Privacy Policy

Effective Date: August 2026

Version 1.0 · Registered Operating Base: Singapore

About This Policy

This Privacy Policy explains how ELODI Online Therapy and Learning Center collects, uses, stores, and protects your personal information when you use our website, mobile application, and related services. Please read this carefully before using the platform. By accessing or using ELODI, you confirm that you have read and agree to this policy.

1. Who We Are

ELODI Online Therapy and Learning Center (referred to in this document as "ELODI," "we," "us," or "our") is a digital telehealth and educational platform that delivers Speech Therapy, Occupational Therapy (OT), SPED and Academic Tutorials, Caregiver Coaching, and subscription-based educational resources.

Operating base: Singapore
Services: Available to Philippines-based and International customers
Contact: info@elodi.com

2. What Personal Data We Collect

2.1 Information You Provide Directly

Full name, date of birth, and contact details (email, phone number)
Location or country of residence
Parent or guardian name and contact details (for minor clients)
Medical, developmental, or educational history provided through intake forms
Diagnosis information, therapist referrals, and school records shared voluntarily
Session-related notes, goals, and progress information
Payment details processed through our payment provider (HitPay)
Communications with our team
Consent forms, service agreements, and signed authorizations

2.2 Information Collected Automatically

IP address and general location data
Device type, browser, and operating system
Pages visited, features used, and session duration on our platform
Booking activity, session attendance, and package usage
Subscription status and content access history
Analytics data collected through Vercel Analytics

2.3 Information From Live Sessions

Session recordings (only where explicit recording consent has been obtained)
Therapist session notes and AI-assisted documentation drafts
Home program instructions and progress reports
Video session metadata processed through Daily.co

Note: ELODI provides services primarily to children and families. All data relating to a minor client is collected under the consent and authority of a parent or legal guardian. We never collect personal data from a minor without explicit parental or guardian consent. If you believe we have collected data from a minor without proper consent, please contact us immediately at info@elodi.com.

3. How We Use Your Data

We collect and use personal data only for specific, legitimate purposes. These are:

Service delivery: To provide, manage, and improve our therapy, tutoring, and educational services
Booking and scheduling: To process bookings, manage calendars, send reminders, and handle cancellations
Payments: To process fees, manage packages and subscriptions, and issue receipts through HitPay
Clinical documentation: To generate AI-assisted session notes, reports, and home programs reviewed and approved by therapists
Communication: To respond to inquiries, send session updates, and deliver automated reminders
Compliance: To meet our legal obligations under Singapore PDPA, Philippine RA 10173, and US COPPA where applicable
Safety and governance: To maintain audit logs, detect misuse, and protect the security of the platform
Marketing (with consent): To send updates about new services, educational content, or promotional offers — only where you have opted in We do not sell, rent, or trade your personal data to third parties for commercial purposes.

4. AI-Assisted Documentation

ELODI uses artificial intelligence to assist therapists with session note drafting. This is a documentation support tool, not a clinical decision-making system.

How it works

After each session, the therapist provides structured session inputs
The AI generates a draft SOAP note or progress summary based on those inputs
The therapist encodes, edits, and approves the draft before it is finalized or shared
No clinical decision, diagnosis, goal change, or report is issued without therapist review and approval

What AI documentation does NOT do

It does not make independent clinical decisions or recommendations
It does not process raw session recordings without explicit, separate recording consent
It does not share draft notes externally until the therapist has approved them
It does not learn from or retain your personal clinical data for model training without your explicit consent

Note: You will be asked to sign a consent for AI-assisted documentation during onboarding.

5. Who We Share Your Data With

We share personal data only with parties that are necessary for delivering our services, and only under appropriate data-sharing agreements.

5.1 Service Providers

Daily.co: Live video session delivery and meeting infrastructure
Supabase: Database, authentication, file storage, and real-time data
HitPay: Payment processing — operates from our Singapore financial base
Wise Business: International financial settlement and therapist payouts
OpenAI: AI-assisted session documentation and Knowledge Base features
Mux: Educational video hosting and streaming delivery
Resend / Zoho: Email delivery for notifications, receipts, and communications
Vercel: Website and application hosting

5.2 Your Assigned Therapist or Educator

Your intake information, session notes, goals, and progress data are shared with the professional assigned to your care. They are bound by a confidentiality agreement and professional ethics obligations.

5.3 Legal and Regulatory Obligations

We may disclose your information where required by law, court order, or regulatory authority — including under Singapore PDPA, Philippine RA 10173, or applicable laws in your jurisdiction.

5.4 Emergency Situations

Where we have reasonable grounds to believe that a child or individual is at immediate risk of harm, we may share relevant information with appropriate authorities without prior consent.

5.5 What We Will Never Do

Sell your personal data to any third party
Share clinical or therapeutic information with advertisers
Use session recordings for any purpose other than the one stated in your recording consent
Share your information with other clients or their families

6. Your Rights — by Jurisdiction

6.1 Philippines — Republic Act 10173 (Data Privacy Act of 2012)

If you are a Philippines-based client, you have the following rights under RA 10173:

Right to be informed about how your data is collected and used
Right to access your personal data held by ELODI
Right to correct inaccurate or outdated personal data
Right to object to processing of your data for certain purposes
Right to erasure or blocking of your data in certain circumstances
Right to data portability — to receive your data in a structured, usable format
Right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines To exercise these rights, contact us at info@elodi.com. We will respond within 15 business days.

6.2 Singapore — Personal Data Protection Act (PDPA) 2012

As ELODI's operating and financial base is Singapore, we adhere to the Singapore PDPA for our operational data governance:

You may request access to personal data we hold about you
You may request correction of inaccurate data
You may withdraw consent for data collection or use, subject to legal and contractual limitations
We maintain secure storage, audit controls, and access restrictions on all data processed from our Singapore base For PDPA-related inquiries, contact: info@elodi.com

6.3 United States — COPPA Compliance (Educational Services Only)

For United States-based customers accessing ELODI's educational and coaching services only:

ELODI does not knowingly collect personal data from children under 13 without verifiable parental consent
Parents may review, request deletion of, or refuse further collection of their child's data
US-based users do not have access to live clinical therapy, evaluations, treatment plans, or clinical reports
All US-accessible content is labelled as educational or coaching material, not clinical therapy
To exercise COPPA rights, contact: info@elodi.com

7. Session Recordings

ELODI does not record sessions by default. Recordings only occur where:

You have provided explicit, written recording consent during intake
The purpose of the recording is clearly stated (e.g., for therapist review, for educational content with full anonymization)
The therapist or admin has reviewed and approved any recording before it is used for any purpose beyond personal clinical review You may withdraw recording consent at any time by contacting info@elodi.com. Withdrawal of recording consent does not affect your access to any other service.

Note: If a session recording or portion thereof is considered for use as educational content, all personally identifying information — including names, faces, and identifying clinical details — will be removed or anonymized before publication. No recording will be published as educational content without therapist approval and your separate written consent.

8. Data Retention

We retain your personal data for as long as necessary to deliver services to you and to meet our legal obligations.

Retention periods

Active client data: retained for the duration of the service relationship
Clinical session notes and reports: retained for a minimum of 5 years after the last session, in compliance with professional and legal standards
Payment records: retained for 7 years for financial compliance
Consent records: retained for the duration of the consent period plus 5 years
Inactive accounts with no activity for 2 years: we will notify you before deletion
Data requested for deletion: processed within 30 days unless legal retention obligations apply

When data is no longer needed, it is securely deleted or anonymized.

9. Data Security

We take the protection of your personal data seriously. Our security measures include:

Role-based access controls (RBAC) — only authorized staff and therapists can access specific client data
Encrypted data storage and secure signed URLs for file access
End-to-end encrypted video sessions through Daily.co
Secure payment processing through HitPay (PCI DSS compliant)
Audit logging for all data access and changes
Regular security reviews of our platform and third-party integrations
Staff and contractor confidentiality agreements Despite these measures, no system is completely immune to security risks. If you believe your account has been compromised, contact us immediately at info@elodi.com.

10. Cookies and Tracking

Our website and application use cookies and similar technologies to improve your experience.

Types of cookies we use

Essential cookies: Required for the platform to function — login sessions, booking, and payment flows
Analytics cookies: Used to understand how visitors use the platform (via Vercel Analytics)
Preference cookies: Used to remember your language, region, and display preferences

We do not use advertising or tracking cookies for third-party marketing purposes. You may manage cookie preferences through your browser settings. Disabling essential cookies may affect platform functionality.

11. Cross-Border Data Transfers

Because ELODI operates from a Singapore base but serves customers in the Philippines and the United States, your personal data may be transferred across borders. Specifically:

Data is stored and processed on servers operated by Supabase (hosted infrastructure)
Payment data flows through HitPay and Wise from our Singapore operating base
Video session data is processed through Daily.co
AI documentation is processed through OpenAI We ensure all cross-border data transfers are subject to appropriate contractual protections and are disclosed to you in this policy. Where required by RA 10173, PDPA, or COPPA, we maintain records of transfer mechanisms and apply appropriate safeguards.

12. Children's Privacy

The majority of ELODI's clients are children and minors. We take our obligations toward children's privacy extremely seriously.

All data relating to a minor is collected under the authority of a parent or legal guardian
A parent or guardian must complete all intake forms, sign all consent documents, and authorize all services on behalf of a minor
Parents and guardians may access, correct, or request deletion of their child's data at any time
Session recordings involving minors require explicit parental consent and are never published without full anonymization and secondary approval
For US-based minors accessing educational content, we comply with COPPA requirements including verifiable parental consent for children under 13

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Where changes are material, we will notify you by email or through the platform at least 14 days before the change takes effect. The updated policy will always be available at www.elodicare.com/privacy. Your continued use of the platform after the effective date of any updated policy constitutes acceptance of the revised terms.

14. Contact and Data Requests

For any questions about this Privacy Policy, to exercise your data rights, or to submit a complaint:

Email: info@elodi.com
Website: www.elodicare.com/privacy We aim to respond to all data-related requests within 15 business days. If you are not satisfied with our response, you may escalate to the National Privacy Commission (Philippines) at www.privacy.gov.ph or to the relevant authority in your jurisdiction.

ELODI Online Therapy and Learning Center · info@elodi.com · www.elodicare.com