Privacy Policy

1. Introduction

Interoperly LLC ("Interoperly," "we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal and health information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our healthcare data infrastructure platform and related services.

We comply with the Health Insurance Portability and Accountability Act (HIPAA), the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other applicable privacy laws and regulations.

2. Information We Collect

2.1 Health Information

With your explicit consent, we may collect:

• Continuous glucose monitoring (CGM) data
• Health metrics from connected devices and wearables (e.g., Apple HealthKit)
• Electronic Health Record (EHR) data via authorized integrations
• Self-reported health information
• Medication and treatment information

2.2 Account Information

• Name and contact information
• Account credentials
• Communication preferences

2.3 Technical Information

• Device information and identifiers
• Log data and usage analytics
• IP address and location data

3. How We Use Your Information

We use collected information to:

• Provide and improve our healthcare data infrastructure services
• Generate predictive insights and health analytics
• Train our causal inference AI models (using only de-identified, aggregated data)
• Enable clinical decision support for authorized healthcare providers
• Facilitate secure data exchange between authorized parties
• Ensure platform security and prevent fraud
• Comply with legal and regulatory requirements
• Conduct research (with explicit consent and in de-identified form)

4. Data Sharing and Disclosure

We may share your information with:

• Healthcare Providers: With your consent, to support your care
• Business Associates: Service providers bound by HIPAA-compliant agreements
• Legal Requirements: When required by law or legal process
• Research Partners: In de-identified or aggregated form, with consent

We never sell your personal health information to third parties.

Furthermore, we will not use or disclose to third parties user data gathered from the Apple HealthKit API for advertising, marketing, or other use-based data mining purposes other than improving health management or for the purpose of medical research.

5. Data Security

We implement industry-leading security measures including:

• AES-256 encryption for data at rest
• TLS 1.3 encryption for data in transit
• Zero-trust architecture with continuous verification
• Role-based access controls (RBAC)
• Immutable audit logging
• Regular security assessments and penetration testing
• SOC-2 compliant infrastructure

6. Your Rights

Depending on your location (e.g., California residents under CCPA/CPRA, or EU residents under GDPR), you have specific rights regarding your data, including:

• Access: Request a copy of your personal data
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your data (subject to legal retention requirements)
• Portability: Receive your data in a structured, machine-readable format
• Revocation: Withdraw consent at any time
• Restriction: Request limitation of data processing

To exercise these rights, contact us at legal@interoperly.com.

7. Data Retention

We retain your information only as long as necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our agreements. Health data retention periods are configurable and comply with applicable healthcare regulations.

8. Children's Privacy

Our services are not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided us with personal information, please contact us.

9. International Data Transfers

If you are accessing our services from outside the United States, your information may be transferred to, stored, and processed in the United States. We ensure appropriate safeguards are in place for international transfers in compliance with applicable data protection laws.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date.

11. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us:

Interoperly LLC
San Francisco Bay Area, CA
Email: legal@interoperly.com
General: hello@interoperly.com