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Trios Consumer Health Data Privacy Policy

Company: Trios LLC

Effective Date: October 11, 2026

Last Updated: October 11, 2026

Trios LLC (“Trios,” “we,” “us,” or “our”) provides caregiving organization and caregiver-wellness tools through the Trios website, mobile applications, any web-based Trios application made available by Trios, Caregiver Weekly, free and paid features, and related services (collectively, the “Services”).

This Consumer Health Data Privacy Policy explains how Trios collects, uses, shares, retains, and protects consumer health data. It is separate from the general Trios Privacy Policy and applies specifically to information that identifies or reveals, or may reasonably be linked to, an individual’s physical or mental health status or related health information.

For privacy questions or requests, contact:

Trios LLC Email: privacy@trios-studio.com

Please do not send medication lists, diagnoses, Daily Care Journal contents, or other sensitive health information in your initial email.

1. Scope of This Policy

This Consumer Health Data Privacy Policy applies to consumer health data processed through the Services, including:

  • the Trios iOS application;
  • the Trios Android application;
  • any web-based Trios application made available by Trios;
  • authenticated caregiving and Care Records features;
  • caregiver wellness features;
  • Care Circle features;
  • Caregiver Weekly or the public Trios website to the extent a person provides consumer health data through those services;
  • other Trios features that process health-related or caregiving information.

Trios accounts may only be created and maintained by individuals who are 18 years of age or older.

Individuals under 18 may not create or maintain a Trios account. An adult account holder may use Trios to organize care for a child or other dependent where the adult is authorized to do so.

2. What We Mean by Consumer Health Data

For purposes of this Policy, consumer health data includes personal information that identifies or reveals information about an individual’s past, present, or future physical or mental health status, where that information falls within applicable consumer-health-data law.

Because Trios is a caregiving platform, information that may appear organizational on its face—such as an appointment, care task, medication reminder, or caregiver journal entry—may also reveal health information.

3. Categories of Consumer Health Data Trios May Collect

Depending on which features you choose to use, Trios may collect or process the following categories of consumer health data.

Medication Information

  • medication names;
  • medication history;
  • medication-related notes;
  • refill information or related care tasks.

Health Observations and Symptoms

  • symptoms;
  • pain levels;
  • sleep information;
  • physical-health observations;
  • behavioral observations;
  • side effects or observations relating to medication.

Mental Health and Wellbeing Information

  • mood;
  • stress;
  • energy;
  • caregiver wellbeing;
  • self-care information;
  • wellness check-ins;
  • information reflected in support scores or wellness summaries.

Care-Recipient Information

  • caregiving needs;
  • illnesses or health conditions entered by a user;
  • disability-related information;
  • cognitive or memory-related information;
  • information about recovery, ongoing care, or assistance needs.

Care Records and Daily Care Journal Information

  • journal entries;
  • care notes;
  • observations;
  • appointments;
  • health-related care schedules;
  • care-history information.

Care Tasks

A care task may reveal health information when it concerns medications, treatment-related appointments, mobility assistance, nutrition, monitoring, therapy, or another health-related caregiving activity.

Derived or Inferred Health Information

Trios may generate or organize information derived from information entered by a user, such as:

  • caregiver wellness summaries;
  • support scores;
  • check-in trends;
  • suggested next steps;
  • organizational insights.

Trios does not currently collect biometric identifiers, genetic information, or precise-location information for the purpose of identifying a person’s health condition or healthcare activity.

4. Why Trios Collects and Uses Consumer Health Data

Trios may collect and use consumer health data to:

  • provide caregiving features requested by users;
  • maintain Care Records;
  • maintain care-recipient profiles;
  • organize medications and medication history;
  • organize appointments and care schedules;
  • support Daily Care Journal functionality;
  • provide caregiver wellness check-ins;
  • provide wellness summaries and support scores;
  • suggest self-care or organizational next steps;
  • display care information entered by users;
  • facilitate user-directed Care Circle collaboration;
  • support reporting, exporting, or sharing initiated by the user;
  • authenticate and secure accounts;
  • troubleshoot and maintain the Services;
  • prevent fraud, misuse, or unauthorized access;
  • comply with applicable legal obligations.

Trios limits its use of identifiable consumer health data to purposes disclosed in this Policy, purposes necessary to provide a product or service requested by the user, or other purposes for which legally required consent or authorization has been obtained.

Trios may use aggregated or deidentified information that is not reasonably linkable to an identified or identifiable individual to understand product usage, evaluate functionality, or improve the Services where permitted by law. Trios will not use identifiable consumer health data for materially additional product-improvement purposes that are not disclosed in this Policy without first providing any additional notice and obtaining any consent required by applicable law.

5. Sources of Consumer Health Data

Trios may receive consumer health data from:

  • the account holder, when information is entered directly into Trios;
  • a caregiver, when that caregiver enters information about a person receiving care;
  • a Care Circle participant, when an authorized participant contributes information through available Trios features;
  • information generated from user-provided data, such as wellness summaries or support scores;
  • user-directed sharing, imports, or integrations, if Trios offers such functionality and the user chooses to use it.

Trios does not currently purchase consumer health data from data brokers.

Trios does not currently obtain consumer health data from advertising networks.

If Trios later introduces integrations with healthcare systems, wearables, health-record providers, or similar services, we will update this Policy and obtain consent where required before introducing materially new collection practices.

6. Consumer Health Data Trios May Share

Trios may share the following categories of consumer health data when necessary to provide a requested feature, at the user’s direction, with legally required consent or authorization, or as otherwise permitted by law:

  • medication information;
  • health observations and symptoms;
  • care-recipient health and caregiving information;
  • Daily Care Journal information;
  • Care Records;
  • appointments and care schedules that reveal health information;
  • caregiver wellness information;
  • wellness summaries or support information;
  • care tasks that reveal health-related information.

Trios does not currently sell consumer health data.

Trios does not share private consumer health data with advertisers for behavioral advertising.

7. Categories of Third Parties With Whom Consumer Health Data May Be Shared

Consumer health data may be processed by or shared with the following categories of recipients, but only as permitted by applicable law and consistent with the purposes described in this Policy.

Infrastructure and Service Providers

Supabase

Trios uses Supabase for authentication, database infrastructure, application backend services, and related technical functionality.

Vercel

Trios uses Vercel for website and web-application hosting, delivery, and related infrastructure.

Google Workspace

Trios uses Google Workspace for business communications. Users are asked not to place unnecessary health information in privacy or support emails, but information voluntarily included in communications may be processed through this service.

Trios may also use technical service providers for security, maintenance, infrastructure, monitoring, or support where necessary to operate the Services.

User-Selected Recipients

Consumer health data may be shared with Care Circle participants, caregivers, family members, professionals, or other recipients when the user intentionally chooses to share information through an available Trios feature.

Legal Recipients

Trios may disclose consumer health data if required or permitted by applicable law, valid legal process, court order, or another legally binding requirement.

Business Transactions

If Trios is involved in a merger, financing, acquisition, restructuring, bankruptcy, sale of assets, or similar corporate transaction, information may be transferred as part of that transaction only to the extent permitted by applicable law. To the extent such a transaction involves consumer health data, Trios will handle that information in accordance with applicable consumer health data laws and this Consumer Health Data Privacy Policy.

Affiliates

Trios currently does not have separately operated affiliates with whom it routinely shares consumer health data. If that changes, this Policy will be updated before consumer health data is shared with a newly disclosed affiliate where required by law.

8. Advertising and Consumer Health Data

The public Trios website and Caregiver Weekly may in the future contain advertising, sponsored content, affiliate links, or commercial partnerships.

Advertisers do not receive private consumer health data merely because they advertise with Trios.

In particular, Trios does not currently provide advertisers access to:

  • medications;
  • Care Records;
  • Daily Care Journal entries;
  • Mood, Energy, or Stress check-ins;
  • caregiver wellness scores;
  • care-recipient profiles;
  • health-related Care Tasks;
  • private Care Circle information.

Trios does not currently use private consumer health data to select or target advertisements.

If Trios proposes to materially change these practices, we will update this Policy and implement any legally required notice, consent, or authorization before beginning the new practice.

9. Sale of Consumer Health Data

Trios does not currently sell consumer health data.

If Trios were ever to propose a practice legally considered a sale of consumer health data, we would not begin that practice without complying with applicable authorization, consent, and disclosure requirements.

10. Consent for Collection and Sharing

Where consumer-health-data law requires affirmative consent, Trios will request that consent before the relevant collection or sharing occurs.

Where required, the request will identify:

  • the categories of consumer health data involved;
  • the purpose of collection or sharing;
  • how the data will be used;
  • the categories of recipients;
  • how consent may be withdrawn.

Where applicable law requires separate consent for sharing, that consent will be separate from consent to collect.

Acceptance of the Trios Terms of Use does not itself constitute consent to collect, use, or share consumer health data where applicable law requires separate affirmative consent or authorization.

11. Health Information About Another Person

Trios allows adult caregivers to enter information concerning people for whom they provide care.

If you enter consumer health data concerning another person, you are responsible for ensuring that you have an appropriate caregiving relationship, authorization, permission, or other lawful basis to provide that information.

Do not enter another person’s consumer health data if you are not authorized to do so.

Privacy rights concerning that information may belong to the individual to whom the data relates. Trios may require reasonable verification of identity, authority, or representation before fulfilling a request concerning another person’s data.

12. Your Consumer Health Data Rights

Where applicable law provides these rights, you may have the right to:

  • confirm whether Trios is collecting, sharing, or selling consumer health data concerning you;
  • access consumer health data concerning you;
  • obtain information about third parties and affiliates with whom your consumer health data has been shared or sold;
  • withdraw consent to future collection where collection depends on consent;
  • withdraw consent to future sharing where sharing depends on consent;
  • request deletion of consumer health data concerning you;
  • appeal certain decisions if Trios declines a qualifying request.

13. How to Submit a Consumer Health Data Request

To initiate a consumer health data request, email:

privacy@trios-studio.com

Suggested subject lines include:

  • Consumer Health Data Access Request
  • Consumer Health Data Deletion Request
  • Withdraw Consumer Health Data Consent
  • Consumer Health Data Privacy Request

Emailing privacy@trios-studio.com initiates the request. Please do not send the health information itself or other unnecessary sensitive information in your initial email.

Trios may direct you to an authenticated or otherwise secure process to verify your identity, your Trios account, your relationship to the information, or your authority to act for another person, where applicable.

You are not required to create a new Trios account solely to exercise consumer health data rights. If you already have an account, Trios may use the existing account as part of reasonable authentication where permitted by applicable law.

14. Response Time and Cost

Where applicable consumer-health-data law establishes a response period, Trios will respond to qualifying requests within the period required by that law.

Where Washington’s My Health My Data Act applies, Trios will generally respond to a qualifying request without undue delay and within 45 days after receiving the request, subject to any permitted extension and authentication requirements.

Qualifying information requests will be provided without charge to the extent required by applicable law. Applicable law may permit a reasonable fee or refusal in limited circumstances involving manifestly unfounded, excessive, or repetitive requests.

15. Deletion of Consumer Health Data

Where applicable law requires deletion, Trios will delete qualifying consumer health data from applicable active systems after authenticating the request, subject to legally permitted limitations or exceptions.

Where required, Trios will also notify applicable processors, contractors, affiliates, or third parties with whom the consumer health data was shared of the deletion request.

Deletion from archived or backup systems may occur on a different timetable where applicable law permits delayed deletion from those systems. Trios will follow the specific backup-deletion period required by the law applicable to the request.

16. Withdrawing Consent

Where Trios relies on your consent to collect or share consumer health data, you may withdraw that consent for future collection or sharing by contacting:

privacy@trios-studio.com

Withdrawal does not necessarily affect processing that was lawful before the withdrawal.

Withdrawal may affect Trios’s ability to provide a feature when the consumer health data is necessary for that feature to function.

17. Appeals

If Trios declines to take action on a qualifying consumer health data request and applicable law provides a right to appeal, you may appeal by emailing:

privacy@trios-studio.com

Use the subject line: Consumer Health Data Appeal

Trios will review the appeal in accordance with the process and timeframe required by applicable law. If an appeal is denied, Trios will provide information about additional complaint options or the applicable regulator where required.

18. New Categories or New Uses of Consumer Health Data

Trios will not begin collecting, using, or sharing an additional category of consumer health data, or begin using existing consumer health data for a materially additional purpose not disclosed in this Policy, without first updating the applicable disclosure and obtaining affirmative consent or other authorization where required by law.

19. Security

Trios uses administrative, technical, and organizational measures designed to protect consumer health data appropriate to the nature and sensitivity of the information processed.

No service or information system can be guaranteed completely secure.

Trios intends to limit access to consumer health data to persons and service providers that reasonably need access for authorized purposes.

Trios will address security incidents and legally required breach notifications in accordance with applicable law.

20. HIPAA and Other Health Privacy Laws

Trios is a consumer caregiving platform.

Trios does not represent that it is currently a HIPAA covered entity or business associate, and not all information stored or processed through Trios is necessarily subject to HIPAA.

Whether HIPAA applies depends on Trios’s relationships and activities. If Trios enters arrangements requiring HIPAA compliance, business associate agreements, or additional safeguards, Trios will implement the required contractual, technical, and organizational controls before processing protected health information in that capacity.

Consumer health privacy laws may protect information even when HIPAA does not apply.

21. Geofencing and Health-Related Location Tracking

Trios does not currently use geofencing technology to identify, track, or target an individual based on visits to healthcare facilities or other locations for the purpose of collecting or inferring consumer health data.

22. Material Changes to This Policy

If Trios materially changes this Consumer Health Data Privacy Policy or materially changes how consumer health data is collected, used, or shared, we will provide notice appropriate to the change.

Where affirmative consent or authorization is required before implementing a new practice, Trios will obtain it before beginning the practice.

23. Relationship to the General Trios Privacy Policy

This Consumer Health Data Privacy Policy supplements the general Trios Privacy Policy.

The general Privacy Policy covers broader categories of personal information, including account information, subscription information, technical information, website information, general communications, and advertising practices.

This Policy governs Trios’s handling of consumer health data where consumer-health-data laws apply.

If a provision of this Consumer Health Data Privacy Policy provides greater rights for qualifying consumer health data than the general Privacy Policy, the applicable consumer-health-data requirement will control to the extent required by law.

24. Contact Trios

For consumer health privacy questions or requests:

Trios LLC Privacy Contact: privacy@trios-studio.com

Please do not include unnecessary medical details or sensitive caregiving information in your initial request.

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