Privacy Policy – Farow

Website, Mobile Applications and Medical Device Software

v2.0 – effective 28 October 2026

Please read our Privacy Policy carefully as it explains the following:

  • What personal information we collect from you and for which purpose (Section 3 and 4)
  • The measures to safeguard access to and the security of your Personal Data (Section 5)
  • Your rights to access, rectify, erase your Personal Data and object to the processing of your Personal Data (Section 8).

Before using the Products, you must confirm that you have read this Privacy Policy. Where we need your consent, for example for the processing of your health data, we ask for it separately in the Products.

1. General

Farow NV ("Farow", "we", "us") provides a set of tools and applications for people with epilepsy and their relatives and caregivers to improve their quality of life. It consists of the epihunter Core app, the epihunter Companion app, epihunter Pro and the epihunter Backend (each as defined below and collectively the "Application").

The epihunter software is a CE-marked medical device. Using brainwaves recorded by a third-party wearable EEG headset, the epihunter Core app automatically detects, signals, and logs absence seizures in real time and can automatically record a video of the seizure. The epihunter Backend securely stores these data and makes them available to the user and, with the user's permission, to the caregivers and physicians the user chooses.

Farow recognizes and understands the importance of the privacy of its users ("users", "You") and wants to respect their desire to store and access personal information in a private and secure manner. This Privacy Policy applies to our Application and our Website (collectively the "Products") and describes how Farow manages, stores and utilizes your Personal Data through its Products. Farow NV is the data controller for this processing. This Privacy Policy also applies to any other current or future Farow product that refers to it, unless a separate privacy policy is provided for that product.

Because the Products process data concerning your health, we ask for your explicit consent to the processing of your health data before you start using the Products. Without this consent, we cannot provide the Products to you. You can withdraw your consent at any time (see Section 8).

Farow is committed to protecting the privacy of all of its users' Personal Data and providing a secure, user-controlled environment for the use of the Products in accordance with the EU General Data Protection Regulation 2016/679 ("GDPR") and the Belgian Law of 30 July 2018 on the protection of natural persons with regard to the processing of personal data. Where relevant, we also comply with the Belgian Law of 13 June 2005 on electronic communications (for cookies and similar technologies), the EU Medical Device Regulation 2017/745 ("MDR") and, as their provisions become applicable, the EU Artificial Intelligence Act (Regulation (EU) 2024/1689) and the European Health Data Space Regulation (Regulation (EU) 2025/327). At the same time, you also share responsibility for maintaining privacy and security, for example by not allowing any third party to use your personal Account. Farow asks all users to be responsible for safeguarding any authentication information and to immediately notify Farow of any unauthorized use of your personal Account.

The Products can also be used by children. If the user is a minor, the Account must be created, and the consents given, by a parent or legal guardian. The parent or legal guardian also exercises the rights described in Section 8 on behalf of the child, taking into account the child's age and maturity.

Please read this Privacy Policy carefully (which is also available on our Website: www.farow.health) so that you fully understand how we obtain and process your Personal Data.

2. Definitions

  • "Account" means your account registered through the registration process of the epihunter subscription.
  • "Application" or "epihunter" means the (i) epihunter Core app; (ii) epihunter Companion app; (iii) epihunter Pro and (iv) epihunter Backend
  • "epihunter Core app" means the smartphone application (Android) which you download on your mobile device and which, connected to the EEG Headset, records your EEG data and automatically detects, signals, logs and (if enabled) video-records seizures
  • "epihunter Companion app" means the smartphone application (Android and iOS) with which the user and, with the user's permission, their relatives and caregivers can consult the seizure history, notes and videos
  • "epihunter Pro" means the web portal, located at pro.epihunter.com, through which a physician can access the epihunter data and reports of a patient who has given consent
  • "epihunter Backend" means the secure cloud platform to which the epihunter Core app, epihunter Companion app and epihunter Pro are connected and which stores and processes the data. Depending on the user profile different functions can be made available
  • "EEG Headset" means the third-party wearable EEG headset used with the epihunter Core app
  • "Products" means the Application, Website and Documentation (such as the instructions for use)
  • "Results" means the raw EEG data recorded with the EEG Headset and the seizure detections generated by the epihunter Core app
  • "Insights" means the overviews of the Results and the other data you entered (such as the seizure diary, calendar views and reports), as displayed in the epihunter Companion app and epihunter Pro
  • "Third Parties" means any natural or legal person or entity other than Farow and you
  • "Website" means the website available at www.farow.health, including its sub-domains such as www.epihunter.com, subscriptions.epihunter.com and pro.epihunter.com

3. Information we collect

We may collect several types of personal information from the users of our Products, and store it on your mobile device and/or our servers, such as:

  • Contact information (e.g. your name, postal address, e-mail address, and mobile or other telephone number)
  • The profile data provided by you on your Account, such as your name and profile picture
  • Information in helpdesk support inquiries
  • Patient demographics such as date of birth and gender
  • Information about your device, such as its model, unique device identifier and operating system version
  • Information collected by manual input in the Application, such as seizure onset, notes, etc.
  • Payment information such as transaction identifiers and summary information that does not include credit card or bank account numbers (we do not collect or store financial account information)
  • Information from the EEG Headset, such as EEG signals and headset identification
  • Automated seizure detections generated by the epihunter Core app, such as the time and duration of a detected seizure
  • Video and audio recordings, as recorded by the epihunter Core app when you enable the video function
  • Information about who you have given access to your data, such as the Companion app users and physicians you share your data with
  • If you are a physician using epihunter Pro: your name, professional contact details and the healthcare institution you work for
  • Web behavior information such as information related to how the users use the Products (e.g. browser type, domains, page views) collected through cookies and other automated technology (cfr. Section 6 "Cookies").

Hereinafter collectively "Personal Data". The EEG data, seizure detections, notes and videos are data concerning your health, a special category of Personal Data that receives extra protection under the GDPR.

We shall store your Personal Data on our servers located in the European Economic Area (Ireland).

Videos may also show other people, for example family members or classmates. For privacy reasons, we advise you to use the video function only at home, and to inform the people around you when it is switched on.

We would like to draw your attention to the fact that Personal Data consisting of patient medical data is also protected by medical secrecy rules.

4. How do we use your Personal Data

Farow (i) collects, (ii) uses, (iii) maintains and (iv) may share your Personal Data provided by you or collected by us with its affiliated companies, if any, for all purposes necessary to ensure the proper functioning and operation of the user Accounts and/or the proper functioning of the Products.

These purposes may include (collectively the "Purpose"):

  • Creating and managing your Account and your subscription, including the shipping of the EEG Headset;
  • Providing information and allowing the users access to the Products, including the detection, signalling and logging of seizures and making the Results and Insights available to you and to the people you choose to share them with;
  • Diagnosing technical problems and managing technical support and processing inquiries concerning the Products;
  • Contacting the users by phone, e-mail, text message or push notifications (if they are enabled) to (i) verify your Account and (ii) for information and operational purposes such as account management, instructions, alerts, reminders, customer service, system maintenance and others;
  • With your consent, contacting the users to (i) communicate about, and organize your participation in market research or (ii) obtain testimonials;
  • Monitoring the safety and performance of epihunter as a medical device, including post-market surveillance, vigilance and quality control as required by the MDR;
  • With your consent, using your Results in pseudonymized form (without your name or contact details) to improve the detection algorithm and to develop new features of the Products, and performing data analyses on anonymized and aggregated data, which can no longer identify you, to improve the Products;
  • The operation, evaluation and improvement of the Products (including the development of additional products and/or services, enhancing and improving the current Products, analysis of our Products, quality control activities and performing internal business functions such as accounting and auditing);
  • Protecting against, identifying and preventing fraud and other unlawful activity, claims and other liabilities;
  • Complying with and enforcing any applicable legal obligations with respect to our Terms of Use and Privacy Policy.

We process your Personal Data on the following legal bases:

  • Performance of our contract with you – to create your Account, manage your subscription and provide the Products;
  • Your explicit consent – for the processing of your health data, for sharing your data with the caregivers and physicians you choose, for improving the detection algorithm with your pseudonymized Results, for market research and testimonials, and for non-essential cookies;
  • Our legitimate interest – to secure and improve the Products, to analyse anonymized data and to prevent fraud;
  • Our legal obligations – for example our obligations as a medical device manufacturer under the MDR, and our accounting and tax obligations.

If you take part in a clinical study in which epihunter is used, you will receive separate information and a separate informed consent form for that study.

The epihunter Core app uses an algorithm based on artificial intelligence to analyse your EEG data and detect seizures automatically. The detections are intended to support you, your caregivers and your physician; they are not a diagnosis, and we do not take decisions that produce legal effects concerning you or similarly significantly affect you based solely on these automated detections. Your physician remains responsible for the interpretation of the Results.

Furthermore, Farow may access, retain, and disclose Personal Data in the following events:

  • In order to be in compliance with any applicable legislation or regulations;
  • If a law enforcement authority or other government official lawfully requests so;
  • To enforce the Farow Terms of Use or Privacy Policy;
  • The investigation of any suspected or actual fraudulent or illegal activity and
  • To protect your or our safety and/or rights.

We may disclose certain information to vendors and service providers who help us provide the Products. Examples of these vendors and service providers include entities that process credit or debit card payments, ship the EEG Headset and provide hosting, authentication and analytics services (see Section 7).

We do not share your Results with Third Parties for their own purposes, for example to develop their own products. If this would change, we will only do so with your prior explicit consent and under a written agreement with that Third Party.

You furthermore understand and agree that the technical processing and transmission of the Products, including your Personal Data, may involve (i) transmissions over various networks; and (ii) modifications to conform and adapt to technical requirements of connecting networks, or devices.

5. Security

Farow shall take appropriate administrative, technical and organizational measures against unauthorized or unlawful processing of any Personal Data or its accidental loss, destruction or damage, access, disclosure or use, such as encrypted connections, secure authentication, access controls and pseudonymization of data where possible. Upon written request, Farow can provide you with a list of people of Farow that may have access to your Personal Data.

These people have entered into confidentiality agreements prior to having been granted access to your Personal Data. In the event of and following discovery or notification of a breach of the security of the Personal Data, or access by an unauthorized person, Farow will notify the competent supervisory authority where required by law, and will notify you without undue delay if the breach is likely to result in a high risk to your rights and freedoms.

6. Cookies

When using the Products, we may collect certain information by automated means, such as cookies (small text files stored in your browser) and similar technologies, including mobile application identifiers, to improve your experience of the Products, increase security, measure use and effectiveness of the Products, identify and resolve issues and for marketing purposes. Cookies that are strictly necessary for the Products to work are always placed. All other cookies (such as analytics and marketing cookies) are only placed with your prior consent.

The information we collect in this manner includes IP address, browser characteristics, device characteristics, operating system version, information on actions taken on our Products (such as usage, activity logs and click-throughs), and dates and times of visits. Log data is deleted on a regular basis.

You can give, refuse or withdraw your consent at any time through the cookie settings on our Website. You can also control cookies through your browser settings and other tools. For example, you may be able to set your device or browser to disable, clear, reset or block the use of cookies or similar technologies. Please note, however, that without cookies the Products may not work properly or you may not be able to use all of their features.

Third parties may also use cookies to collect information about your activities on our Products to understand and continue improving the performance of our Products. Please check the relevant third party website for more information about their use of cookies. Where you access other websites from the Products using the links provided, the operators of these websites will use cookies in accordance with their own cookies policy, which may differ from ours.

More information about cookies and similar technologies set by third parties is available on the websites of the following providers we use: Cloudflare, Facebook, Google AdSense, Google Analytics, Google Firebase, Google Tag Manager, HubSpot, LinkedIn, Okta (Auth0), Stripe and Twitter (X).

7. Disclosure to Third Parties

Sharing at your request. You decide who can see your data. You can give your relatives and caregivers access to your Results and Insights through the epihunter Companion app, and you can withdraw this access at any time in the app settings. If your physician uses epihunter Pro, your data and videos only become available to your physician after you have given your consent. You can also export your data and share it yourself, for example with your doctor.

In the event of full or partial merger with, or acquisition of all or part of Farow, we may transfer your Personal Data to a Third Party. In such an event, Farow shall impose this Third Party to use any Personal Data strictly consistent with this Privacy Policy, and we will inform you in advance.

Other than as set out in this Privacy Policy, we shall not sell or otherwise disclose your Personal Data to Third Parties without obtaining your prior explicit consent unless this is necessary for the purposes set out in this Privacy Policy or unless we are required to do so by law.

We may also share Personal Data with Third Party service providers who help us to provide, understand and improve our Products, such as providers of hosting, authentication (Okta Auth0), app analytics and notifications (Google Firebase), payments (Stripe), customer relationship management and support (HubSpot), website security (Cloudflare) and shipping. We do not authorize these Third Party service providers to use or disclose your Personal Data except as strictly necessary to perform any services under our supervision or to comply with applicable legislation. We seek to provide any such Third Party service provider with only the Personal Data they need to perform their specific function.

In any event, such Third Party service providers shall be obliged, under a data processing agreement, to treat your Personal Data in accordance with this Privacy Policy and the GDPR.

We do not transfer your Personal Data outside the European Economic Area, unless appropriate safeguards are in place, such as an adequacy decision of the European Commission (including the EU-U.S. Data Privacy Framework) or the European Commission's Standard Contractual Clauses.

8. Your rights

Right of access – If you are concerned or have any questions about your Personal Data, you have the right to request access to the Personal Data which we hold or process about you. We will then provide you with information about the data that are being processed and on the source of those data.

Right of rectification and right of erasure – You have the right to request us free of charge to correct or erase your Personal Data, for example if such Personal Data would be incomplete, inaccurate, no longer needed or processed unlawfully.

Right to restriction of processing – You have the right to request us to restrict the processing of your Personal Data in certain cases, for example while we check whether your data is accurate.

Right to data portability – You have the right to receive the Personal Data you provided to us in a structured, commonly used and machine-readable format, and to have it transmitted to another controller.

Right to not be subject to automated individual decision making – You have the right to request us not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Right to object and to withdraw consent – You may object at any time to the processing of your Personal Data based on our legitimate interest, and to the use of your Personal Data for direct marketing purposes. You may also withdraw at any time your consent to the processing of your Personal Data by notifying us in writing via info@farow.health. Upon receipt of this notification, Farow shall promptly stop any processing of your Personal Data based on that consent. Withdrawing your consent does not affect the lawfulness of processing before the withdrawal. Please note that we cannot provide the Application without your consent to the processing of your health data.

To exercise your abovementioned rights or any other questions concerning this Privacy Policy, please contact us by e-mail or in writing on the address below. If we have reasonable doubts about your identity, we may ask you for additional proof of your identity. Farow will undertake the necessary action without undue delay and provide information on action taken (or the absence of any such action) within one month. This period may be extended by two further months for complex or numerous requests, in which case we will inform you.

You may also lodge a complaint with a supervisory authority, such as the Belgian Data Protection Authority (www.dataprotectionauthority.be).

9. Data retention and deletion

We may retain information regarding you and your use of the Products, including Personal Data, for as long as your Account is active and as long as reasonably needed to provide you with the Products and the uses described in this Privacy Policy, or as long as required by law.

When you end your subscription, we offer you a free export of all your data. If we offer you a data storage option and you choose it, we keep your data securely stored so that you can consult it or reactivate your Account later.

Please note that we retain your Personal Data even if you stop using the Products, end your subscription or remove the Application from your mobile device. To have all your Personal Data removed, you must send a deletion request to info@farow.health. Upon receipt of your request, we will delete your Personal Data without undue delay, unless we are required by law to keep certain data for a longer period, such as invoicing and accounting data under Belgian accounting and tax law, or data we need to keep to meet our obligations as a medical device manufacturer. We may retain and continue to use your data exclusively on a fully anonymized basis.

10. Third Party websites or applications

You acknowledge and agree that certain content or services provided by Third Parties may be made available to you through the Products. You agree that such linked content or services may have their own privacy policies for which Farow cannot be held responsible. Farow does not in any way review or endorse the privacy practices of such Third Parties.

11. Updates or changes to our Privacy Policy

Occasionally, we may change or update this Privacy Policy. The version number and date at the top of this Privacy Policy show when it was last updated. If Farow would use your Personal Data in a manner materially different from that stated at the time of the collection, we will provide you with a notice on our Website and in our Application indicating that the Privacy Policy has been changed or updated and, where required, request your consent.

Farow NV, Kempische Steenweg 303/200, 3500 Hasselt, Belgium – enterprise number BE 0676.380.406 – www.farow.health – info@farow.health

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