Privacy Policy

We never sell your health data or use it for advertising.

This Privacy Notice for Kaizen Healthcare Inc ("Kaizen Health", "we", "us", or "our"), 1875 Mission St Ste 103, San Francisco, CA 94103, United States, describes how and why we access, collect, store, use, and share ("process") your personal information. Kaizen Healthcare Inc is the controller of your personal data. This Notice applies when you:

• Visit our website at kaizenhealth.io, including the website AI chat and contact forms, or any other website of ours that links to this Notice.
• Download and use our mobile application, Kaizen - Family Health & AI, and its home screen widgets, or any other application of ours that links to this Notice.
• Use Kaizen Health through our WhatsApp number, including typed messages, files, and voice notes where those features are available.
• Engage with us in other related ways, including support, marketing, or events.

We refer to all of the above together as the "Services". Questions or concerns? If you do not agree with our policies and practices, please do not use the Services. If you have questions, contact us at info@kaizenhealth.io.

Summary of key points

• We do not sell your personal information, share it for cross-context behavioral advertising, or use your health data to target ads. Subscriptions are our only revenue.
• What we process. Account details, health information you record, documents and voice notes you add, device and usage data, and, with your permission, health metrics from Apple Health or Health Connect, contacts, and location. See what information we collect.
• Sensitive information. We process health data, account login credentials, and precise geolocation, with your consent or as permitted by law. We do not collect genetic data or create voiceprints to identify you. Voice recordings can be personal or sensitive information even when we do not use them for identification.
• Third parties. We receive limited data from Apple and Google when you sign in with them or buy a subscription. See information we receive from third parties.
• AI features. We use AI and transcription providers to deliver the features you request. We do not permit them to train models on your content. HIPAA agreements apply only to covered services and processing; they are not a certification of the Services. See AI products.
• Analytics and crash reporting collect usage and diagnostic data. They are not given your health records, documents, or chat content. See cookies and tracking.
• How long we keep it. Account records generally stay while your account exists. WhatsApp chat history, including voice transcripts, is scheduled to expire after 30 days without activity; new activity restarts that period. See how long we keep your information.
• WhatsApp voice notes. Audio passes through WhatsApp (Meta) and Google Cloud Speech-to-Text. The transcript goes through AI processing to produce a text reply. See WhatsApp messages and voice notes. Our separate Consumer Health Data Privacy Policy explains consumer health data rights.
• Your rights. You can access, export, correct, or delete your data at any time, in the App, through support, or by email. See your privacy rights.

Table of contents

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on?
4. When and with whom do we share your information?
5. Do we use cookies and other tracking technologies?
6. Do we offer artificial intelligence-based products?
7. How do we handle your social logins?
8. How long do we keep your information?
9. How do we keep your information safe?
10. Do we collect information from minors?
11. What are your privacy rights?
12. Controls for Do-Not-Track and Global Privacy Control
13. Do United States residents have specific privacy rights?
14. International data transfers
15. Automated processing
16. Health privacy laws and our status
17. Do we make updates to this Notice?
18. How can you contact us about this Notice?
19. How can you review, update, or delete your data?

1. What information do we collect?

1.1 Personal information you disclose to us

In Short: We collect personal information that you provide to us.

• Account and profile data: name, email address, password (stored only as a salted hash) or the identifier returned by Sign in with Apple or Google Sign In, date of birth or age, sex or gender, height, weight, phone number if you provide one, profile photo, language, and time zone.
• Health information: conditions, symptoms, medications, allergies, immunizations, procedures, family history, lab and test results, appointments, care notes, and anything else you record or ask about in the App.
• Documents and media: medical records, lab reports, prescriptions, insurance documents, and images you upload, scan with the in-app document scanner, or attach to a chat. We extract text from these documents so we can summarize and search them.
• Voice recordings: audio you record in the App or send to our WhatsApp number, which is transcribed to text so the feature can work. We do not create voiceprints or use audio to identify or authenticate you. WhatsApp audio and transcripts have the separate handling described below.
• Family and group data: information about family members or dependents you add to your account or a care group, including their name, relationship to you, and any health information you record about them. You must have that person's permission (or legal authority) before you add their information.
• Support and survey content: messages, feedback, bug reports, and any attachments you send us.

Sensitive information. With your consent or as otherwise permitted by applicable law, we process health data, account login credentials, and precise geolocation. We do not collect genetic data or fingerprints, and we do not create voiceprints. Laws differ in how they classify voice recordings. We treat voice audio and transcripts as sensitive when they contain health information, regardless of whether they qualify as biometric information. If you enable Face ID, Touch ID, or Android biometric unlock, that check happens on your device through the operating system and we never receive or store the underlying data.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to it.

1.2 Information collected with your permission

• Apple Health and Google Health Connect: if you grant access, we read health and fitness metrics such as steps, heart rate and resting heart rate, sleep, weight, height, blood pressure, blood glucose, and activity. We only request the metric types the features you use need, we do not write ad-related data back, and you can revoke access at any time in iOS Settings, Health Connect, or the App. Health data received through these APIs is never used for advertising or marketing and is never sold or shared with data brokers.
• Camera, photo library, microphone, and files: used only to capture or select the documents, images, and audio you choose to add.
• Contacts: if you choose to add a family member from your address book, the App reads your contact list on your device so you can pick one. Only the details of the contact you select are sent to us. We do not upload your full address book.
• Location: if you grant access, we use your device location for location-dependent features. We do not track your location in the background and we do not build location profiles. You can disable this in your device settings, though some features may stop working.
• Push notifications: if you allow them, we store a device push token so we can send reminders and updates. You can turn these off in your device settings.

1.3 Information collected automatically

In Short: Some information, such as your IP address and device characteristics, is collected automatically when you use the Services.

• Device data: device model and manufacturer, operating system and version, App version, language and region, hardware settings, mobile carrier or internet service provider, device and installation identifiers, and IP address.
• Log and usage data: screens you open, how long you spend on them, features you use, session timing, searches, and the date and time stamps of your activity.
• Diagnostic and crash data: error messages, stack traces, performance traces, and the sequence of app events leading up to a problem.
• Website data: pages viewed, referring URL, approximate location derived from IP address, browser and device type, and cookie or similar identifiers set by the analytics tools described in section 5.
• Security and abuse-prevention data: IP address and request counts, which we use to rate-limit the website AI chat and to detect abuse.

1.4 Information we receive from third parties

• Apple and Google sign-in: if you register using Sign in with Apple or Google Sign In, we receive the profile information described in section 7.
• Apple and Google billing: we receive your transaction identifier, product identifier, purchase and renewal dates, and entitlement status so we can unlock paid features.

We do not buy personal information from data brokers, and we do not enrich your profile with data purchased from third parties.

1.5 Subscription and payment information

Subscriptions are sold and billed by Apple and Google. We never receive or store your card number, bank details, security code, or billing address. Payment data is handled entirely by Apple and Google under their own privacy policies.

1.6 Website AI chat

The AI chat on our website asks for your email address and verifies it with a one-time code. Your questions, any files you attach, and your email address are processed to produce a response, and your IP address is used to apply rate limits. Please do not enter information in the website chat that you would not want associated with your email address.

1.7 Google API Services

Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including its Limited Use requirements.

1.8 WhatsApp messages and voice notes

WhatsApp is optional and is for adults aged 18 or over. When you agree to the WhatsApp consent notice, we create or connect a Kaizen account linked to your WhatsApp number. We receive your number, messages, files you send, and delivery information from WhatsApp (Meta). Your messages may contain health information about you or someone you are authorized to help. Send another person's voice or health information only with their permission or other valid legal authority.

• Audio processing. If you choose to send a voice note when the feature is enabled, our server downloads and converts the audio, then sends it to Google Cloud Speech-to-Text, our transcription processor. Conversion uses temporary files on our servers that are designed to be removed after processing. We do not keep an audio archive or save the voice note as a health record.
• Transcript and AI reply. We process the transcript like a typed message. Where configured, TypeSafe receives message text and clarification context for safety screening. When generating an AI reply, OpenAI receives the transcript and relevant recent chat context. WhatsApp processing requires the WhatsApp consent notice. Audio and transcripts may include names, medicine names, doses, and other health information; they are not necessarily de-identified.
• What we understood. A reply may show all or part of the transcript after "I heard:" and may ask a short question to check an uncertain detail. This can repeat sensitive health information into your WhatsApp chat and notification previews. Check the text and type a correction if it is wrong. Confirmation checks what was heard; it does not establish that medical information is correct or safe.
• Your choice. Voice transcription currently uses English speech recognition. You can type instead of sending audio. Typing avoids audio transcription; typed messages still use AI processing. Send STOP to pause WhatsApp interactions. STOP does not erase existing data. Unlink WhatsApp in the App or contact us to withdraw WhatsApp processing consent and request deletion. Sending DELETE MY DATA starts the account deletion flow; complete its verification and confirmation steps. See sections 8 and 19 for what deletion removes and what may remain.

Our servers and providers process data outside some users' countries, including in the United States. Google Speech-to-Text's default service can process audio globally. We do not promise that WhatsApp audio stays in your country. See section 14. WhatsApp also handles information under its own privacy policy.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer the Services, to communicate with you, for security and fraud prevention, and to comply with law. We process it only when we have a valid legal reason.

• To provide the Services: create and manage your account, store your records, generate summaries and your health score, run reminders, and deliver the features you request.
• To operate AI features: answer your questions, summarize documents, extract clinical facts, and transcribe voice notes.
• To enable family and group sharing: share the records you choose with the care groups you choose, and enable communication between members.
• To respond to your inquiries and provide support.
• To keep the Services secure and reliable: authenticate you, prevent fraud and abuse, apply rate limits, and diagnose crashes and errors.
• To identify usage trends and understand how the Services are used so we can improve them.
• To communicate with you: service and security notices, and marketing messages you have opted into.
• To save or protect a vital interest, such as to prevent harm to you or another person.
• To meet legal and accounting obligations and respond to lawful requests.

We do not use your health information, documents, or chat content to target advertising, and we do not profile you for advertising purposes. Marketing communications we send are based only on your contact details and your subscription status.

3. What legal bases do we rely on to process your information?

In Short: We process your personal information only when we have a valid legal reason to do so under applicable law.

If you are located in the EEA, UK, or Switzerland, this section applies to you

The GDPR and UK GDPR require us to explain the legal bases we rely on. For each purpose in section 2, we rely on:

• Consent: where you have given us permission for a specific purpose. For health data we rely on your explicit consent under GDPR Article 9(2)(a), which you give when you enable health features, and which you can withdraw at any time.
• Performance of a contract: to deliver the Services you signed up for, including your account, records, AI features, and subscription.
• Legitimate interests: to secure the Services, diagnose problems, prevent fraud, and analyze how the Services are used so we can improve them, where those interests do not override your rights.
• Legal obligations: to comply with law, cooperate with law enforcement or a regulator, or exercise or defend legal claims.
• Vital interests: where processing is necessary to protect your life or that of another person.

If you are located in Canada, this section applies to you

We process your information where you have given us express consent, or where consent can be inferred from the circumstances (implied consent). You can withdraw your consent at any time. In limited cases, applicable law permits us to process without consent, for example: where collection is clearly in your interest and consent cannot be obtained in time; for investigations, fraud detection, and prevention; for business transactions meeting certain conditions; to identify injured, ill, or deceased persons and communicate with next of kin; where we have reasonable grounds to believe someone has been a victim of financial abuse; where disclosure is required by subpoena, warrant, or court order; or where the information is publicly available and specified by the regulations.

If you are located in India

We explain the information we process and its purposes before seeking your consent, including for WhatsApp voice transcription and health information. You can request access, correction, deletion, or withdrawal of consent using the contact details in section 18. Rights and obligations under Indian privacy laws apply as their relevant provisions take effect. Withdrawing WhatsApp consent does not require you to stop using the separate Kaizen App.

For privacy grievances in India, contact our Grievance Officer, Snehal Shah, at snehal@kaizenhealth.io. We address these grievances within one month of receipt. You can also write to the company address in section 18.

4. When and with whom do we share your personal information?

In Short: We share information only in the situations described below. We do not sell your personal information and we do not share it for cross-context behavioral advertising.

We do not disclose your health data to data brokers, insurers, or employers.

4.1 With people you choose

If you add a document or record to a care group, every member of that group can see it, and members can communicate with each other in the App. You control what you share and can turn sharing off at any time, but members may already have seen or saved the content. Removing sharing does not undo what someone has already read. Content shared into a care group is visible only to that group. It is not public, and it is not published outside the Services.

4.2 With service providers

These vendors process data on our behalf, under written contract, and only for the purposes we specify:

• Amazon Web Services: hosting and operation of our backend application servers.
• Google (Firebase and Google Cloud): authentication, database, file storage, push notifications, analytics, and remote configuration. Google Cloud Speech-to-Text receives voice audio for transcription, including audio sent through WhatsApp.
• OpenAI, Anthropic, Google, and TypeSafe: AI processing, as described in section 6.
• Supabase: storage of health-fact memories and vector embeddings.
• Sentry: crash and error monitoring.
• Twilio SendGrid: transactional and product email, including verification codes.
• Apple and Google: app distribution, subscription billing, and receipt validation.

4.3 For legal reasons and to protect people

We may disclose information where we believe it is required by law, or reasonably necessary to comply with legal process, enforce our terms, investigate suspected fraud or abuse, or protect the rights, property, or safety of you, us, or others. Where we are legally permitted, we will notify you before disclosing your information in response to a legal request.

4.4 Business transfers

If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, your information may transfer as part of that transaction. We will notify you before your information becomes subject to a materially different privacy policy, and we will require the recipient to honor the commitments in this Notice. Your health data is not an asset we will market or sell separately from the Services.

4.5 WhatsApp (Meta)

If you use our WhatsApp number, WhatsApp (Meta) carries your messages, audio, and our replies. Meta also processes information to operate WhatsApp under its own terms and privacy policy. Our transcription and AI providers process content on our behalf; that does not make all of Meta's processing subject to our instructions or retention periods.

5. Do we use cookies and other tracking technologies?

In Short: We use a small set of cookies and analytics tools. We do not use advertising or retargeting trackers.

We use strictly necessary cookies and local storage for sign-in, security, and remembering your preferences. These cannot be turned off without breaking the Services. We use the measurement tools listed below. None of them is given your health records, documents, or chat content.

• Google Analytics 4 (website): provided by Google, to measure page views, traffic sources, and general site usage. It sets cookies and similar identifiers in your browser and processes your IP address, which Google anonymizes before storage. We have not enabled Google Signals, Demographics and Interests Reporting, advertising features, or remarketing on this property. You can opt out with the Google Analytics opt-out browser add-on, by declining analytics cookies where we present that choice, or by sending a Global Privacy Control signal.
• Firebase Analytics (App): provided by Google. Records which screens you open, how long you spend on them, and similar product-usage events, tied to an app instance identifier. It is not given health record content. You can turn off analytics collection in the App's privacy settings.
• Sentry (App, website, and backend): crash and error monitoring. Sentry receives error messages, stack traces, performance traces, device and OS details, and a pseudonymous identifier so we can tell how many users an error affects. We have disabled Sentry's collection of personally identifying request data on our backend. Error reports can incidentally contain technical fragments of a request; we configure our systems to scrub and redact sensitive values, and we do not intentionally send health data to Sentry.
• Firebase Remote Config and Cloud Messaging: provided by Google, to roll features out safely and deliver notifications you have opted into.

We do not use advertising, retargeting, or social media tracking pixels on the website or in the App, we do not display third-party advertising or offer walls, and we do not permit third parties to collect data through the Services for their own advertising purposes. Because we do not use tracking technologies for targeted advertising, there is no advertising opt-out for us to offer.

Analytics data collected through Google Analytics 4 and Firebase Analytics is retained for no longer than 14 months. Error and diagnostic data in Sentry is retained for no longer than 90 days. For more on Google's practices, see the Google Privacy & Terms page.

6. Do we offer artificial intelligence-based products?

In Short: Yes. We offer features powered by artificial intelligence, and this section explains how your data is handled when you use them.

Our AI features provide chat responses, document and image analysis, text summarization, health insights, and voice transcription. The providers we use are:

• OpenAI: chat responses, document summarization, and extraction of clinical facts.
• Anthropic: chat responses and document analysis.
• TypeSafe: automated message safety screening and classification, including WhatsApp message text and voice transcripts where configured.
• Google Cloud: transcription of voice recordings through Speech-to-Text, and redaction of identifying details through Data Loss Prevention.
• Google Gemini: document and content analysis. This runs under Google's API data processing terms rather than the Business Associate Agreement described below.

How we handle this processing:

• We require written data processing terms for providers acting on our behalf. We have a signed Business Associate Agreement with Google. Where HIPAA applies, a Business Associate Agreement must cover the provider and the particular service before we send protected health information. A provider's other products or a new feature are not automatically covered.
• Your data is not used for training. Under our agreements, none of these providers may use your input or the generated output to train or improve their models.
• Zero data retention. Under zero data retention terms with OpenAI and Anthropic, your input and the generated output are not stored on their systems after the response is returned to us. They are not kept for abuse monitoring, human review, or any other purpose, so there is no copy on their side to retain or disclose.
• We apply automated redaction and de-identification, including Google Cloud Data Loss Prevention, to remove directly identifying details before content is sent for processing where the feature allows it. Redaction is not perfect, and content you write yourself may still contain identifying details.
• No provider receives your Kaizen Health account credentials. Where a provider is not covered by zero data retention terms, it may hold the request briefly for abuse monitoring before deleting it, and never uses it for training.
• AI features are optional. In the App, consent is obtained through the in-app AI Use Disclaimer. On WhatsApp, we obtain consent through the WhatsApp consent notice, including before voice transcription. You can stop using AI features at any time. You must not use them in any way that violates the terms or policies of these providers.

Google Speech-to-Text for WhatsApp. We enable voice transcription only with Google's optional data logging and model improvement program disabled. Google's Speech-to-Text data usage documentation says that synchronous recognition, which this feature uses, processes audio in memory without storing audio or transcripts when that program is disabled. Google may temporarily log service metadata, such as request time and size. This is separate from the transcript we retain as chat history. We do not authorize Google to retain these notes for training.

To give you continuity across conversations, we store extracted health facts ("memories") and their vector embeddings in a database hosted on Supabase. You can view and delete individual memories, or all of them, in the App.

AI output is informational only and is not medical advice. See our Medical Disclaimer.

7. How do we handle your social logins?

In Short: If you register or log in using Apple or Google, we receive limited profile information from them.

You can register and log in using Sign in with Apple or Google Sign In. When you do, we receive a unique account identifier, your email address (or Apple's private relay address if you choose to hide it), and your name where you choose to share it. We use this information only for the purposes described in this Notice, principally to create and authenticate your account.

We do not control, and are not responsible for, other uses of your personal information by Apple or Google. We recommend reviewing their privacy notices to understand how they collect, use, and share your information, and how to set your preferences.

8. How long do we keep your information?

Account records generally stay while your account exists. WhatsApp chat history has a separate inactivity period, and audio processing is temporary. Deletion and limited exceptions are described below.

Your profile, health records, documents and media, voice recordings saved in the App, health-fact memories, and group memberships are kept while your account exists, and are deleted when you delete your account. WhatsApp chat history and voice notes follow the separate periods below. You can also delete individual records, documents, and memories at any time without closing your account.

Some records have different retention periods or cannot disappear at the same instant:

• WhatsApp chat history: we keep a limited recent thread, including voice transcripts and AI replies. It is scheduled to expire after 30 days without activity. New activity restarts the 30-day period, so a retained message can remain longer than 30 days from when it was sent. Expiry uses background deletion and is not an exact physical-deletion deadline. Replies, which may contain the "I heard:" text, are also kept in delivery-retry records scheduled to expire after seven days. Unlinking or account deletion removes these chat and reply records through the deletion flow.
• WhatsApp voice audio: audio is used transiently for conversion and transcription, including temporary conversion files; it is not retained as a chat attachment or an audio archive. This does not delete the original note from WhatsApp or copies on your devices.
• WhatsApp consent and deletion receipts: limited receipts are scheduled to expire after three years. They contain a pseudonymous phone-number reference, policy version, channel, and timestamps, rather than audio, transcripts, or chat text. They support consent records and handling of deletion requests; they are not anonymous merely because your account has been deleted.
• Encrypted backups: deletion removes your data from our live systems immediately, but residual copies persist in encrypted backups until they rotate out, which happens within 90 days. These backups are isolated from further processing and are only ever used to recover from a disaster.
• Analytics and crash diagnostics: usage and error records are tied to a device or app-instance identifier rather than to your account, so deleting your account does not reach into them. They contain no health data and age out automatically, within 14 months for analytics and 90 days for crash data.
• Transaction and tax records: we are legally required to keep records of subscription payments, typically for seven years. These contain no health data.
• Records we must keep by law: where we need information to comply with a legal obligation, resolve a dispute, prevent fraud, assist an investigation, or enforce our terms, we keep only what is necessary and only for as long as necessary.

The WhatsApp periods above are subject to applicable legal retention requirements. If the law requires us to retain information for longer, we limit retention to the information and purposes that requirement covers, rather than keeping it for continued chat use.

Two further notes. Content you shared into a care group may already have been saved or exported by other members, and we cannot reach those copies. And the website AI chat is keyed to an email address rather than an account, so it is not covered by account deletion: verification codes expire within minutes and chat rate-limit records are kept no longer than 24 hours, both independently of whether you have an account.

Where we no longer have a legitimate need to process your information and cannot delete it immediately, we securely store it and isolate it from further processing until deletion is possible.

9. How do we keep your information safe?

In Short: We protect your information with organizational and technical security measures, though no system can be guaranteed completely secure.

Our safeguards include encryption in transit with TLS, encryption at rest, per-user access rules enforced at the database level, scoped file storage, optional biometric app lock, credentials stored in your device's secure keychain or keystore, least-privilege access for our team, and audit logging of administrative access. Despite these efforts, no electronic transmission or storage technology can be guaranteed to be 100% secure, so we cannot promise that unauthorized third parties will never defeat our security. Transmission of personal information to and from the Services is at your own risk, and you should only use the Services in a secure environment.

WhatsApp voice transcripts and the "I heard:" text require the same care as typed health messages. WhatsApp messages are readable by our service after delivery for processing and are sent to the providers described above. WhatsApp's encryption does not mean that Kaizen and its processors cannot read them. Protect access to your phone and linked devices, and hide notification previews if others can see your screen.

If a breach affects your personal or health information, we will notify you and the relevant regulators as required by applicable law, including the FTC Health Breach Notification Rule, state breach notification laws, and GDPR Articles 33 and 34.

10. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

The Services are for people 18 and over. We do not knowingly collect, solicit data from, or market to children under 18, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18, or that you are the parent or guardian of a minor dependent and consent to that minor's information being recorded.

Adult account holders can record information about a child as a family member or dependent. When you do, you are responsible for having the legal authority to provide that information, you act as that child's parent or guardian for consent purposes, and the child's information is treated with the same protections as your own. It is never used for advertising or profiling. If we learn that a child under 18 has created an account, we will deactivate it and promptly delete the data. If you become aware of any data we may have collected from a child, contact us at info@kaizenhealth.io.

11. What are your privacy rights?

In Short: Depending on where you live, you may review, change, or terminate your account at any time, and you have rights that give you greater access to and control over your personal information.

11.1 EEA, UK, Switzerland, and Canada

In these regions you have the right to request access to and a copy of your personal information; rectification or erasure; restriction of processing; portability of data you provided to us; and not to be subject to solely automated decision-making. In certain circumstances you may also object to processing based on our legitimate interests. Exercising these rights is free and we will not treat you differently for doing so.

To exercise any of these rights, email info@kaizenhealth.io with "Data Rights Request" in the subject line, or use our support form. We respond within one month and may extend by two further months for complex requests, telling you if we do. We may need to verify your identity first.

If you are in the EEA or UK and believe we are unlawfully processing your personal information, you have the right to complain to your Member State data protection authority or the UK Information Commissioner's Office. If you are in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

11.2 Complaining to us first

You can complain directly to us before going to a regulator, and we would appreciate the chance to put things right. Contact us online at our support form, by email at info@kaizenhealth.io, or by post at the address in section 18. We will acknowledge your complaint within 30 days, investigate without undue delay, keep you informed of progress, and explain the outcome. For UK users, this is in addition to your rights under the UK GDPR and the Data Protection Act 2018.

11.3 Withdrawing your consent

Where we rely on your consent, including explicit consent for health data, you can withdraw it at any time by contacting us using the details in section 18, or by turning off the relevant feature or device permission. Withdrawal does not affect the lawfulness of processing before it, nor processing we carry out on another lawful basis.

11.4 Opting out of marketing

You can unsubscribe from marketing messages at any time using the link in any marketing email, or by contacting us. You will then be removed from our marketing lists. We will still send service-related messages necessary for the administration of your account, responses to your requests, and security notices.

11.5 Account information and other controls

• Review and edit: view and correct your profile, records, documents, and health-fact memories in the App at any time.
• Export: request a machine-readable copy of your data by contacting us.
• Withdraw device permissions: revoke access to Apple Health, Health Connect, contacts, location, camera, microphone, and notifications in your device settings, or in the App.
• Turn off analytics: disable analytics collection in the App's privacy settings, and use the browser controls described in section 5 for the website.
• Stop sharing: turn off group sharing or leave a care group at any time.
• Terminate your account: see section 19.

12. Controls for Do-Not-Track and Global Privacy Control

Most browsers and some mobile operating systems offer a Do-Not-Track ("DNT") setting. No uniform technology standard for recognizing and implementing DNT signals has been finalized, so we do not currently respond to DNT browser signals. If a standard is adopted that we must follow, we will update this Notice.

We do honor Global Privacy Control (GPC) signals as a valid opt-out preference signal where applicable law requires it. Because we do not sell personal information or share it for cross-context behavioral advertising, a GPC signal does not change how we handle your data, but we recognize and respect it.

13. Do United States residents have specific privacy rights?

In Short: If you live in a US state with a comprehensive privacy law, you may have rights to access, correct, delete, and obtain a copy of your personal information, and to withdraw your consent.

This section applies if you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, or another state with a comparable law. These rights may be limited in some circumstances by applicable law.

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve months. For the full detail, see section 1.

Retention depends on the feature and category, including the separate WhatsApp periods in section 8. We may also collect personal information outside these categories when you interact with us through customer support, surveys, or in the course of delivering the Services and responding to your inquiries.

We collect sensitive personal information, including health information and precise geolocation where you permit it. We use it only to provide the Services you requested and for the purposes permitted by law. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you for advertising. You may have the right to limit our use and disclosure of your sensitive personal information.

Sale, sharing, and disclosure

We have not sold personal information, and we have not shared it for cross-context behavioral advertising, in the preceding twelve months. We will not do so in the future, and we do not knowingly sell or share the personal information of anyone under 16. We do disclose personal information to the service providers named in section 4.2 for business purposes, under written contracts that restrict what they may do with it. Using your information for our own internal research and technological development is not a sale.

Your rights

• Right to know whether we are processing your personal data.
• Right to access your personal data and details about how we have processed it.
• Right to correct inaccuracies.
• Right to delete your personal data.
• Right to obtain a copy of the data you previously shared with us.
• Right to non-discrimination for exercising your rights.
• Right to opt out of processing for targeted advertising, sale, or profiling with legal or similarly significant effects. We do not carry out any of these activities.
• Right to limit the use and disclosure of sensitive personal data (California).
• Right to a list of categories or specific third parties to which we have disclosed personal data, where your state law provides it (including California, Delaware, Maryland, Minnesota, and Oregon).
• Right to review, understand, and question profiling (including Connecticut and Minnesota).
• Right to opt out of the collection of sensitive data and data collected through a voice or facial recognition feature (Florida).

Washington, Nevada, and consumer health data

Under the Washington My Health My Data Act and Nevada SB 370, consumer health data receives specific protections. Our separate Consumer Health Data Privacy Policy describes the categories, sources, purposes, recipients, and ways to exercise your rights, including for WhatsApp audio, transcripts, and replies. We do not sell consumer health data. Where separate consent to collection or sharing is required, acceptance of general Terms does not replace that consent.

California Confidentiality of Medical Information Act

We handle medical information in line with the California Confidentiality of Medical Information Act, which applies to businesses offering health applications to California residents.

California "Shine The Light" law

California Civil Code Section 1798.83 permits California residents to request, once a year and free of charge, information about the categories of personal information we disclosed to third parties for their direct marketing purposes, and the names and addresses of those third parties. We do not disclose personal information to third parties for their own direct marketing purposes. To make a request, contact us using the details in section 18.

How to exercise your rights

Use our support form, email info@kaizenhealth.io with "Data Rights Request" in the subject line, or write to us at the address in section 18. We acknowledge requests within 10 business days and respond within 45 days, extending once by a further 45 days where necessary and telling you if we do.

Authorized agents. You may designate an authorized agent to make a request on your behalf. We may deny a request from an agent who does not submit proof of valid authorization, and we may need to collect additional information from you to verify your identity.

Request verification. We will need to verify your identity before acting on a request. We use the personal information in your request only to verify your identity or authority. If we cannot verify you from the information we already hold, we may ask for additional details for verification and fraud-prevention purposes.

Appeals. If we decline to act on your request, you may appeal by emailing info@kaizenhealth.io with "Privacy Request Appeal" in the subject line. We will inform you in writing of any action taken or not taken, with our reasons. If your appeal is denied, you may submit a complaint to your state attorney general.

14. International data transfers

Our backend application servers are hosted on Amazon Web Services. Your account data, health records, and uploaded documents are stored on Google Cloud and Firebase infrastructure, and health-fact memories and their vector embeddings are stored on Supabase. This infrastructure is located in the United States, and our service providers are located primarily in the United States.

WhatsApp audio, transcripts, and replies can also pass through Meta and Google infrastructure outside your country. Google Speech-to-Text's default processing is global, even if other Kaizen data is stored in the United States. A provider's regional endpoint, where supported, limits only the processing covered by that endpoint; it does not localize the entire WhatsApp and AI service. We apply applicable transfer restrictions and contractual safeguards. Consent to use a feature does not waive mandatory transfer protections.

If you use the Services from outside the United States, your information will be transferred to and processed in the United States, which may have different data protection laws than your country. For transfers of personal data out of the EEA, the United Kingdom, or Switzerland, we rely on the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum where applicable), together with additional technical and organizational safeguards. You can request a copy of the relevant transfer mechanism by contacting us.

15. Automated processing

Two features process your data automatically: your health score, which compares metrics such as age, sex, height, weight, step count, and resting heart rate against published population averages (see how the health score is calculated), and our AI features, which generate summaries and responses. Neither makes decisions about you that have legal effects or similarly significant consequences, and neither is used to determine eligibility for insurance, credit, employment, or care. If a decision producing legal or similarly significant effects were ever made solely by automated means, we would tell you, explain the main factors, and offer a simple way to request human review. You can ask us to explain a result, contest it, or stop using these features.

16. Health privacy laws and our status

We apply HIPAA-aligned administrative, technical, and physical safeguards to health information. Kaizen Health is a direct-to-consumer service, so when you use it on your own behalf we are generally not acting as a HIPAA covered entity or business associate, and the health information you give us is not protected health information under HIPAA. Instead, it is protected by this Notice, by the consumer health privacy laws described in section 13, and by the FTC Health Breach Notification Rule. Where we provide services on behalf of a HIPAA covered entity, we act as a business associate under a written agreement and HIPAA applies to that processing.

Being in the United States or sending health information does not by itself make your use subject to HIPAA. A Google Cloud BAA does not cover WhatsApp (Meta) or every AI service. The WhatsApp channel is not offered as a channel for HIPAA-regulated care on behalf of a provider or health plan. A BAA with one vendor is not a guarantee of compliance for the whole channel.

17. Do we make updates to this Notice?

Yes. We update this Notice as necessary to stay compliant with relevant laws and to reflect changes to the Services. When we do, we will change the "Last updated" date above. If a change materially affects how we handle your personal or health data, we will notify you in the App, on WhatsApp, or by email before it takes effect, and where the law requires it we will ask for your consent. For the introduction of WhatsApp voice transcription, existing WhatsApp users must accept an updated WhatsApp consent notice before we process voice audio. Posting this Notice or continuing to send messages does not replace that agreement. Voice notes remain optional. Previous versions are available on request.

18. How can you contact us about this Notice?

Kaizen Healthcare Inc
1875 Mission St Ste 103
San Francisco, CA 94103
United States
info@kaizenhealth.io

For privacy questions, put "Privacy Question" in the subject line. For rights requests, see section 13.

India Grievance Officer: Snehal Shah, snehal@kaizenhealth.io. Privacy grievances are addressed within one month of receipt.

19. How can you review, update, or delete the data we collect from you?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correction of inaccuracies, and deletion. You can delete your account and its data at any time, using any of these methods:

• In the App, under profile settings. (Recommended, because it takes effect immediately.)
• Through our support form, selecting "Account & Data Deletion".
• By emailing info@kaizenhealth.io from the address on your account, with "Account & Data Deletion" in the subject line.

WhatsApp controls. Send DELETE MY DATA to start the account deletion flow and complete its verification and confirmation steps. Unlinking WhatsApp removes the WhatsApp chat thread, saved voice transcripts, and delivery-retry replies. Unlinking can let you keep health records and documents already saved to your Kaizen account; use the deletion option if you also want those removed. Account deletion removes account records through the deletion flow. STOP pauses WhatsApp interactions and does not delete data. Neither unlinking nor account deletion removes copies in your own WhatsApp history, device backups, or Meta's independently controlled systems; use WhatsApp's own controls for those copies. Contact us if you need help exercising deletion rights.

What deletion removes: your profile and account record, your health records and entries, uploaded documents and media, your health-fact memories and their embeddings, your group memberships and invitations, your stored device push tokens, and your sign-in credentials. Deletion is permanent and cannot be undone. We complete deletion immediately for in-app requests, and within 30 days for requests sent by email or through support.

What may remain, and why: encrypted backups until the rotation described in section 8; aggregated or de-identified statistics that can no longer be linked to you; transaction and tax records we are legally required to keep; records we must retain to prevent fraud, resolve a dispute, assist an investigation, or enforce our legal terms; content you shared into a care group that other members have already saved or exported; and short-lived diagnostic logs held by our analytics and error-monitoring providers, which age out on the schedules in section 8. Limited WhatsApp consent and deletion receipts follow the separate retention period in section 8. Where applicable law requires, we also notify processors and other recipients of your deletion request.

Deleting your Kaizen Health account does not cancel your Apple or Google subscription. Cancel that in your App Store or Google Play account settings.