Privacy and Security Notice

This notice describes how medical information about you may be used and disclosed and how you can get access to this information.

Please Review It Carefully.

Material Changes From Prior Version

May 23, 2026:

Added ONC Model Privacy Notice and CARIN Code of Conduct as development references
Clarified that account registration accepts either an email address or a phone number, and that Clerk handles account authentication
Added "What's Required to Use Doctronic, and What's Up to You" distinguishing required vs. optional data uses
Added "How We Retrieve Records From Other Providers" disclosing both patient-initiated and treatment-pathway TEFCA/Carequality retrievals, with revocation mechanism
Added "One-Time vs. Ongoing Collection" subsection
Added "Where Your Information Comes From" data provenance disclosure
Added "When Sharing Affects Others" addressing genetic and family medical history
Added "Reporting Inaccurate or Incomplete Information" and "How Corrections Flow" subsections
Expanded deletion language to specify 7-year retention and locked-state treatment
Added "If Doctronic Is Sold, Merged, or Shut Down" successor-entity language
Corrected multi-factor authentication description in Security Practices
Added references to HHS OCR and ONC consumer guidance

May 4, 2026:

Clarified that "targeted advertising" restrictions refer to sharing health data with third-party advertising platforms, and do not restrict treatment-related communications we send directly to you about your care

March 16, 2026:

Added "Information We Collect" section with explicit enumeration of data types
Added "Identity Verification Providers" section detailing CLEAR and Verified
Added "Treatment-Related Communications" section covering SMS, email, and app notifications
Added "AI Processing" disclosure confirming all AI inference runs within Doctronic's private cloud
Updated "Security Practices" to reflect multi-cloud infrastructure (AWS, Azure, GCP)
Updated "We Do Not" list to explicitly state health data is not sent to external AI providers
Updated vendor management language to specify equivalent safeguard requirements
Added "TEFCA Exchange Type" disclosure
Added "How to Revoke Your Consent" with step-by-step instructions

At Doctronic, accessible from https://www.doctronic.ai, we protect your privacy. This Privacy and Security Notice explains how we collect, use, share, and protect your information when you use our website, mobile app, and services. This Notice was developed using the ONC Model Privacy Notice and the CARIN Code of Conduct for Consumer-Facing Applications as references.

For users with member accounts accessing health records through our Individual Access Services ("IAS"), this Notice also incorporates requirements under the Trusted Exchange Framework and Common Agreement (TEFCA) and the CMS Interoperability and Patient Access Rule.

We do not sell your health information. We do not share your health information with third-party advertising platforms or use it to target advertising on external websites or apps. We may, with your authorization, use your health information to send you treatment-related communications about your care, as described below. Your health information belongs to you -- you control it. You can access it anytime, download it, share it with other providers, or delete it as you choose.

📋 Service Types and Information We Share

Anonymous Usage (No Account)

No account or personal information (other than age and sex if prompted) is required
Minimal technical data for functionality: browser type, session cookies
Health conversations not linked to any identity
Session data disconnected immediately upon closing browser or logging out
Not covered by HIPAA (no stored protected health information)
Truly anonymous -- we cannot identify you

Member Accounts

Requires registration with personal information
Stores your health information and medical history ("Individually Identifiable Information" or "III")
Full HIPAA and TEFCA protections apply
Persistent access to your records
Enhanced features including care coordination and prescription services

How We Use and Share Your Information

We may access, use, exchange, and disclose your III:

For providing IAS: To help you securely access your medical records, send and receive health information, and share with authorized parties.
With third parties: Only with your consent or as required by law.
For required reporting: As permitted or required under TEFCA and applicable law.
No sale or advertising use: We do not sell your III. We do not use your III for marketing or targeted advertising. If this practice were ever to change, we would obtain your separate, express "Consent to Sale" before doing so (see Section 11).
Retention: We retain your III only as long as necessary to fulfill the purposes described here or as required by law.
De-identified information: If we de-identify your III, we may use or disclose it for research, analytics, or service improvement.

We will never use your III to make claims against you, except for collection of fees you owe.

What's Required to Use Doctronic, and What's Up to You

The only information we require to create a Doctronic member account is an email address or a phone number, which we use to identify and contact you about your account.

Everything else is optional. You decide whether to:

Share symptoms, health history, or other medical information with our AI or providers
Consent to treatment data import from other providers via HIE networks
Verify your identity through CLEAR for accessing medical records or prescriptions
Receive treatment-related communications via SMS, email, or push notifications
Share data with family members, caregivers, or external providers you designate

Declining any optional use may affect specific features (for example, you can't access medical records from other providers without identity verification), but does not affect your ability to use Doctronic's core anonymous consultation service.

Automated Decision-Making

Doctronic uses AI to generate clinical assessments, differential diagnoses, treatment recommendations, and prescription renewal decisions. These outputs may have significant effects on your health care. You have the right to request human physician review of any AI-generated clinical decision at any time by contacting support@doctronic.ai. Human physician oversight is also built into our prescription renewal workflow as described in our service terms.

Age Requirement

You must be 18 or older to use Doctronic. We do not knowingly collect information from anyone under 18. If we discover underage usage, we immediately delete all associated data.

⚖️ Our Legal Status

We are a "Covered Entity" by law under HIPAA for member accounts that store protected health information. Even when HIPAA doesn't apply (such as anonymous usage), we follow equivalent or stronger privacy protections including consumer-protection and breach notification laws (including the FTC's Health Breach Notification Rule).

🔍 How We Use Your Information

For Healthcare Services

Process your symptoms and medical questions
Generate clinical summaries and doctor's notes
Coordinate care with Doctronic physicians
Manage prescriptions and referrals
Access and share medical records (only with your consent)
Verify your identity through third-party identity verification services to enable secure access to your health records and prescription services (see "Identity Verification Providers" below)

Example: Doctronic processes information you provide to format it in a way that is helpful for discussing with your doctor.

For Operations

Improve our AI doctor technology
Provide customer support
Process payments
Ensure platform security and prevent fraud
Develop new features

Example: We use health information to develop better ways of helping users communicate with their doctors and to improve our AI systems and services.

We maintain all consents in a secured auditable log to validate and verify.

We Do Not:

Train our AI models on your chat data or conversations
Send your health data to external AI providers (all AI processing occurs within our infrastructure)
Sell your information
Share your health data with third-party advertising platforms or use it to target advertising outside Doctronic's own treatment communications
Make insurance claims against you (except fee collection)

All disclosures through TEFCA are in accordance with the permitted and required Uses and Disclosures specified in the Common Agreement and applicable US Department of Health and Human Services guidance.

📀 Information We Collect

Information you provide directly:

Email address or phone number (account registration; either is sufficient)
Name, date of birth, address, sex, and gender (member profiles and identity verification)
Symptoms, health concerns, and medical history (AI consultations)
Payment information (processed by Stripe; we do not store card numbers)

Information collected from third-party sources (with your consent):

Prescription history (Surescripts)
Medical records (TEFCA/QHIN via MedAllies)
Identity verification results (CLEAR, Verified)
Apple HealthKit data (heart rate, blood pressure, sleep, activity)

Information collected automatically:

Device type, operating system, browser type
App usage and interaction data (e.g., screens visited, features used)
Session cookies and anonymous identifiers
IP address (used only for legal compliance with state/federal regulations; not stored for tracking)

One-Time vs. Ongoing Collection

Some information is collected only once and updated when you change it (for example, your name and date of birth at registration). Other information is collected when needed:

Medical records from HIE networks (TEFCA, Carequality) are retrieved either when you specifically request them or when we need them to support your care (see "How We Retrieve Records From Other Providers").
Prescription history is retrieved when needed to support your care.
App usage data is collected automatically while you are using Doctronic.

You can stop provider-initiated retrievals at any time through your account settings.

Analytics and Service Improvement

We collect anonymized app usage data (such as screens visited, features
used, and interaction patterns) to improve our services. This data is
processed by our analytics providers, which operate under agreements
requiring them to protect user data consistent with this Notice. Analytics data does not include protected health information.

Where Your Information Comes From

Your Doctronic record may combine information from several sources: data you provide yourself, encounter notes and clinical information from Doctronic providers, prescription history, and records from external HIE networks (including TEFCA and Carequality) when requested. Where it is technically possible, we keep a record of where each piece of information came from and display that source to you in your record.

🪪 Identity Verification Providers

To enable secure access to your health records and prescription services, we use third-party identity verification providers. These providers operate under Business Associate Agreements with Doctronic.

Clerk (Account Authentication)

We use Clerk to manage member account authentication (sign-up, sign-in, session management). Clerk is distinct from the identity verification providers described below: Clerk authenticates that you are the holder of your Doctronic account, while CLEAR and Verified perform identity proofing required for medical record access and prescription services. Clerk processes your email address or phone number (whichever you used to register) and authentication credentials, and operates under a Business Associate Agreement with Doctronic.

CLEAR

CLEAR (clearme.com) is used to verify your identity when you access your medical records through our Individual Access Services (IAS) under TEFCA, and may also be used for prescription renewal identity verification. When you verify through Clear, we transmit your name, date of birth, and address to CLEAR for identity matching. CLEAR returns a verification result (pass or fail). We store only the verified demographics and the verification result. CLEAR access tokens are discarded from memory immediately after verification is complete. We do not store CLEAR identifiers, CLEAR account metadata, or any biometric information. Clear's verification satisfies NIST IAL2 requirements for medical record access.

Verified

Verified (verified.inc) may be used for identity verification in connection with prescription renewal services. Verified receives your phone number and returns verified demographic information (such as name, date of birth, and address). We store the verified demographics returned by Verified in our system to support the prescription workflow. We do not store Verified account identifiers or tokens beyond what is necessary to complete the verification.

You are not required to use either verification service to access Doctronic's free anonymous AI consultation. Identity verification is required only for services that involve accessing your medical records or processing prescriptions.

How We Retrieve Records From Other Providers

We may obtain your medical records from outside providers through Health Information Exchange (HIE) networks, including TEFCA and Carequality. We do this in two ways:

At your specific request. When you ask us to retrieve a specific record on your behalf, we make the request through the HIE network. For this type of request, we verify your identity through CLEAR, which meets the NIST IAL2 standard required by federal rules.
To support your care. As your treating provider, we may also obtain records from your other providers through the HIE network's treatment exchange pathway when it supports the care we're providing to you. This pathway does not require identity verification of you, because the request is made by us as your treating provider. By creating a member account and consenting to treatment data import with Doctronic, you authorize us to obtain records under this pathway.

You may revoke your authorization for provider-initiated retrieval at any time through your account settings or by emailing privacy@doctronic.ai. Records obtained through either method become part of your Doctronic medical record.

Treatment-Related Communications via SMS, Email, and App Notifications

If you provide us with a phone number, email address, or enable app notifications, we may use those channels to send you treatment-related communications, including appointment reminders, medication follow-ups, prescription status updates, care coordination messages, clinically-indicated follow-up for conditions previously discussed with our AI or clinical team (including reminders for recommended monitoring, re-evaluation, or continued care based on our clinical guidelines), and other information related to your health care.

These communication channels are not fully secure. SMS, email, and push notifications are not encrypted end-to-end, and messages containing protected health information (PHI) may be intercepted in transit by third parties such as mobile carriers, email providers, or device manufacturers.

Categories we will NOT send via SMS, email, or app notifications: We will not transmit information about HIV/AIDS status, substance abuse treatment records, psychotherapy notes, reproductive health information, or genetic test results through these channels.

Consent. By providing your phone number, email address, or enabling app notifications, you authorize Doctronic to send treatment-related communications containing PHI through these channels. This authorization is voluntary. You may revoke this authorization at any time by emailing our Privacy Officer at privacy@doctronic.ai. Please note that if you revoke authorization for treatment-related messages, it may affect our ability to coordinate your care, send medication reminders, or communicate time-sensitive health information.

Revocation of this authorization does not affect communications sent before your revocation was processed.

This authorization for treatment-related communications is separate from any consent for promotional or marketing messages, which is governed by applicable telecommunications law and may be managed independently.

Only With Your Express Consent

Your designated healthcare providers
Family members or representatives you authorize
Third parties you specifically approve
Any sharing beyond what's described in this Notice

Never Shared Without Written Permission

Sale of your information
Therapy notes and psychotherapy notes
Your health information with third parties for their marketing purposes

Please note that some states have therapy chatbot restrictions and additional regulations governing mental health services. Doctronic complies with all applicable state and federal laws regarding mental health and therapy services, and we do not provide services that are prohibited by law in your jurisdiction.

As Required by Law

Court orders, subpoenas, search warrants
Public health emergencies
Preventing imminent serious harm
Government compliance audits

Note: For anonymous users, we have no identifying information to share even if compelled by law.

When we receive a subpoena, court order, search warrant, or other legal demand for your information, we will notify you within 3 business days of receipt (unless prohibited by law, e.g., under the Patriot Act), giving you an opportunity to object or seek a protective order before disclosure. We will also notify you within 3 business days if we make your information available to law enforcement, including through any sale of individually identifiable data.

For Healthcare Operations

Contracted medical professionals reviewing for quality (bound by confidentiality)
HIPAA-compliant service providers (hosting, payment processing)
Healthcare networks for care coordination (TEFCA exchanges) -- only with your consent
Identity verification providers to confirm your identity for medical record access and prescription services (see "Identity Verification Providers" above)

Some health information you share with us also describes other people. Genetic test results, family medical history, and infectious disease records can reveal information about your relatives or close contacts, even though they have not consented to share it. Before sharing this kind of information with another provider, family member, or third party through Doctronic, consider whether the people described in your records would want that information disclosed. We treat genetic test results and family medical history as we do with all sensitive information and do not transmit them through unsecured channels.

Sensitive Health Information

Certain sensitive information (reproductive health, mental health, substance use, gender affirming care) receives extra protection. We only disclose when required by law and notify you within 3 business days unless prohibited.

For anonymous users, this protection is absolute -- we have no way to identify or disclose your information.

Emergency Situations

In emergency situations or if we believe there is a serious and imminent threat to health or safety, we may share your information when necessary to prevent harm to you or others. We may take appropriate action to protect you, other individuals, or the public, which may include sharing information with emergency services, law enforcement, or healthcare providers without your prior consent. This exception applies only in circumstances where we reasonably believe immediate action is required to prevent serious harm.

✅ Your Rights

Access and Control Your Information

You have the right to:

View your medical records anytime (member accounts)
Update or correct your information
Download data in machine-readable format
Explicit right to opt out of TEFCA sharing

Deleting Your Information

You have the right to ask us to delete information we hold about you. We will delete information that is not subject to legal retention requirements (such as account profile and preferences). We are legally required to retain your medical records, AI clinical summaries, prescription records, and audit logs for at least 7 years (or longer where state law requires). When we cannot delete, you may still close your account, and the retained information is locked from further active use and destroyed at the end of its required retention period.

Reporting Inaccurate or Incomplete Information

Some of the information in your Doctronic record comes from outside sources — hospitals, pharmacies, and HIE networks.

If you notice information that appears wrong, out of date, or incomplete:

For records from a hospital, clinic, or health plan: the source organization is the right place to request a correction. Under HIPAA, you have the right to request corrections to records held by health care providers and health plans. Email privacy@doctronic.ai if you need help identifying the source.
For information Doctronic entered or generated: email privacy@doctronic.ai and we will review and correct as appropriate.

How Corrections Flow

When information in your Doctronic record needs to be corrected, email support@doctronic.ai. Corrections we make apply to your Doctronic record only. We do not correct records held outside Doctronic, and we cannot update copies that were previously shared with third parties at your direction. To correct records held by an outside organization, contact that organization directly.

Privacy Choices

Request restrictions on how we use your information
Choose communication preferences
Designate someone to act on your behalf
Object to specific uses of your data

Transparency

Receive breach notifications (members only -- anonymous users cannot be notified)
Get copy of this Notice
File complaints without retaliation

TEFCA Exchange Type

Request-Only IAS Provider

Doctronic does not provide bidirectional services. You will have the ability to request access to your health information via TEFCA exchange. You will not be able to use Doctronic to share your health information with other participants in TEFCA.

Response time: 30 days for most requests

⚙️ Managing Your Preferences

To revoke consent, modify communication preferences, request restrictions on data use, or exercise any of your rights described in this Notice, email our Privacy Officer at privacy@doctronic.ai. You may also contact us by phone at (212) 287-5081 or by mail at the address below. We will process your request within 30 days and confirm completion by email or mail.

🔒 Security Practices

Protection: Doctronic uses commercially reasonable efforts to protect III from unauthorized or illegal access, modification, Use, or destruction.
Encryption: All data encrypted in transit and at rest
Access Controls: Role-based permissions; multi-factor authentication available to users; identity verification through CLEAR (meeting NIST IAL2) required for medical record access from outside providers and for prescription services
Monitoring: 24/7 security monitoring and threat detection
Infrastructure: HIPAA-compliant cloud infrastructure (AWS, Microsoft Azure, Google Cloud Platform), all covered by Business Associate Agreements
AI Processing: All AI model inference runs within Doctronic's private cloud infrastructure. No protected health information is transmitted to external AI model providers.
Vendor Management: Partners sign Business Associate Agreements and are required to implement administrative, technical, and physical safeguards equivalent to those we maintain, including encryption at rest and in transit, access controls, and breach notification obligations. We conduct reasonable due diligence on third-party security practices before sharing individually identifiable information. All third parties that receive user data, including analytics providers, payment processors, identity verification services, and healthcare network partners, are contractually required to provide the same or greater protection of user data as described in this Notice.

Obligations under this Notice continue for as long as information is maintained.

🚨 Breach & Security Incident Notification

Doctronic will notify individuals whose III has been or is reasonably believed to have been affected by an IAS TEFCA Security Incident or Breach of Unencrypted III. We will notify you promptly and include:

A description of what happened and when.
What types of information was involved.
Steps you can take to protect yourself.
Actions we are taking to address it.
How you can contact us for more information.

Compliance with Privacy and Security Requirements

Pursuant to Section 4.1.a.5 of the IAS Provider Requirements SOP, Doctronic affirms that it is required to act in conformance with the Privacy and Security Notice and to protect the security and confidentiality of all information it holds in accordance with the applicable Framework Agreement.

Doctronic shall implement and maintain administrative, technical, and physical safeguards consistent with industry standards and the Framework Agreement to ensure the integrity, availability, and confidentiality of all data received, maintained, or transmitted under its services.

For questions regarding our privacy or security practices, you may contact us at privacy@doctronic.ai.

For Member Accounts

We obtain documented consent before:

Creating your account and storing health information
Sharing data beyond what's described here
Making material changes to privacy practices

Consent to Sale

We do not sell your III, use it for targeted advertising, or receive payment in exchange for it. If this practice were ever to change, we would obtain a separate Consent to Sale from you, clearly labeled and distinct from this Notice, before doing so. You would not be required to provide such consent to continue using our IAS.

You have the right to revoke your consent for data sharing or use at any time, including consent for accessing your health records through TEFCA Individual Access Services.

Step 1: Email our Privacy Officer at privacy@doctronic.ai or call (212) 287-5081. Include your full name and the consent(s) you wish to revoke.

Step 2: You will receive written acknowledgment within 5 business days.

Step 3: Your revocation will be processed and confirmed in writing within 30 days.

Revocation takes effect upon processing. It does not affect uses or disclosures made before your revocation was processed. Revoking IAS consent will end your ability to access medical records through TEFCA. Revoking account consent will end account access.

For general customer support, please call (415) 340-2274 or email support@doctronic.ai.

🗂️ Data Retention

Anonymous Sessions: Disconnected immediately when browser closed or logged out
Member Health Records: 7 years (per medical record requirements and TEFCA IAS obligations)
Account Deletion: Processed within 30 days
Legal Holds: Some data retained if required by law (members only)

If Doctronic Is Sold, Merged, or Shut Down

If Doctronic is acquired by another company, merges with another business, or stops operating, your information may be transferred to a successor organization. The successor organization will be required to follow privacy and security commitments at least as protective as those in this Notice.

Dormant Accounts

An account with no login activity for 24 months is considered dormant. We will send one email notification to your registered address 30 days before deactivation. If no action is taken, your account will be deactivated (login disabled). Underlying health records are retained per our standard 7-year retention schedule and are not deleted upon deactivation. You may reactivate at any time by logging in and confirming consent to the then-current privacy policy. To request full data deletion of a dormant account, contact privacy@doctronic.ai.

Digital Contact Information

To support nationwide interoperability, we have secure digital contact methods.

Purpose: For use by other providers, hospitals, and health information networks to securely send referrals, event notifications, and protected health information (PHI).
Security: Our digital contact method is HIPAA-compliant and encrypted to protect PHI in transit.

Technical Details

Cookies and Web Beacons

Like any other website, Doctronic uses cookies. These cookies are used to store information including visitors' preferences and the pages on the website that the visitor accessed or visited. The information is used to optimize the users' experience by customizing our web page content based on visitors' browser type and other information.

Log Files

Doctronic follows a standard procedure of using log files. The information collected by log files includes internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. We may use IP addresses for legal compliance with state and federal laws, but we do not log or use IP addresses for tracking, marketing, or other purposes. These log files are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, and gathering demographic information.

Cookies and Tracking

Essential cookies for security and preferences
Analytics to improve services (anonymized)
Advertising cookies for marketing attribution (anonymous users only -- no health data)
No IP address collection for tracking purposes (IP addresses may be temporarily checked to comply with state-specific regulations, but are not stored)

Communications

Secure in-app messaging
Optional SMS (text STOP to opt out)
No unencrypted email for health information, except as authorized by you (see "Treatment-Related Communications" above)

SMS and Text Messaging

We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your personal data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

Treatment-related SMS messages (appointment reminders, medication follow-ups, care coordination) are governed by the HIPAA authorization described in the "Treatment-Related Communications" section of this Notice. Promotional and marketing SMS messages are governed by applicable telecommunications law, including the Telephone Consumer Protection Act (TCPA), and require separate consent at the time your phone number is collected.

Marketing and Advertising

We use ads for marketing purposes. Advertising platforms may receive anonymous tracking data and marketing attribution information to measure campaign effectiveness. No protected health information or member account data is ever shared with advertising platforms. We do not share your health information with third-party advertising platforms or use it for advertising on external sites or apps. Treatment-related communications we send you directly about your care are governed by the "Treatment-Related Communications" section above and are not advertising.

Special Provisions

For California Residents (CCPA)

Right to know what personal information we collect
Right to delete (with exceptions)
Right to opt-out of sale (we don't sell, but certain advertising tracking may qualify as "sale" under some laws -- contact us to opt out)
No discrimination for exercising rights

For Areas with Consumer Health Data Laws

Please see our Consumer Health Data Privacy Policy for additional information about the processing of your Consumer Health Data, and your rights under applicable Consumer Health Data Privacy laws.

For European Union Residents (GDPR)

Every user is entitled to the following data protection rights:

Right to Access: Request copies of your personal data
Right to Rectification: Request correction of inaccurate or incomplete information
Right to Erasure: Request deletion of your personal data under certain conditions
Right to Restrict Processing: Request restricted processing under certain conditions
Right to Object to Processing: Object to our processing under certain conditions
Right to Data Portability: Request transfer of data to another organization or directly to you

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us using the information provided at the end of this notice.

For Healthcare Providers (Interoperability)

NPPES-listed digital contact for secure messaging
TEFCA-compliant health information exchange
FHIR API access for authorized applications

Changes to This Notice

We'll notify you of material changes via:

Email (members only -- anonymous users have no contact info)
Website banner (30 days)
New consent for significant changes

Changes are posted no later than the effective date of the change.

Fees

We will clearly disclose any fees associated with our IAS or with exercising your rights. Current fees: "None".

📞 Contact Us

Doctronic Inc.
1460 Broadway
New York, NY 10036

Email: support@doctronic.ai
Phone: (415) 340-2274

For privacy related issues only you may contact our Privacy Officer via the mailing address above or (212) 287-5081 or privacy@doctronic.ai.

For general information about your rights and what to consider before sharing health data, see the HHS Office for Civil Rights guidance at hhs.gov/hipaa/for-individuals and ONC consumer guidance at healthit.gov/topic/patient-access-information.

File a Complaint

With us: privacy@doctronic.ai
With government: HHS Office for Civil Rights (1-877-696-6775)

We document all privacy complaints and their final disposition. We will also never retaliate.