required or permitted by applicable law, including in response to a court order, subpoena, or lawful demand of a governmental or regulatory authority; (b) where necessary to protect the rights, property or safety of any person; (c) to professional advisors under obligations of confidentiality; and (d) in connection with a merger, acquisition, financing or sale of assets, in which case this Policy will continue to apply to the transferred information until affected individuals are notified of any change.

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9. Artificial intelligence processing

9.1 Certain features of ALJA are delivered using the commercial application programming interface of Anthropic PBC ("Anthropic").

9.2 Information disclosed to Anthropic when you use the Bestie feature. Each request transmits: your first name; your approximate age; your own description of your periods and of anything affecting your cycle (contraception, hormone therapy, surgery); date of last menstrual period; symptoms you have identified as most burdensome; what you said you want from ALJA and how much you chose to track; the statements held in your Memory Vault, each marked with its source; approximately the preceding fourteen days of daily log entries, including any free-text notes recorded on those days and, where you have connected a health source, the sleep values it supplied; recent food, sleep and training entries; your most burdensome symptoms and their average severity over the preceding thirty days; the items on your current plan; patterns previously surfaced to you; and the recent messages within the conversation then in progress. Where a safety rule has matched your message, the safety message shown to you is also transmitted, with an instruction that it not be softened.

9.3 Scheduled processing. The Company operates a scheduled daily process which transmits conversation content from the preceding two days to Anthropic for the purpose of extracting durable statements into your Memory Vault. Extracted statements are written in the second person, record their source, and may not record a diagnosis, condition or medication that you did not state in your own words. This process operates solely upon conversation content. Where you do not use the Bestie feature, no information is transmitted by this process.

9.3.1 No other AI processing. Patterns, counts, comparisons and summaries shown in ALJA outside the Bestie feature are computed by the Company's own software from your records and are not transmitted to Anthropic or any other AI provider.

9.4 Extent of disclosure. The disclosure described in section 9.2 constitutes a substantial and recurring disclosure of Health-Related Information, and the Company states this expressly rather than characterising it as limited. The disclosure is necessary to the functionality you request, which is a companion feature that retains and applies your history.

9.5 Identifiers. Your email address and Account identifier are not transmitted to Anthropic. The only direct identifier transmitted is your first name, where you have provided one.

9.6 Anthropic's handling. Anthropic's commercial and application programming interface products do not use inputs or outputs to train Anthropic's models by default. This is not equivalent to non-retention. Anthropic may retain application programming interface data in accordance with the retention terms and configuration applicable to the Company's account. The Company makes no representation that a zero-data-retention arrangement is in effect.

9.7 Optional nature. The Bestie feature is optional. Tracking, the health record, plans, the library and guided programs remain available without it. Where you do not wish Health-Related Information to be disclosed to Anthropic, you should not use the Bestie feature.

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10. Transfers outside Canada

10.1 Service Providers engaged by the Company process Personal Information outside Canada, including in the United States and other jurisdictions.

10.2 While Personal Information is in a foreign jurisdiction, it is subject to the laws of that jurisdiction and may be accessible to the courts, law enforcement agencies, and national security authorities of that jurisdiction.

10.3 The Company remains accountable for Personal Information transferred to a Service Provider for processing and uses contractual and other means to require a comparable level of protection, as required under PIPEDA. Where a transfer is subject to the UK GDPR or EU GDPR, the Company relies upon the transfer mechanisms recognized under that legislation.

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11. Cookies and tracking technologies

11.1 perimenopausebestie.com. The e-commerce platform on which the website operates sets cookies. Certain of these are strictly necessary for site function, security and cart operation. Others are the platform's own visitor and session analytics cookies, which distinguish individual visitors from one another and are accordingly not anonymous. Typefaces are served from the website's own content delivery network; no request is made to any third-party font service.

11.1.1 alja.app. The marketing pages of alja.app set no cookies and load no analytics package, session recording technology, advertising pixel or third-party tracker. Typefaces and images are served from alja.app itself.

11.2 ALJA. Within the authenticated application, the Company uses only those cookies necessary to maintain your authenticated session and its security. No analytics package, session recording technology, advertising pixel or third-party tracker is deployed on any page of ALJA. Usage is measured only by the first-party records described in section 8.2.1.

11.3 The Company does not deploy advertising or cross-context behavioural advertising cookies on any part of the Services.

11.4 You may block or delete cookies through your browser settings. Blocking strictly necessary cookies will prevent authentication from functioning.

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12. Retention

12.1 Marketing contacts. Retained until you unsubscribe, and for a limited period thereafter as required to give effect to and evidence the unsubscribe request.

12.2 Accounts and Health-Related Information. Retained for so long as the Account remains open. The retention of history is a core function of the Services. Statements you delete from your Memory Vault are archived, cease to be used immediately, and are removed with the Account. Data imported from a Connected Health Source, including the source's own records, is retained until you delete it in Settings or the Account is deleted. Records of AI usage (token counts and cost, containing no content) are retained for operational purposes and pruned periodically.

12.3 Deleted Accounts. You may delete your Account yourself in ALJA Settings by typing DELETE to confirm, or by request to the Privacy Officer. Upon confirmation, any active paid Subscription is cancelled and the Account and every record associated with it — including Health-Related Information, conversations, Memory Vault statements, Connected Health Source data and credentials, safety records and usage records — is removed from the production database immediately and permanently. Copies may persist for a further period within encrypted backups and within Service Provider systems until overwritten in the ordinary course of those systems' operation. The Company does not presently state a guaranteed outer limit for backup expiry and will not do so until that limit can be verified.

12.4 Records required by law. Retained for the period prescribed by the applicable legal, regulatory or tax obligation.

12.5 Personal Information that is no longer required for an identified purpose and is not subject to a legal retention obligation is deleted, destroyed or anonymized.

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13. Individual rights

13.1 Subject to applicable law and to verification of identity, the Company makes the following available to you:

(a) Access — a copy of the Personal Information the Company holds about you, and an account of its use and disclosure;
(b) Correction — amendment of inaccurate or incomplete Personal Information;
(c) Deletion — erasure of your Account and associated record;
(d) Portability — receipt of your data in a structured, commonly used, machine-readable format. ALJA provides this as a self-serve download in Settings ("Download my data"), covering every record held about you other than the safety records described in section 5.3.1, which are available on request;
(e) Objection and restriction — objection to, or restriction of, specified processing;
(f) Withdrawal of consent — in accordance with section 7; and
(g) Unsubscribe — from marketing communications, by the mechanism provided in each such communication.

13.2 Jurisdiction-specific rights. Depending upon your place of residence, you may hold additional statutory rights, including under PIPEDA and provincial privacy legislation in Canada; under United States federal and state privacy and consumer health data legislation, including in California; and under the UK GDPR or EU GDPR where applicable to you. Those rights apply in addition to the entitlements in section 13.1. The Company does not "sell" or "share" Personal Information as those terms are defined under California law, and will not discriminate against any individual for exercising a privacy right.

13.3 Exercising a right. Requests should be directed to the Privacy Officer at hello@alja.app. The Company will respond within thirty (30) days, or within such other period as applicable law prescribes. The Company may require verification of identity before acting upon a deletion, access or portability request.

13.4 Complaints. Complaints should first be directed to the Privacy Officer. You additionally have the right to lodge a complaint with the Office of the Privacy Commissioner of Canada or your provincial commissioner; with your state attorney general, where applicable; or with the Information Commissioner's Office or your national supervisory authority, where the UK GDPR or EU GDPR applies.

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14. Safeguards

14.1 The Company maintains physical, organizational and technological safeguards appropriate to the sensitivity of the Personal Information it holds, including:

(a) encryption of Personal Information in transit;
(b) encryption at rest, as provided by the Company's infrastructure providers;
(c) database authorization policies restricting each authenticated session to records associated with that session's own account;
(d) authentication by password or by emailed sign-in link. Passwords are held by the Company's authentication provider only as salted hashes and are never stored or readable in plain text;
(d.1) encryption of Connected Health Source credentials at the application layer, with the key held outside the database;
(d.2) rate limiting on the interfaces that write and export your data and that call AI processing;
(e) restriction of administrative access to personnel requiring it; and
(f) engagement of established infrastructure providers.

14.2 No method of transmission or storage is entirely secure, and the Company does not warrant absolute security.

14.3 Breach notification. In the event of a breach of security safeguards involving Personal Information under the Company's control, the Company will assess the real risk of significant harm and will notify affected individuals and the relevant regulator where required by applicable law, and will maintain records of breaches as PIPEDA requires.

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15. Marketing communications

15.1 Commercial electronic messages are sent only in accordance with Canada's Anti-Spam Legislation ("CASL") and other applicable law.

15.2 Each commercial electronic message identifies the Company, provides contact information, and contains an unsubscribe mechanism that remains functional for no less than sixty (60) days.

15.3 Unsubscribe requests are given effect without delay and in any event within ten (10) business days of receipt.

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16. Age restriction

16.1 The Services are intended solely for individuals aged 18 years or older. You may not create an Account, nor submit Health-Related Information, unless you are 18 years of age or older.

16.2 The Company does not knowingly collect Personal Information from individuals under 18 years of age. Where the Company becomes aware that it has collected such information, it will delete it.

16.3 Where you believe an individual under 18 has provided Personal Information to the Company, notify the Privacy Officer and the Company will effect deletion.

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17. Amendments

17.1 The Company may amend this Policy from time to time. The "Last updated" date will be revised accordingly.

17.2 Where an amendment is material — in particular an amendment to the use or disclosure of Health-Related Information — the Company will notify registered Users by email.

17.3 Where a new use or disclosure of Health-Related Information requires consent, the Company will obtain that consent before the new processing commences. Continued use of the Services will not be treated as consent to a new use or disclosure of Health-Related Information.

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18. Contact

Privacy Officer
17967519 Canada Inc.
240 Richmond St. W.
Toronto, Ontario M5V 1V6
Canada
hello@alja.app

Enquiries are answered by a person, ordinarily within ten (10) business days. Requests to exercise rights under section 13 are handled within the periods stated there.

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The Services provide educational information and self-management tools. They do not provide medical advice. See the Terms of Service.