Privacy Policy

Effective Date: April 21, 2026

This Privacy Policy describes how Clarity Health Innovations Inc., a California corporation ("Clarity," "we," or "us"), collects, uses, and shares information in connection with the CosignMD platform available at cosignmd.ai and app.cosignmd.ai (the "Service").

CosignMD is a workflow tool for licensed physicians. This policy governs information about the physicians and practices that use the Service ("Users"). Protected Health Information ("PHI") about the patients of our Users is handled under the Business Associate Agreement, which controls over this policy with respect to PHI.

1. Information We Collect

Information you provide:

Account information: email address, display name, medical specialty, hospitals, personal and office phone numbers, NPI, DEA, and state license (if provided for prescription features).
Authentication: magic-link verification codes, PIN hashes, and (if enrolled) passkey credentials.
Payment information: billing details are collected and processed by Stripe. We do not store full card numbers; we retain Stripe customer and subscription identifiers.
Content you generate: clinical notes, billing codes, facesheet captures, voicemails, SMS, prescriptions, and other content you create while using the Service. This content frequently contains PHI and is governed by the BAA.
Support communications: messages you send to us, including in-app feedback submitted through the Service.

Information collected automatically:

Usage and device data: pages and features used, timestamps, browser type, operating system, and approximate location inferred from IP address.
Audit logs: we record authentication events and access to PHI in an immutable audit log, including User ID, action, resource type, timestamp, and IP address.
Error and performance data: diagnostic information captured via Sentry with PHI-scrubbing filters applied before transmission.
Local storage: the Service stores authentication tokens, PIN hashes, cached patient data, and preferences in your device's local storage and IndexedDB to support offline use.

2. How We Use Information

To operate, maintain, and improve the Service, including multi-device synchronization.
To authenticate you and secure your account, including rate-limiting and fraud prevention.
To process payments and manage subscriptions.
To provide AI-assisted features (note drafting, billing code suggestions, voicemail transcription, facesheet extraction). AI output is advisory; the physician confirms all clinical and billing decisions.
To send service-related communications (magic-link codes, receipts, security alerts, product updates).
To comply with legal, regulatory, and audit obligations, including HIPAA.
To detect, investigate, and respond to security incidents.
To produce de-identified, aggregated statistics about Service usage. De-identification follows 45 CFR 164.514.

We do not sell personal information. We do not use PHI for marketing or advertising.

SMS messaging. If you provide your mobile number or claim a CosignMD-hosted office number, we use SMS for authentication codes and clinical-workflow notifications (patient-communication alerts, voicemail, billing summary, STAT alerts, account/security messages). Message frequency varies. Reply STOP to unsubscribe and HELP for help. See the SMS Terms for the full list of message categories, opt-out keywords, and the platform-wide opt-out registry.

3. How We Share Information

We share information only as described below:

Recipient	Purpose	PHI?
Anthropic (Claude API)	AI clinical reasoning and note generation	Yes — under BAA
Deepgram	Medical speech-to-text transcription	Yes — under BAA
Neon	PostgreSQL database hosting	Yes — under BAA
Amazon Web Services	Compute (ECS Fargate), object storage (S3), Secrets Manager	Yes — under BAA
Twilio	Voice, SMS, fax (HIPAA conduit)	Transits — conduit exception
Stripe	Subscription billing and payment processing	No — billing data only
Sentry	Error monitoring (PHI scrubbed before transmission)	No — PHI scrubbed
SMTP provider	Magic-link and transactional email	No — email address and verification code only

We may also share information: (a) with your consent; (b) to comply with law, legal process, or lawful government requests; (c) to protect the rights, property, or safety of Clarity, our Users, or others; and (d) in connection with a merger, acquisition, or sale of assets, subject to the protections of this policy.

4. Security

All data is transmitted over TLS 1.2 or higher.
Database (Neon Postgres) and object storage (AWS S3) are encrypted at rest using AES-256.
API keys are never transmitted to the browser; all sensitive third-party calls are proxied through our server.
Authentication uses magic-link email with short-lived JWT sessions (4-hour expiry, auto-refresh). Device PIN lock enforces a 5-minute inactivity timeout.
Rate limiting, brute-force protection, and server-side session revocation are enabled on authentication endpoints.
Access to PHI is scoped per User and recorded in the audit log.

No method of transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your login credentials and device.

5. Data Retention

Account data: retained while your account is active and for a reasonable period afterward to comply with legal, audit, and dispute-resolution obligations.
Patient data (PHI): retained per the BAA. Census snapshots are retained for 90 days as a recovery tool. Patient records are soft-deleted and recoverable.
Audit logs: retained to support HIPAA accounting-of-disclosures obligations (up to six years).
Magic-link codes: expire after 10 minutes.
Twilio call recordings: transferred to our S3 storage and deleted from Twilio.
Webhook event records: Stripe webhook event IDs retained 30 days for idempotency.

6. Your Choices and Rights

Access and export: you may request a copy of your account data or export your census data from within the Service.
Correction: you may update your profile, hospitals, and contact details in Settings.
Deletion: you may request account deletion at info@clarityhealthinnovations.com. Account deletion snapshots your patient data, cancels your subscription, revokes all sessions, and suspends the account. Residual data required by law or by the BAA may be retained.
Marketing: transactional emails cannot be opted out of while your account is active; any future marketing emails will include an unsubscribe link.
Do Not Track: we do not respond to Do Not Track signals.

Residents of California, the EEA, the UK, and other jurisdictions may have additional rights, including the right to object to or restrict processing, the right to data portability, and the right to lodge a complaint with a supervisory authority. Contact us to exercise these rights.

7. HIPAA and Covered Entities

If you are a Covered Entity or the workforce member of a Covered Entity, your use of the Service with PHI is governed by the Business Associate Agreement. In the event of a conflict between this Privacy Policy and the BAA with respect to PHI, the BAA controls.

8. Children

The Service is for use by licensed healthcare providers and is not directed to individuals under 18. We do not knowingly collect personal information directly from children. Physicians may enter clinical data about pediatric patients pursuant to their own legal authority as healthcare providers.

9. International Users

The Service is operated from the United States. If you access the Service from outside the United States, you consent to the transfer and processing of your information in the United States, where privacy laws may differ from those of your country.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified by email or through the Service. Your continued use of the Service after the effective date of an updated policy constitutes acceptance of the changes.

11. Contact

Clarity Health Innovations Inc.
Privacy Officer: Dr. Alfredo Lee Chang, MD
Email: info@clarityhealthinnovations.com
Web: cosignmd.ai