Privacy Policy

1. Who We Are and What This Policy Covers

Lenaya Health is operated by Clargenta AI LLC ("Clargenta," "we," "us," or "our"). Lenaya Health is our product; Clargenta AI LLC is the company responsible for the information described in this Policy.

Our consumer service lets you record a medical visit, receive a plain-language summary and a checklist of what your clinician asked you to do, upload health documents and recordings, ask questions about your records, and invite family members or caregivers into a Care Circle. Features also organize visits by concern in My Care Journey and display laboratory results across visits.

This Policy covers our websites, iOS application, and related services (the "Services"). It applies to people using the Services for their own care, authorized adults managing someone else's care, and invited Care Circle members. Information about another person must be provided and used with that person's permission or other valid legal authority.

Our relationship to health privacy laws

Lenaya Health provides a consumer information service. We do not provide clinical care, operate a health plan, or act as a healthcare clearinghouse. For the direct-to-consumer Services covered by this Policy, we do not provide the Services on behalf of a HIPAA-covered healthcare organization as its business associate.

HIPAA generally governs information held by covered healthcare organizations and their business associates. When you independently choose to place information in a consumer app that is neither a covered entity nor a business associate, HIPAA generally does not govern that app's handling of its copy. Your clinician's own records remain subject to the laws and privacy practices applicable to the clinician.

Your information in Lenaya Health is protected by this Policy and applicable law. Depending on the information and circumstances, those laws include the Federal Trade Commission Act and Health Breach Notification Rule, state consumer health data laws, and California's Confidentiality of Medical Information Act (CMIA). A consumer app can have obligations under CMIA even when it is not subject to HIPAA. Nothing in this Policy limits rights you have under applicable law.

2. Information We Collect

Account and contact information

Your name and email address, received from Google or Apple when you sign in (if you choose Apple’s “Hide My Email,” Apple gives us a private address that forwards to your own); a postal address, which we use for billing and to reach you by post when the law requires it; the sign-in identifier associated with your account; an optional mobile telephone number for verification or notifications; and account preferences and settings. Google’s and Apple’s handling of information within their own sign-in services is governed by their privacy practices.

Health information

Recordings, transcripts, summaries, documents, questions, answers, and other health-related information described in Section 3. We also receive information an authorized Care Circle member provides on your behalf.

Care Circle information

An invitee's email address, assigned role, invitation status, membership, permissions, and actions taken within a circle. An invitation identifies the account or person inviting the recipient so the recipient can understand the invitation.

Payment information

Subscription details, plan selections, billing history, invoices, and transaction records. Our payment processor collects and stores payment card details. We receive limited information, such as card brand and last four digits, rather than full card numbers. Payment providers may also process information for their own legally required payment, fraud-prevention, and compliance functions under their applicable terms and notices.

Usage, device, and technical information

IP address, device and operating system, app version, sign-in times, features used, error and diagnostic logs, and security events. If you grant location permission, we use the location where a recording was made, including its street address, to label that recording for you. Technical information can itself reveal health information when connected to a visit, health question, document, or other health-related activity; we protect it accordingly.

Communications

Support requests, feedback, emails, and any information you include in those communications. If you use text-message verification or notifications, we process your phone number and message-delivery information. If you choose to receive optional product news, we process your contact details and communication preferences for that purpose.

3. Health Information You Share With Us

Depending on how you use the Services, we process:

• Audio recordings of medical conversations you or an authorized person choose to record or upload, including recordings made outside Lenaya and the voices and statements of participants.
• Transcripts, including speech attributed to you, your clinician, and other participants.
• Summaries, action items, and follow-up checklists generated from your content.
• Uploaded laboratory results, after-visit summaries, referrals, imaging reports, and similar records, together with extracted text.
• Health concerns or conditions identified from your records over time, their status as reflected in those records, My Care Journey groupings, and laboratory values and trends drawn from your records.
• Questions about your care and generated answers.
• Visit dates, clinician names, facilities, and other appointment details appearing in your content, together with optional recording-location labels.
• Identifiers and technical information linked to these records, and information about who has access to them.

Your content may include diagnoses, symptoms, medications, treatment plans, laboratory values, disabilities, mental health or substance-use information, reproductive or sexual health information, genetic information appearing in documents, or other sensitive details. We do not require you to provide every category. What we receive depends on your content and use of the Services.

Generated information can be sensitive even when you did not explicitly state it. We protect health-related conclusions and inferences derived from your records as health information. Generated output may be inaccurate; it does not establish a medical diagnosis.

4. How We Use Information

We use information to:

• Provide transcription, summaries, action items, document extraction, record organization, and answers grounded in your records.
• Create and authenticate accounts, manage subscriptions, and process payments.
• Operate Care Circle permissions and sharing you request.
• Deliver verification codes, processing notifications, security notices, billing messages, and other service communications.
• Respond to support requests and correct technical problems.
• Maintain security, prevent fraud and abuse, and protect the integrity and reliability of the Services.
• Measure technical performance, such as processing time, failure rates, and feature reliability.
• Send optional product news when you choose to receive it, using your contact details and preferences rather than the contents of your health records.
• Meet applicable legal requirements and administer our agreements, subject to restrictions on the use of health information.

Technical improvement and access to health content

Routine performance measurement uses technical information rather than the contents of your medical conversations or documents. Authorized personnel may access relevant health content when necessary to deliver the Services, investigate a support issue, correct a processing problem, or address a security incident, and only as permitted by applicable law and the permissions or authorizations required for that access.

We do not use your health content as a general-purpose product research dataset or for unrelated human review or AI evaluation. If we propose an optional use beyond the purposes described here, we will explain it and obtain any required separate consent before starting it.

What we do not do

• We do not sell personal information, including consumer health data.
• We do not share personal information for cross-context behavioral advertising or targeted advertising, or use health information to build advertising profiles.
• We do not use recordings, transcripts, documents, questions, answers, or other health information to train or fine-tune generative AI models, whether ours or a third party's.
• We do not use health information to make insurance, credit, or employment decisions, or provide it to others for those purposes.

5. Recording, Transcription, and AI Features

The Services use automated speech recognition, document processing, and AI to produce the features you request. Generating an answer or summary from your content is processing that content to serve you; it is not training the underlying AI model on your records.

Recording starts only when you or an authorized user start it; there is no always-listening mode. Answers are designed to be grounded in the records you are authorized to access. The answer feature does not retrieve information from the internet or other customers' records to supplement those records.

Processing by Microsoft Azure

We use Microsoft Azure for hosting, storage, speech-to-text, document text extraction, and AI processing. Our processors act under contracts that restrict their handling of content and do not permit them to use it to train their own models.

Microsoft uses automated systems to screen AI requests and responses for misuse. Content flagged for potential abuse may be reviewed by authorized Microsoft personnel under restricted-access procedures. This review is for abuse prevention, not for training Microsoft's AI models. It is distinct from Lenaya's own support and troubleshooting access described in Section 4.

Recording permission

Recording laws vary. Before recording, obtain the permission required from the people participating in the conversation. Our Terms also require you to tell everyone present that you are recording with Lenaya Health and that software will store and process the recording, and to stop if anyone asks. Microphone permission on your phone authorizes the app to use the microphone; it does not establish that the other participants agreed to be recorded. Uploaded recordings must also have been lawfully obtained and be authorized for the intended processing. See our Terms and Conditions for additional recording responsibilities.

Automated output

Transcription and AI output can be incomplete or wrong. Summaries, checklists, and answers help you remember and understand your care. They are not medical advice or a substitute for your clinician. Confirm important information with a qualified professional.

6. Care Circle Sharing

Care Circle lets you give family members or caregivers access to health information inside the Services.

• Other consumers do not receive Care Circle access unless you or a legally authorized representative invite or authorize them.
• You select each member's role and the permissions available for that role.
• Depending on the role, a member may view visits, ask questions, record a visit, or add documents on your behalf.
• You can change a role or remove a member at any time. Removal stops future access through the Services within minutes.

An invitation may give a member access to recordings, transcripts, summaries, action items, documents, questions and answers, and identified health concerns associated with your account, including information added later within the authorized scope. Review the permissions before sharing. Where applicable law requires a separate consent or signed authorization, we obtain it before making the disclosure and honor its limits and expiration.

Removing a member does not erase information they already saw or copies they downloaded or saved outside Lenaya. However, information and access still controlled by Lenaya remain subject to our access controls and deletion obligations. Prior sharing does not create a general exception allowing us to keep your health data after a valid deletion request.

This section describes sharing with other consumers. Restricted access by our personnel and processors, and legally permitted disclosures, are described in Sections 4, 5, and 7.

Care Circle members must have permission or other valid legal authority to act for the person whose care is involved and must use the information only within that authority to support the person's care. Family relationship alone does not establish unlimited access rights.

7. How We Disclose Information

We disclose information only for the following purposes and subject to applicable consent, authorization, and confidentiality requirements:

We do not disclose consumer health data to corporate affiliates. We do not provide health information to advertisers or data brokers, or to insurers or employers for their independent use. You may choose what to do with a copy you export yourself. Any disclosure legally compelled from us remains subject to the legal-disclosure limits above.

Providers processing information on our behalf are subject to contractual purpose and confidentiality restrictions. Some providers, such as payment and sign-in providers, also have independent responsibilities for their own services; those functions do not give them permission to use your medical content for advertising or AI training.

8. Cookies and Similar Technologies

We and our providers use cookies, local storage, and similar technologies to keep you signed in, remember preferences, maintain security, and measure technical use and reliability of the Services. We do not use advertising cookies or third-party advertising trackers.

We do not authorize third parties to collect consumer health data through the Services over time and across unrelated websites or online services for their independent tracking or profiling purposes. Our technical measurement does not permit health-record content to be used for advertising.

Your browser may let you block or delete cookies; doing so may prevent some features from working. Because we do not sell information or share it for targeted advertising, there is no such sale or advertising-sharing activity to opt out of. We do not use browser Do Not Track signals to change our essential cookie practices.

9. Data Retention and Deletion

We retain information while needed to provide the Services and for the specific periods and limited purposes below. We do not retain health records indefinitely because an account once existed.

When a subscription or free trial ends

Trials that automatically convert to paid subscriptions do so under the subscription terms presented at signup, unless canceled. Successful conversion or renewal keeps the subscription active.

If you cancel a paid plan, you keep it until the end of the period you have paid for or, during a free trial, through the trial's original end date. After that, or if a payment fails and is not resolved, your account goes back to the free Core plan. Your records stay in your account and you can keep using them within the free plan's limits. We do not delete health records because a plan ended or a payment failed. If an add-on that lets you share with other people ends, those people lose access; your records are not deleted.

You can export a personal copy at any time. An export contains your transcripts, summaries, to-dos, questions and answers, and uploaded documents. It does not include audio recordings: we keep audio to produce your transcript and summary, may delete it after that while keeping the records made from it, and do not provide copies of it.

Deleting individual items

You can delete a recording, conversation, or uploaded document in the Services at any time. We delete that item and information derived from it, including applicable transcripts, summaries, action items, extracted text, search-index content, and derived health information. Information independently supported by other records you retain is not deleted solely because a different source was removed.

You can also remove a person you manage (a dependent). We then delete all of that person's health information in the same way, at once; it is not offered for download first.

Deleting your account or requesting health-data deletion

If you want to delete your account, go to Account Settings and delete your account, or contact us as described in Section 16. You may also request deletion of your health data without using the account-deletion feature.

Deletion covers health information under our control, including recordings, transcripts, summaries, action items, uploaded documents, extracted text, health questions and answers, derived health concerns, and associated search or retrieval data. Deleting your account also deletes this information for every dependent you added. We notify relevant processors and other recipients and require deletion where applicable law requires it.

Most health content is removed from active systems right away. Some derived data and routine encrypted backups clear within about three weeks. If a system restoration reintroduces records marked for deletion, we reapply those deletions as part of the restoration. Once the backup window has passed, deletion cannot be undone through our routine backups.

This schedule also applies to health content in routine logs or other copies under our control; calling a copy a log does not exempt it from deletion. Where law permits or requires narrowly limited retention, we retain only the necessary information for that purpose, restrict its use and access, and delete it when the basis ends. We do not retain medical content merely because we retain billing records.

We cannot erase someone's memory or retrieve copies a Care Circle member independently saved outside the Services. Copies or shared views still controlled by Lenaya remain covered by our deletion obligations. Where applicable law requires notifying a recipient of a deletion request, we do so.

Security and authorization records

Our ordinary retention period for limited security-event logs, including sign-ins, failed sign-in attempts, and important account events, is six years from the event. This is a security-log schedule, not a six-year retention period for your medical records.

On account deletion, we remove identifying links from routine account-change records where they are no longer needed and can lawfully be removed. We delete or de-identify other personal information in logs as required to honor applicable deletion rights. We retain only limited identifiable security, privacy-request, or authorization records where necessary and permitted or required by law, for the period applicable to that purpose. The ordinary log schedule does not override those rights or the health-content deletion schedule above. Removing a name alone does not make a record anonymous if other information can still identify you.

Billing records after account deletion

If you paid us or were billed, we retain a limited billing record: your name and email address at the time, account sign-in identifier, plans, charges, payments, and card brand and last four digits. This record contains no medical-record content or full card numbers.

We use it only for accounting, applicable tax and legal requirements, payment questions or disputes, and account-deletion confirmation. We do not use it for marketing, analytics, or reconnecting you to deleted health records.

Our ordinary retention period for this record is two years after account deletion. If a longer period is required for applicable tax, accounting, legal-preservation, or other legal obligations, we keep only the information needed for that obligation and delete it when the required period ends. The Terms and Conditions and account-deletion confirmation explain the treatment of any unpaid balance.

Other account and operational information

For information without a specific period above, we determine retention by its purpose, sensitivity, the duration of the account or support issue, fraud-prevention and security needs, and applicable legal requirements. Those criteria do not override health-data deletion rights or the health-content schedule above.

10. Data Security

We use administrative, technical, and physical safeguards designed for sensitive health information, including encryption in transit and at rest, authentication, access controls, logging of account changes, and restricted personnel access.

No system can guarantee absolute security. Protect your sign-in credentials and devices. If we discover a reportable breach involving your information, including an unauthorized disclosure where covered by law, we provide required notices to affected individuals and applicable authorities, including under the FTC Health Breach Notification Rule. We also provide any other notifications required by applicable law.

11. Your Choices and Privacy Rights

Access, correction, export, and deletion

You can review and correct information through available account features, export records, delete individual items while your subscription is active, and delete your account. You may also email us to request access, a portable copy, correction, or deletion. You may request correction of inaccurate generated information; correcting a Lenaya record does not change your clinician's original record.

Where applicable law provides it, you can also request confirmation of collection or disclosure, information about the recipients of your data, limitations on sensitive-information use, and an appeal of a denied request. The state notices explain additional health-data rights.

How to make a request

Email support@lenayahealth.com from the address associated with your account when possible. "Privacy Request" in the subject helps route it, but is not required. Explain what you want us to do. Do not send copies of medical records or identity documents unless we request information needed for verification through an appropriate method.

We verify identity and authority using information reasonably necessary for the request. We may ask an authorized representative for evidence of authority and, where permitted, confirmation from the individual. You do not need to create a new account to submit a request.

We respond without undue delay and within the applicable legal deadline. Unless a shorter deadline applies, our general response period is forty-five days after receipt. Where law permits an extension, we explain the reason and extension within the original period. The Nevada notice includes a thirty-day deadline after authentication for covered deletion requests. We do not delay authentication to avoid a deadline.

Requests are generally free. Any fee or refusal for an excessive or unfounded request must be allowed by applicable law, and we explain the basis. We do not unlawfully discriminate against you for exercising your rights.

Consent and authorization withdrawal

To withdraw permission for a Care Circle member, remove the member or change the available permissions in the Services. To withdraw consent for other collection, use, or sharing of health information, email support@lenayahealth.com and identify the permission you wish to withdraw. You may use "Withdraw Health Data Consent" as the subject.

We stop future processing covered by the withdrawal unless a separate legal basis permits or requires it. We explain which features can no longer operate. Withdrawing optional permission does not require you to give up unrelated features. Withdrawal does not retroactively undo processing lawfully completed before the withdrawal, and does not automatically delete existing records; you may request deletion at the same time.

Appeals

If we deny a request, reply to our response or email support@lenayahealth.com with "Privacy Appeal" and explain why you believe we should reconsider. We provide a written decision and reasons within forty-five days after receipt, or sooner where required. If an appeal is denied, we provide the applicable regulator's complaint mechanism where required. State complaint information appears in the separate health-data notices.

Device permissions

Microphone, camera, notification, and location permissions can be changed in your device settings. Removing microphone permission prevents new recording through that device. Changing a device permission does not itself delete content previously uploaded or revoke a Care Circle member's access.

Communications

If you choose to receive optional product emails, you can unsubscribe using the link in the email. Necessary account messages, including security and billing notices, may continue. For text messages, reply STOP to opt out or HELP for assistance. Message frequency varies; message and data rates may apply. Opting out may affect features that require delivery of a verification code or notification by text.

12. United States State Privacy Disclosures

This section supplements the Policy where state privacy laws apply. Rights vary by law, type of information, and circumstances; we also provide the account controls described above regardless of whether a particular statute applies.

California

California medical information may be protected by CMIA. We restrict its use and disclosure as required by that law and obtain a separate valid authorization when required. The fact that Lenaya does not provide clinical care does not remove applicable medical-confidentiality duties.

Where the California Consumer Privacy Act applies to the relevant business activity and information, it provides rights concerning access, correction, deletion, portability, nondiscrimination, and certain sensitive-information uses. Its scope and health-data exemptions are different from CMIA's. Contact us through Section 11 to exercise an applicable right or use an authorized agent.

Categories, sources, purposes, and recipients

In the preceding twelve months, depending on use of the Services, we may have collected:

Specific permitted disclosures are described in Section 7. Retention periods and criteria are in Section 9. We do not sell personal information or share it for cross-context behavioral advertising and have not done so in the preceding twelve months. This commitment also applies to information about minors. Authorized care sharing described in this Policy is different from advertising sharing.

Washington and Nevada

For consumer health data covered by these laws, see the separate Washington notice and Nevada notice. They explain categories, sources, uses, disclosures, recipient information, consent withdrawal, deletion, and appeals. They apply to covered consumers under each law, which can include people whose consumer health data is collected in the state as well as residents.

13. Children and Minors

Account holders and Care Circle members must be at least eighteen years old. The Services are not directed to children, and minors may not create or operate their own accounts.

An adult may use the Services to organize a minor's care only when the adult has the legal authority to provide the information, authorize its processing, and make the requested sharing decisions. This is different from collecting information directly from a child operating an account.

An account holder may add people they look after who do not sign in themselves ("dependents"), such as a child. To add someone under eighteen, the account holder must confirm that they are that person's parent or legal guardian; we record who confirmed it and when. A dependent never has an account or sign-in of their own. Their information is visible only to the account holder who added them and is never shared with that account holder's Care Circle. Removing a dependent deletes their records, and deleting the account deletes the records of every dependent it holds.

A parent or guardian does not necessarily have authority over every category of a minor's health information. Applicable law may give a minor control over records relating to care the minor could independently consent to receive. Do not upload or share those records unless you have the required authority or authorization.

If you believe a minor is operating an account, or that information was provided without appropriate authority, contact us. We investigate and take appropriate action, including restricting access or deleting information as required by law.

14. United States Availability

Clargenta AI LLC is based in the United States and offers the Services to users in the United States.

Content you export, or permit another person to download, is outside our control after it leaves the Services.

If you access the Services while outside the United States, you remain responsible for complying with applicable local requirements. That access does not waive rights that applicable law provides.

15. Changes to This Policy

We may update this Policy and revise the Last Updated date. If a change materially affects how we handle health information, we provide prominent notice before it takes effect and obtain consent or authorization where required.

Posting an updated policy does not replace consent required for a new purpose, new data category, or new sharing arrangement. Previously collected information remains subject to applicable legal restrictions and any continuing commitments or permissions governing that information.

16. Contact Us

Clargenta AI LLC
Lenaya Health is a product of Clargenta AI LLC.

Privacy and support: support@lenayahealth.com
Website: https://app.lenayahealth.com

You may use "Privacy Request," "Withdraw Health Data Consent," or "Privacy Appeal" in your email subject to help route your request. A particular subject line is not required to exercise your rights.