Privacy Policy

Last updated: October 23, 2026

This Privacy Policy describes how Medis Labs, Inc. (“Welle,” “we,” “us,” or “our”) collects, uses, shares, and otherwise processes personal information when you use the Welle platform at app.wellehealth.com, our mobile apps, and the services delivered through them (together, the “Service”). The technology platform underlying the Service is provided by Medis Labs, Inc. (“Medis Labs”), which processes information on our behalf and coordinates the laboratory testing available through the Service.

Scope of this Privacy Policy. This Privacy Policy applies only to information collected through the Service. It does not apply to any marketing website, blog, social media presence, or other property we operate separately from the platform at app.wellehealth.com, which is governed by its own privacy policy.

This Privacy Policy works alongside our Terms and Conditions and our Consumer Health Data Privacy Policy. The Consumer Health Data Privacy Policy supplements this Privacy Policy and applies to information that is “consumer health data” under U.S. state laws, including the Washington My Health My Data Act, the Nevada Consumer Health Data Privacy Act, and the Connecticut Data Privacy Act.

Protected health information is governed separately. The medical groups that provide your care, OpenLoop Healthcare Partners, PC and its affiliated and contracted professional entities (the “Medical Groups”), are covered entities under the Health Insurance Portability and Accountability Act (“HIPAA”). Information created or received to provide your care, such as intake answers, lab results, clinical notes, and prescriptions, is protected health information (“PHI”). It belongs to the Medical Groups and is governed by their Notice of Privacy Practices. We and Medis Labs handle PHI only as the Medical Groups’ business associates, and only as they permit. This Privacy Policy describes how we handle other personal information and how we protect all of the information we hold.

How we handle consumer health data. We collect, use, and share consumer health data only as necessary to provide the services you request through the Service, or with your separate consent where the law requires it. If a law requires your separate consent for a particular collection or sharing, we ask for it before that activity begins, and you may withdraw it as described in Section 7 and in our Consumer Health Data Privacy Policy.

Just-in-time disclosures. We may provide separate or supplemental privacy notices for specific products, services, partners, or features, including when we collect personal information for a specific purpose. For example, certain laboratory tests, such as the Galleri® Multi-Cancer Early Detection Test offered by GRAIL, come with test-specific patient information sheets and consents that you review and acknowledge when you order. Where a just-in-time disclosure or test-specific consent applies, it controls for the personal information it covers.

Your relationship with us. The personal information we collect depends on your relationship with us. If you represent a prospective business partner, we collect more limited business contact information than we do from someone who uses the Service for testing and clinical services.

Our privacy principles

• We do not sell your personal information.
• We don’t use your health information for marketing or advertising. Promotional messages are based only on your contact details and marketing choices, and we never share your health information with advertising platforms. If that ever changes, we will ask for your written authorization first, and accepting this Privacy Policy is not that authorization.
• No advertising tracking. We don’t use advertising pixels or advertising SDKs, and we don’t share your personal information with advertising platforms.
• No AI training on identifiable health information without your consent. Medis Labs may use de-identified data, which can no longer reasonably be linked to you, to develop and improve its technology, as described in Section 10.2.
• We limit what we collect and how long we keep it. We collect personal information to deliver the Service and keep it only as long as needed for the purposes in this Privacy Policy or as the law requires.
• We will not reduce your privacy rights retroactively. We will not change this Privacy Policy in a way that reduces your rights over personal information we previously collected, except where the law requires it or with your affirmative consent.

1. Information We Collect

We collect personal information from you directly, automatically when you use the Service, from third parties, and by generating it from other information.

1.1 Information you provide directly

• Identifiers and contact information: name, email address, mailing address, phone number, and date of birth.
• Account credentials: username, password, and other authentication information.
• Demographic information: age, gender or gender identity, sex assigned at birth, racial or ethnic identity, sexual orientation, and geographic location.
• Government-issued identification: where required for identity verification, fraud prevention, or compliance, identification numbers such as a driver’s license or state ID number, and an image of the document.
• Service-eligibility data: if your access is sponsored or provided through an employer, gym, health plan, or other Partner Organization (see Section 3.4), the organization’s name, your eligibility status, and a participant identifier.
• Payment information: payment method, billing address, and transaction details. Full card numbers are handled by our payment processor and are not stored on our servers.
• Health-related data: your health history, conditions, symptoms, diagnoses, treatments, medications, supplements, lifestyle, fitness, biomarkers, lab samples and results, medical images, clinical notes, and goals.
• Genetic data: if you use genetic testing through the Service, information about inherited characteristics. Genetic data is treated as a sensitive category of personal information with additional protections.
• Visit transcripts: when a telehealth visit uses Medis Labs’ visit tools, AI-enabled transcription processes audio in real time to help your Healthcare Provider document the visit. The audio is not kept. The text transcript is kept for quality review, as described in Section 6. Customer support calls may be recorded, with notice, for quality and training.
• Relationship data: information about family members, emergency contacts, or others whose information you provide in connection with the Service.
• User content: messages, files, photos, prior lab results, and other content you upload or share through the Service.
• Communications: the content of your communications with member support, your Healthcare Providers (where applicable), and others through the Service.

1.2 Information collected automatically

• Device and technical information: IP address, device identifiers, device type, operating system, browser type and version, language settings, and similar information.
• Usage information: screens viewed, features used, time spent, navigation paths, click and scroll behavior, search queries, and similar information about how you use the Service.
• Location information: approximate location derived from your IP address and, with your permission, precise location from your mobile device for specific features.
• Cookies and similar technologies: information collected through cookies and similar technologies that run the Service and measure its use. See Section 5.

1.3 Information from connected devices and third parties

• Wearable and connected device data: if you connect a wearable device or health app, such as Apple Health, Google Health Connect, Oura, or Garmin, we receive the biometric and activity data you authorize.
• Lab and clinical data: lab results flow into the Service from laboratories through Medis Labs, which coordinates testing under its laboratory agreements. Prescription information and clinical notes come from the Medical Groups, including from their own systems where a visit took place there. This information is PHI and is governed by the Medical Groups’ Notice of Privacy Practices.
• Single sign-on: if you sign in with a third-party identity provider, we receive the profile information your settings with that provider allow.
• Marketing and analytics partners: information that helps us understand how you found the Service and measure marketing effectiveness.

1.4 Information we generate or infer

We generate or infer information from the data above, including health insights, recommendations, scores, and analytics, to provide the Service to you. We and Medis Labs may also aggregate or de-identify personal information, including PHI de-identified under HIPAA’s standards, for purposes consistent with this Privacy Policy and applicable law.

2. How We Use Information

We use personal information to:

• Provide, maintain, and improve the Service, including troubleshooting and personalization.
• Coordinate with our clinical, laboratory, pharmacy, phlebotomy, imaging, and other partners to deliver the services you request.
• Communicate with you by email, text message, in-app message, and push notification about your account, lab results, appointments, prescriptions, and the Service.
• Send you promotional emails and, if you opt in, promotional texts about our products and services, based only on your contact details and marketing choices. Promotions about the Service may be sent under Welle Health or under our company’s other brands, and marketing sent under another brand is also governed by that brand’s own privacy policy. We do not use your health information for marketing without your written authorization.
• Process payments and manage Memberships and refunds.
• Verify your identity, prevent fraud, and protect the security of the Service and its users.
• Generate analytics and aggregated insights to operate and improve the Service.
• Conduct research and development, including with de-identified or aggregated information.
• Comply with the law, respond to legal process, and enforce our agreements.

3. How We Share Information

We share personal information only as described in this Privacy Policy, as you direct, or, for PHI, as the Medical Groups permit under HIPAA. We do not sell personal information or share it for targeted advertising. We may share de-identified or aggregated information, which can’t reasonably be used to identify you, with analytics and advertising partners.

3.1 Categories of recipients

• Clinical services providers: the Medical Groups and their licensed Healthcare Providers, who use information to deliver clinical services and coordinate care.
• Medis Labs: our technology provider, which operates the platform and coordinates laboratory testing, as described in Section 3.3.
• Laboratory partners: Quest Diagnostics, Labcorp, BioReference, US Specialty Labs, GRAIL (for the Galleri® test), and other laboratories that perform testing.
• Phlebotomy and specimen collection partners: in-home and partner-facility phlebotomy providers.
• At-home test kit partners: vendors that manufacture and ship at-home test kits.
• Imaging and functional testing partners: facilities that perform DEXA body composition scans (scheduled through BodySpec, Inc.’s system and performed at BodySpec locations), MRI, CT, ultrasound, coronary artery calcium scans, VO2 max testing, and similar services where available.
• Pharmacies: pharmacies that fill prescriptions written by Healthcare Providers.
• Lab data orchestration partners: service providers that route lab orders, results, and related clinical data among laboratory, clinical, and platform partners.
• Payment processors: Stripe, and OpenLoop Healthcare Partners, PC, whose merchant account processes payments for the Service and which bills medical services as the Medical Groups’ billing agent.
• Communications service providers: vendors that help send email, text messages, push notifications, and in-app messages.
• Cloud infrastructure providers: vendors that host the Service and provide databases, storage, and content delivery.
• AI service providers: the providers described in Section 10.
• Analytics and product intelligence providers: vendors that help us understand how the Service is used and improve it.
• Customer support and operations vendors: vendors that help with member support, fraud prevention, and operations.
• Partner Organizations: if your access is sponsored by an employer, gym, health plan, or other organization, as described in Section 3.4.
• Professional advisors: lawyers, accountants, auditors, and similar advisors.
• Affiliates: entities under common ownership or control with us.
• Corporate transactions: counterparties and their advisors in a financing, merger, acquisition, reorganization, sale of assets, bankruptcy, or similar transaction.
• Legal and law enforcement: where we believe disclosure is necessary to comply with the law, respond to valid legal process, or protect the rights, safety, or property of Welle, our users, or others.

Text messaging. We do not share your mobile number or text-messaging consent with any third party or affiliate for marketing or promotional purposes.

3.2 Service providers and sub-processors

We and Medis Labs work with third-party service providers and sub-processors to deliver the Service. Each must enter into contracts that protect your personal information consistent with this Privacy Policy and applicable law, including, where appropriate, Business Associate Agreements under HIPAA and data processing agreements under state privacy laws. For questions about a specific provider, or for a current sub-processor list, contact [email protected]. Adding, removing, or changing a sub-processor within an existing category is not a material change to this Privacy Policy unless it adds a new category of recipient or changes how previously collected personal information is used. See Section 12.

3.3 Medis Labs

Medis Labs provides the technology platform behind the Service, including the app, the electronic health record and visit tools Healthcare Providers may use, messaging, and lab ordering and results delivery. Medis Labs processes personal information on our behalf as our service provider, and handles PHI as a business associate of the Medical Groups. It uses your information to provide the Service and, once the information is de-identified as HIPAA allows, to develop and improve its technology, as described in Section 10.2. It does not sell your information. When you order lab testing, the Request for Release of Laboratory Results you accept names Medis Labs as your agent to receive your results from the laboratories.

3.4 Partner Organizations

Your access to the Service may be sponsored, subsidized, or provided through an organization you have a relationship with, such as an employer, gym, or health plan (a “Partner Organization”). A Partner Organization does not operate the Service or provide your clinical care. If one sponsors or provides your access:

• What we share: only what is reasonably needed to administer your eligibility and access, such as identifiers and contact information, enrollment and eligibility status, and aggregate or de-identified participation metrics. We do not share your clinical records, lab results, or other individually identifiable health information with a Partner Organization unless you specifically authorize it.
• How it uses the information: for its own purposes, such as administering your eligibility and benefits, communicating with you about the benefit, and measuring participation, under its own privacy practices. It is contractually prohibited from using what we share for interest-based advertising involving health-related information and from selling it.
• Independent controller: for its own use of your information, the Partner Organization is an independent controller with its own legal obligations and privacy policy, which we encourage you to review.
• Your rights: you may exercise privacy rights directly with the Partner Organization. If you’d like us to forward a request on your behalf, contact [email protected].
• Contractual protections: we require a written agreement with appropriate data-protection terms and, where PHI is involved, a Business Associate Agreement, covering security, breach notification, use restrictions, and cooperation with your privacy requests.

4. Third-Party Services and Devices

4.1 General

If you connect a third-party service, account, or wearable device to the Service, you authorize that third party to share information with us, and us to share information with it as needed to provide the connected feature. The third party’s use of your information is governed by its own privacy policy.

4.2 Apple HealthKit

If you authorize our iOS app to read from or write to Apple HealthKit:

• Scope of access: we access only the HealthKit data types you authorize. You can grant or revoke each type in your iOS Settings > Privacy & Security > Health.
• No advertising use: we do not use HealthKit data for advertising, marketing, or other use-based data mining.
• No third-party sharing for advertising: we do not share HealthKit data with third parties for advertising or data mining.
• No sale: we do not sell HealthKit data.
• Purpose limitation: we process HealthKit data only to provide and improve the Service, including to inform clinical recommendations, show you insights, and support your Healthcare Providers’ care.
• Revocation: you can revoke access at any time in iOS Settings. Revoking access does not delete data we already received; to request deletion, see Section 7.

4.3 Google Health Connect

If you authorize our Android app to read from or write to Google Health Connect:

• Scope of access: we access only the Health Connect data types you authorize. You can grant or revoke each type in your Android Settings > Apps > Health Connect.
• No advertising use: we do not use Health Connect data for advertising, marketing, or other use-based data mining.
• No third-party sharing for advertising: we do not share Health Connect data with third parties for advertising or data mining.
• No sale: we do not sell Health Connect data.
• Purpose limitation: we process Health Connect data only to provide and improve the Service, including to inform clinical recommendations, show you insights, and support your Healthcare Providers’ care.
• Revocation: you can revoke access at any time in Android Settings. Revoking access does not delete data we already received; to request deletion, see Section 7.

4.4 Other connected devices and apps

If you connect other wearables or health apps, such as Oura or Garmin, we receive only the data types you authorize. Those services have their own privacy practices, and we are not responsible for how they collect or use information. Disconnecting stops further data flow but does not delete data already received.

5. Cookies and Tracking Technologies

We use cookies, software development kits (SDKs), and similar technologies (“Tracking Technologies”) to run the Service, remember your preferences, understand how the Service is used, and keep it secure. We do not use advertising cookies, advertising pixels, or advertising SDKs.

5.1 Categories of Tracking Technologies

• Strictly necessary: required for the Service to work, including sign-in, session management, security, and load balancing. These cannot be turned off.
• Functional: remember your preferences, language, and similar settings.
• Analytics and performance: help us understand how the Service is used so we can improve it, using vendors such as Google Analytics and similar product intelligence providers.
• Mobile SDKs: in our apps, we use SDKs from analytics, communications, and infrastructure providers for the purposes above. We do not use advertising or attribution SDKs, and we do not access mobile advertising identifiers such as Apple’s IDFA or Google’s Advertising ID.

5.2 Managing your preferences

• Cookie banner: where we show one, you can accept, reject, or customize non-essential cookies.
• Browser settings: most browsers let you block or delete cookies.
• Global Privacy Control: we honor the GPC signal as a valid opt-out of sale and sharing under applicable state laws.

5.3 Do Not Track

Some browsers send a “Do Not Track” signal. Because there is no industry standard for responding to it, the Service does not respond to Do Not Track signals. We do honor Global Privacy Control.

5.4 App Tracking Transparency (Apple iOS)

We do not use advertising or attribution SDKs that access Apple’s IDFA, and we do not track you across other companies’ apps and websites.

Health data. We do not use PHI, genetic information, Apple HealthKit data, or Google Health Connect data for cross-app tracking or advertising. On screens that show health-related information, such as biomarker results, clinical recommendations, and personalized health insights, no third-party advertising technology runs.

5.5 Third-party technologies

Some Tracking Technologies are set by third parties whose services appear in the Service, such as analytics providers. They may collect information about your interactions with the Service, under their own privacy policies. We do not share PHI with them. For a list of the specific Tracking Technologies we use, with their providers, purposes, and durations, contact [email protected].

6. Data Retention

We keep personal information as long as needed to provide the Service, meet our legal and contractual obligations, resolve disputes, and enforce our agreements. Retention depends on the type of information, why we collected it, our legal obligations, and your reasonable expectations. When we no longer need personal information, we delete or de-identify it.

• Visit transcripts: when a visit uses Medis Labs’ visit tools, the audio is not kept. The text transcript is kept only as long as needed for quality review, such as checking that clinical notes are accurate, and then deleted, unless the law, a legal hold, or agreements with the Medical Groups require it to be kept longer.
• Consent and acceptance records: we keep records of the terms, policies, and consents you accept, including the version you saw and when, for as long as needed to show what you agreed to.
• PHI: kept according to the Medical Groups’ policies, our agreements with them, and applicable law. If the Service ends, PHI is returned to the Medical Groups or deleted as those agreements require, except where the law requires it to be kept.

Our clinical, laboratory, pharmacy, lab orchestration, and other partners may keep personal information they receive under their own retention policies, applicable law, and any agreements you have with them. For example, laboratories must keep certain testing records for periods set by federal and state laboratory regulations.

7. Your Privacy Choices and Rights

7.1 General choices

• Promotional emails: unsubscribe at any time using the link in any promotional email.
• Promotional texts: we send these only if you opted in. Reply STOP to any promotional text to opt out, or HELP for help. Message frequency varies, and message and data rates may apply.
• Care texts: care-related texts, such as appointment reminders and lab updates, are sent only with your consent. Reply STOP to opt out, or turn them off in the app’s settings. Care texts for several apps may come from the same number, so replying STOP stops care texts from every app at that number.
• Service messages: opting out of promotions does not stop account, billing, and care-related notices that are part of providing the Service.
• Cookie preferences: see Section 5.
• Connected services: disconnect any wearable or third-party service at any time under My account > Wearables.
• Account information: update it in the Service or by contacting [email protected].
• Precise location: turn off location access in your device settings.

7.2 U.S. state privacy rights

Depending on where you live, you may have the following rights over personal information we collect:

• Right to know and access: to confirm whether we process your personal information and to get a copy.
• Right to correction: to correct inaccurate personal information.
• Right to deletion: to delete personal information, subject to legal exceptions.
• Right to data portability: to receive your personal information in a portable format.
• Right to opt out: of the sale or sharing of personal information for targeted advertising, and of certain profiling.
• Right to limit use of sensitive personal information: to limit how we use and disclose sensitive personal information.
• Right to non-discrimination: to exercise these rights without discrimination.
• Right to appeal: to appeal our decision on your request, where the law provides this right.

These rights apply to residents of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, and Washington, among other states as new laws take effect, subject to each state’s scope and exceptions.

To exercise these rights, email [email protected]. To verify your identity, we generally require requests to come from the email address on your account. We respond within the time the law requires, generally 45 days, with a possible extension. HIPAA rights over PHI, such as access, amendment, and an accounting of disclosures, are exercised through the Medical Groups under their Notice of Privacy Practices, with our support and Medis Labs’ support.

7.3 Global Privacy Control

We honor opt-out preference signals from recognized universal opt-out mechanisms, including Global Privacy Control, as a request to opt out of sale and sharing, where the law requires and to the extent we can identify the signal from your browser or device.

7.4 Authorized agents

Where the law allows, you may have an authorized agent submit a privacy request for you. We will require proof of the agent’s authority and may ask you to verify your identity directly with us.

7.5 Right to limit (California residents)

California residents may ask us to limit the use and disclosure of sensitive personal information to what is necessary to provide the Service or as otherwise permitted by the California Consumer Privacy Act. To make this request, email [email protected] with the subject line “California Right to Limit.”

8. Security and Incident Response

We and Medis Labs use reasonable administrative, technical, and physical safeguards to protect personal information from unauthorized access, use, disclosure, alteration, and destruction, including encryption in transit and at rest, access controls, vendor due diligence, employee training, and incident response procedures. No method of transmission or storage is completely secure, and we cannot guarantee security.

If a security incident affects personal information, we will investigate promptly and fix vulnerabilities within our control; comply with applicable breach-notification laws; cooperate with affected users and the Medical Groups as required; document our actions; and review the incident to prevent recurrence. We will notify you as the law requires.

You are responsible for protecting your account credentials and for telling us promptly at [email protected] about any suspected unauthorized access to your account.

9. Children’s Privacy

The Service is not directed to children under 18, and we do not knowingly collect personal information from anyone under 18. If you are a parent or guardian and believe we have collected a child’s personal information, contact [email protected] and we will take appropriate steps to delete it.

10. Artificial Intelligence Features

The Service includes features powered by artificial intelligence (“AI”), provided through Medis Labs’ platform. Some support the delivery of clinical services and are required to use the Service; others are optional. This Section 10 describes those features, the AI providers that receive your data, the protections in place, and your consent choices. If this Section 10 conflicts with another part of this Privacy Policy on AI features, this Section 10 controls.

10.1 AI features and providers

Clinical AI features (required for clinical services). These features help your Healthcare Providers deliver care and are foundational to the Service. If you do not consent to them, the Service is not available to you. They apply when a visit or record uses Medis Labs’ tools; visits on the Medical Groups’ own systems are governed by the Medical Groups’ consents and practices.

• Live medical transcription: during telehealth visits, audio is transcribed in real time by Deepgram and returned to your Healthcare Provider for documentation. The audio is not kept, and the transcript is kept for quality review (see Section 6).
• Clinical assessment generation: your visit transcript, intake responses, and clinical context are sent to OpenAI to draft a structured clinical assessment, which your Healthcare Provider reviews before it influences your care.
• Treatment plan formulation: your clinical context and assessment are sent to OpenAI to draft a proposed treatment plan, which your Healthcare Provider reviews and finalizes.
• Subjective and objective clinical entry: your visit transcript and intake data are sent to OpenAI to structure sections of clinical notes for your Healthcare Provider’s review.
• SOAP note summary: your visit data is sent to OpenAI to draft a structured SOAP (Subjective, Objective, Assessment, Plan) note, which your Healthcare Provider reviews.
• Clinician recommendations: your clinical context is sent to OpenAI to generate recommendations, which your Healthcare Provider accepts, changes, or rejects using clinical judgment.
• Comprehensive clinician note: your full visit data is sent to OpenAI to draft a comprehensive clinical note for your Healthcare Provider to review and finalize.
• Lab result interpretation: your lab results and relevant clinical context are sent to OpenAI to draft an interpretation, which your Healthcare Provider reviews before it informs your care.
• Patient summary emails: clinical updates for you are drafted by OpenAI for your Healthcare Provider’s review before being emailed to you.

Optional AI features. You can choose whether to use these without affecting your access to clinical services.

• AI Coach: an in-app AI health chatbot. What you enter, along with relevant profile and health information, is sent to OpenAI to generate responses. The AI Coach is informational only and is not a substitute for care from your Healthcare Provider.
• Chat summaries and routing: if you use the AI Coach, conversation summaries and intent classifications may be sent to OpenAI to give your Healthcare Provider context and to route urgent matters.
• Nutrition logging: if you log meals, food descriptions or photos are sent to Passio for identification and nutrient analysis.
• Insurance card recognition: if you submit an image of your insurance card, it is sent to OpenAI Vision to extract the card details, such as name, member ID, group number, and payer, for billing and care coordination.

AI service providers.

• OpenAI OpCo, LLC (“OpenAI”): GPT models for clinical structuring, lab interpretation, the AI Coach, patient communications, and insurance card recognition. OpenAI processes PHI under a Business Associate Agreement with Medis Labs, with a zero-retention configuration, and is prohibited from using your data to train its models.
• Deepgram, Inc. (“Deepgram”): speech-to-text models for live medical transcription. Deepgram processes PHI under a Business Associate Agreement with Medis Labs and is prohibited from using your data to train its models.
• Passio, Inc. (“Passio”): nutrition analysis for meal logging. Passio uses other AI providers, including OpenAI and Google. Nutrition data is treated as wellness data rather than PHI; see Section 10.2.

10.2 Protections for your data

Business Associate Agreements. Medis Labs’ Business Associate Agreements with OpenAI and Deepgram comply with the HIPAA Privacy and Security Rules. They require the providers to protect PHI with administrative, physical, and technical safeguards at least as protective as Medis Labs’ own, and to use it only to provide services.

Zero retention with OpenAI. Data sent to OpenAI is not retained on OpenAI’s systems after the response is delivered. OpenAI does not store, log, or train models on your data.

Third-party AI providers. Medis Labs’ agreements with OpenAI and Deepgram prohibit them from using your data to train their models. Your data is used only to deliver the feature you are using.

Medis Labs models. Medis Labs does not train its own AI models on identifiable PHI without your explicit, separate consent. Medis Labs may train, fine-tune, or develop models that support the Service using aggregated or de-identified data, meaning data processed under HIPAA’s Safe Harbor method (45 CFR § 164.514(b)(2)) or Expert Determination method (45 CFR § 164.514(b)(1)) so it can no longer reasonably be linked to you. Your individual records cannot be retrieved from those models, and you cannot be re-identified from them.

De-identification standard. Data used for model development has these identifiers removed under HIPAA Safe Harbor: names; geographic subdivisions smaller than a state; dates directly related to an individual (other than year); telephone numbers; email addresses; Social Security numbers; medical record numbers; health plan beneficiary numbers; account numbers; certificate and license numbers; vehicle identifiers; device identifiers; web URLs; IP addresses; biometric identifiers; full-face photographs; and any other unique identifying number, characteristic, or code.

No PHI training without consent. If Medis Labs ever wants to train its own models on identifiable PHI, we will give you advance notice and ask for your explicit, separate consent first. Accepting this Privacy Policy is not that consent.

No sale or advertising use. We do not sell your data to AI providers or anyone else, and we do not use your data, or anything derived from AI features, for advertising.

Nutrition data. Meal descriptions and food photos sent to Passio are treated as wellness data rather than PHI, so there is no Business Associate Agreement with Passio. You can avoid sending food data to Passio by not using nutrition logging, without affecting your clinical services.

10.3 Your consent

Consent at onboarding. When you create an account, you are shown an in-app disclosure of the clinical AI features, naming the providers that receive your clinical data (OpenAI and Deepgram), the categories of data sent, and the protections in place. Your affirmative consent is required to use the Service. If you decline, your account will not be activated.

Permission prompts for optional features. The first time you use each optional AI feature, the Service asks for your permission and shows the provider, the data sent, and the protections that apply. Nothing is sent until you agree. Declining one optional feature does not affect the others or your access to clinical care.

Reminders. Within each AI feature, we show reminders about AI involvement, such as a disclaimer on AI-generated lab interpretations and a notice on AI Coach responses.

Duration and withdrawal. Your consent to an AI feature stays in effect while you use the Service. The Service does not currently let you turn off an individual AI feature after consenting. To stop all processing through AI features, close your account under My account > Profile info > Delete account. You can review your consents under My account > Privacy & consent. Residents of states with consumer health data laws, including Washington, Nevada, and Connecticut, have additional withdrawal rights described in our Consumer Health Data Privacy Policy.

Data already sent. Closing your account does not delete data already incorporated into your clinical record, which the Medical Groups keep under medical record retention requirements. To request deletion of clinical records, contact [email protected].

10.4 Important limitations

AI is not your healthcare provider. AI features support, but do not replace, the clinical judgment of licensed Healthcare Providers, who review AI-generated clinical content before it influences your care. If you have a medical concern, contact your Healthcare Provider. In an emergency, call 911 or go to the nearest emergency room.

AI can make mistakes. AI models can produce inaccurate, incomplete, or misleading information. This risk is reduced through clinician review of clinical AI features and reminders in the AI Coach, but you should not rely on AI-generated content as the sole basis for any medical decision.

AI Coach limits. The AI Coach is not designed for medical emergencies, urgent symptoms, or mental health crises. If you describe a possible emergency or crisis, it will direct you to call 911 or a crisis line, but it cannot contact emergency services for you.

10.5 AI in telehealth visits

AI use during telehealth visits, including transcription, ambient documentation, and AI-assisted clinical decision support, is also governed by the Medical Groups’ telehealth consents, which you review and accept before your first visit. These include the Telehealth Consent Form of OpenLoop Healthcare Partners, PC, available at openloophealth.com/telehealth-consent.

11. International Users and Data Transfers

The Service is operated in the United States and is intended for people located in the United States. If you access it from elsewhere, your personal information will be transferred to and processed in the United States, where data protection laws may differ from those in your country. Where service providers in other countries are used, steps are taken designed to protect your personal information adequately.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top shows when it last changed.

• Routine updates: for clarifications, formatting changes, vendor changes within existing categories, and similar non-material updates, we update the date and post the revised policy.
• Material changes: for changes such as new categories of personal information, new uses, or new categories of recipients, we notify you in the Service, by email, or by other reasonable means before the change takes effect.
• Changes affecting information already collected: where the law requires it, or where a change would expand the use of information we already collected (such as new sharing for advertising or new use for AI training), we ask for your affirmative consent first.

We will not retroactively reduce your privacy rights over personal information we previously collected, except where the law requires it or with your affirmative consent. Continuing to use the Service after a change takes effect means you accept the updated Privacy Policy. If you do not accept it, you may stop using the Service and exercise your rights under Section 7.

13. Contact Us

For questions about this Privacy Policy or our privacy practices, contact:

Medis Labs, Inc.

Attn: Privacy Officer

214 Main St, Ste 553, El Segundo, CA 90245

Email: [email protected]