Privacy Policy & Health Data Disclosures
Plain-language summary
- The Free tier stores your loved one’s health records entirely on your local device. We receive no health records.
- Paid synchronization uses zero-knowledge, client-side end-to-end encryption. Cloudflare stores only encrypted ciphertext; we do not hold your private keys and cannot decrypt your records.
- We do not sell, rent, or trade personal data or health information. We do not use health information to train machine-learning models, and we run no behavioral advertising trackers.
- Statutory privacy, access, correction, and deletion requests go to admin@ahlchemy.org.
Data we process
- Account identification: your email address (for one-time sign-in codes and receipts) and internal circle identifiers.
- Encrypted health records (synced tiers only): names, medication schedules, notes, vitals, appointments, and contacts are encrypted on your device before transmission; our databases receive only ciphertext.
- Billing: card transactions and billing postal codes are processed directly by Stripe, Inc.; we never view or store complete card credentials.
- Technical telemetry: ephemeral network logs (IP, user agent, routing) processed by Cloudflare for security and DDoS prevention, on rolling 7–30 day schedules.
- Encryption material: device public keys and wrapped (encrypted) key blobs. Private keys never reach us. We also keep minimal access logs (sign-ins, grants, revocations) with no clinical content.
Sub-processors
- Cloudflare, Inc. (USA) — edge compute, delivery, and encrypted storage (KV, D1, R2). Processes account identifiers, network logs, and encrypted ciphertext.
- Stripe, Inc. (USA) — secure payment processing and recurring billing.
- Resend, Inc. (USA) — transactional email for one-time sign-in codes and billing notices.
Zero behavioral monetization
We do not monetize your personal records. We never sell consumer health data, share records for cross-context behavioral marketing, or permit third-party advertising SDKs to track you within the App.
Children’s health data & adult caregiver agency (COPPA)
The Service is directed exclusively to adult caregivers aged eighteen (18) and older. We do not permit children under thirteen (13) to create accounts or own circles. Where an adult caregiver records the health information of a pediatric or minor Cared-For Person, the adult warrants that they are the child’s legal parent or court-appointed guardian, or hold express written authority from such a representative, and consents to the processing and storage of those records under this Policy.
Your statutory health-data rights (WA MHMDA, NV SB 370, CCPA/CPRA)
Residents of states with consumer-health-data protections (including Washington, Nevada, California, and Connecticut) have specific rights over consumer health information:
- Right to know & access — confirm whether we process your consumer health data and obtain a copy.
- Right to withdraw consent & deletion — withdraw consent and request permanent deletion of your account records.
- No geofencing — we do not establish or use virtual geofences around healthcare facilities.
- How to exercise — email admin@ahlchemy.org; verification requires confirmation from your registered sign-in email.
Security, breach notification & FTC HBNR
Synced circles use authenticated encryption (AES-GCM) with keys derived on client hardware. In the event of an unauthorized security compromise affecting unsecured personal information, we will notify affected account holders without unreasonable delay and report to required regulators in accordance with applicable state breach statutes and the Federal Trade Commission Health Breach Notification Rule (16 CFR Part 318). Because synchronized records exist only as end-to-end encrypted ciphertext, a storage compromise would expose only unreadable cryptographic blobs.
Data retention & deletion
- Local data — retained on your device until you clear or export it.
- Synced encrypted records — kept until the Circle Owner deletes the circle in-app, which purges the ciphertext from active cloud storage.
- Inactivity — cloud archives tied to expired/inactive subscriptions with zero activity for twelve (12) months may be pruned after thirty (30) days’ notice to the registered email.
Health information & not medical advice
The Circle of Care is a place to store your loved one’s information and share it with your physicians and care team. It is a record you keep and coordinate — it is not a medical device and does not provide medical advice, diagnosis, or treatment. Always rely on qualified professionals, and call your local emergency number in an emergency.
Governing law & contact
This Policy is governed by the laws of the State of Missouri, USA. Questions and requests: admin@ahlchemy.org.