Privacy Policy
This Privacy Policy (the “Policy”) explains how Patient Ally Systems, LLC (the “Company,” “we,” “us,” or “our”) collects, uses, and protects information when you use our Website and the SurgiUncle Service. The SurgiUncle Service is designed to provide procedure-specific education and emotional support to the Patient through one Designated User for each Care Episode.
At launch, Designated Users provide information during registration and through text or voice chat. If you use voice features, we may process your voice input, the transcript generated from that input, and related technical information in order to provide the voice interaction, display the transcript, maintain conversational continuity, support safety and quality functions, and provide customer support. Voice interactions are accompanied by on-screen text or a transcript when the applicable Service configuration provides that feature. The Service does not accept medical-record uploads, import records from outside sources, connect to outside health accounts, or collect health information from multiple external sources at launch.
We may update this Policy to reflect changes to the SurgiUncle Service, our information practices, or applicable law. We will post the updated version and identify its effective date. Material changes will be communicated as required by applicable law.
Definitions
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. Personal Information does not include information that is publicly available, de-identified, or aggregated.
“Sensitive Personal Information” means Personal Information that reveals information such as: (a) social security, driver’s license, state identification card, or passport number; (b) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (c) precise geolocation; (d) racial, ethnic, or national origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; (e) the contents of mail, email, and text messages, unless we are the intended recipient of the communication; (f) genetic data; (g) information about a child; (h) biometric information for the purpose of uniquely identifying an individual; (i) mental health, physical health, and pregnancy; (j) sex life or sexual orientation, including status as a trans or nonbinary individual; (k) status as a crime victim; and (l) neural data. Sensitive Personal Information that is publicly available is not considered Sensitive Personal Information or Personal Information. Please note that various jurisdictions may use different terms. For example, some jurisdictions use the terms “personal data” or “sensitive personal data.” Moreover, some jurisdictions do not consider some of the Personal Information listed in the Sensitive Personal Information definition above as Sensitive Personal Information.
“Patient” means the person undergoing or preparing for the selected procedure. The Patient is the subject of the SurgiUncle Service’s procedure-specific education and emotional support.
“Designated User” means the one person registered for the Care Episode as either the Patient or a Caregiver. In this Policy, “User” refers to the Designated User.
“Caregiver” means a Designated User who receives Patient-centered education and support through the SurgiUncle Service for the Patient’s care journey. The Caregiver does not become the Patient.
“Care Episode” means the procedure-specific Service experience associated with one selected procedure, including the free trial of 10 free text messages and 3 free voice messages and, if purchased, a paid 180-day access period. A paid Care Episode begins when the $49 payment is successfully processed. One $25 renewal may extend the same Care Episode for another 180 days. Selecting a different procedure requires a separate Care Episode.
Another person may occasionally participate in a conversation, but that participation does not create a second Designated User, separate access right, or new Care Episode.
Information We Collect and From Whom We Collect It
At launch, we collect the information needed to register and operate the SurgiUncle Service. Users provide information during registration and through text or voice chat. We do not accept medical-record uploads, import records from outside sources, connect outside health accounts, or collect health information from multiple external sources at launch.
Categories of Personal Information and Sources
Identifiers
Information such as your name or alias, email address, account identifier, phone number if provided, IP address, device and browser information, and other identifiers needed to operate and secure the Service. The exact categories collected will depend on the final launch configuration.
Sources: Directly from you during registration and when you communicate with us; automatically from your device or browser when needed to operate, secure, and measure the Service.
Sensitive Information
Health information you choose to provide during registration or through text or voice chat, including your selected procedure, approximate timeline, and optional health conditions. Payment information is handled by our payment processor; we do not store full payment-card details.
Sources: Directly from you during registration and through text or voice chat; through our payment processor when you make a payment.
Internet or Other Electronic Network Activity Information
Information about your interaction with the Service, such as device, browser, log-in, and usage information, if enabled in the final launch configuration.
Source: Automatically from your device or browser, subject to the final launch configuration and applicable consent requirements.
Geolocation Data
We do not intentionally collect precise geolocation at launch. If that changes, we will update this Policy and obtain any consent required by law.
Source: Not intentionally collected at launch.
Health Insurance Portability and Accountability Act of 1996 (HIPAA)
At the current standalone launch, Patient Ally Systems does not intend to operate as a HIPAA covered entity or business associate, and the SurgiUncle Service is not designed to receive health information from a covered entity. If the SurgiUncle Service later integrates with a covered entity, receives patient-specific clinical data, or performs services on a covered entity’s behalf, we will reassess HIPAA status, business associate agreement requirements, and related safeguards before that use.
Purposes for Which We Collect Personal Information
We collect and use Personal Information for the following business or commercial purposes, as applicable:
Identifiers and Sensitive Information
• To register and maintain your account.
• To provide procedure-specific education, emotional support, and customer support.
• To provide and personalize the Service within your Care Episode.
• To process the $49 payment for the initial Care Episode and, if selected, the one-time $25 renewal.
• To maintain short-term and episode-level conversational memory so the Service can respond coherently.
• To send administrative and transactional communications.
• To secure the Service, prevent fraud, debug errors, and comply with law.
• To evaluate and improve the Service using information handled in accordance with this Policy.
• To respond to requests and exercise legal rights.
Internet or Other Electronic Network Activity Information
To operate, secure, debug, and improve the Service, and to understand aggregate use of the Service if analytics are enabled after the final launch configuration is confirmed.
Geolocation Data
Not intentionally collected or used at launch. If geolocation is introduced later, we will disclose the purpose and obtain any consent required by law.
How We Do Not Use Your Personal Information
At launch, we do not sell Personal Information, use it for targeted advertising, or share health information with third parties for their own advertising or marketing. Patient and Caregiver messages, prompts, model outputs, transcripts, voice recordings, and Care Episode memory are not used by Patient Ally Systems or its service providers to train public or general-purpose AI models. Any future use of this information for model training will require separate product and legal review and any notice or consent required by applicable law.
We may consider advertising or behavioral technologies in the future, but any such change will require review of the data involved, updated disclosures, and compliance with applicable consent and privacy requirements. We will not begin using health information for advertising without an appropriate legal and product review.
How We Share Your Personal Information
We may share Personal Information with service providers that help us operate the Service, including providers for hosting and storage, large-language-model processing, speech recognition, text-to-speech or voice generation, payment processing, email delivery, analytics and search-performance tools, error logging, security, and customer support. The data handled by each provider depends on the provider’s role and the applicable Service configuration. Providers may handle account data, chat data, voice data, transcripts, payment information, or technical logs as needed to provide their services. Service-provider use is subject to applicable contractual, privacy, and security requirements.
Other purposes for which we share your information may include:
• At launch, we do not use Personal Information for ad-impression auditing.
• Security and Fraud Detection: We may use and disclose information as reasonably necessary to detect security incidents, prevent fraud, protect the SurgiUncle Service, and investigate unlawful activity.
• Functionality and Debugging: We may disclose information to service providers helping us identify and repair errors that affect intended functionality.
• Short-Term or Transient Use: We do not use health information for advertising at launch. Any future short-term advertising use would require prior review and updated disclosures.
• Services on Our Behalf: We may disclose information to providers that maintain accounts, provide customer support, process payments, provide hosting or email, store data, provide security, or perform similar services for us.
• Advertising and Marketing Services: No advertising or targeted marketing is planned at launch. We will not add these uses without reviewing the data involved, updating disclosures as required, and complying with applicable consent requirements.
• Research and Development: We may use information for internal product development and improvement, subject to the limits and commitments in this Policy.
• Quality Control and Improvement: We may evaluate and improve the Service using aggregated, deidentified, or otherwise permitted information, subject to the restrictions and commitments stated in this Policy.
All such third parties are subject to contractual confidentiality obligations in order to protect your information to the extent commercially reasonable.
We may also use or disclose your Personal Information to resolve disputes, investigate problems, and enforce our Terms of Service or any other agreement with us. We may investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure is (a) reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us; (b) helpful to prevent, investigate, or identify possible wrongdoing in connection with the SurgiUncle Service; or (c) necessary to protect our rights, reputation, property, or that of our users, affiliates, or the public.
In addition, any information we collect, including Personal Information, may be disclosed as part of any merger, acquisition, sale of company assets, or similar transaction, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Information could be transferred to third parties as one of our business assets.
Transactional emails will not include open tracking, click tracking, or other measurement technologies unless the Company confirms and discloses their use before publication. Marketing email tracking is not part of the launch configuration.
Except as stated in this Policy, we do not share, distribute, or release your Personal Information to a third party without notice to you.
Behavioral Advertising, Cookies, and Online Technologies
At launch, the Service uses only technologies consistent with the final approved Service configuration. Strictly necessary technologies may be used to authenticate users, maintain sessions, protect security, and remember required settings. We do not use advertising or targeting cookies, advertising pixels, or behavioral advertising at launch. Any non-essential analytics or search-performance tool will be deployed only after the final configuration is confirmed, any required consent is obtained, and this Policy is updated as required.
Email Communications
The CAN-SPAM Act gives recipients of commercial email the right to have emails stopped from being sent to them. You may unsubscribe from our marketing communications by clicking the “unsubscribe” link found in every commercial email we send, or, if you have an account with us, by sending us a request to unsubscribe at info@surgiuncle.com. If you opt out of receiving our marketing email communications, we may still send you email messages related to your account or specific transactions with us. Unsubscribing from our marketing emails will not affect our service to you or your use of the SurgiUncle Service.
Data Retention
We retain account information, text conversations, voice transcripts, and Care Episode memory during the applicable Care Episode and for six months after the final paid access period ends, including any permitted renewal. If a Designated User uses the free trial but does not purchase paid access, the applicable retention period will be determined before launch. Raw voice recordings and generated audio will be retained only for the period reasonably necessary to provide the applicable feature, unless a different period is disclosed before launch. We may retain limited payment, security, audit, and dispute-related information for longer periods when required by law or reasonably necessary for those purposes. Retention periods for trial data, raw audio, generated audio, transcripts, support records, logs, and backups depend on the applicable Service configuration and legal requirements.
Links to Other Websites
This Policy applies only to the SurgiUncle Service as provided by us. The SurgiUncle Service may contain links to other websites, which may be subject to a different privacy policy or are otherwise maintained or provided by a third party. We are not responsible for the privacy practices of any third-party website you access from the SurgiUncle Service. You should review the privacy policy of every website before using the SurgiUncle Service or submitting any information to the SurgiUncle Service.
Children
No part of the SurgiUncle Service, or any services made available through the SurgiUncle Service, is designed for, directed to, or intended to attract children under the age of 18. No Personal Information is knowingly collected from any person under the age of 18.
Your Rights
Depending on where you live, you may have rights involving access, correction, deletion, portability, appeal, opt-out choices, sensitive Personal Information, and protection against discrimination for exercising privacy rights. The rights available to you and the procedures for submitting requests depend on applicable law and the jurisdictions in which the Service is offered.
• Access the Personal Information we hold about you.
• Correct inaccurate information.
• Request deletion of your data.
• Export a copy of your data.
To exercise these rights, contact us at info@surgiuncle.com, and we will respond in accordance with applicable law. Note that deleting your account will end your ability to access the SurgiUncle Service.
Security
We use commercially reasonable safeguards, including TLS encryption in transit for Service connections and access controls designed to protect Personal Information, subject to the controls implemented throughout the launch architecture. No data transmission or storage system can be guaranteed to be completely secure.
No data transmission over the Internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we strive to protect your Personal Information using commercially available and industry-standard encryption technology, we cannot ensure or guarantee the security of any information you transmit to us, and you do so at your own risk.
If we determine that your Personal Information has or may reasonably have been disclosed due to a security breach of our systems, we will notify you in accordance with and to the extent required by applicable state and federal law using the information that we have on file.
Changes to This Policy
We may update this Privacy Policy from time to time to reflect, for example, changes to our practices or for other operational, legal, or regulatory reasons. The “Last Updated” date will reflect changes, and we will communicate material changes with you as appropriate. Your continued use of the SurgiUncle Service after changes constitutes acceptance.
Contact Us
If you have any questions or concerns about this Privacy Policy, our privacy practices, or access to your Personal Information, please contact us at info@surgiuncle.com.