Consumer Health Data Privacy Policy

Why this policy exists

Several states — including Washington (My Health My Data Act), Nevada (SB 370), and Connecticut — require companies that handle consumer health data to publish a dedicated health data privacy policy and to obtain consent before collecting or sharing that data. This policy meets those requirements.

Legacy Pulse applies this policy to every user, in every state, rather than only where the law requires it. We designed to the strictest standard so that your protections do not depend on your address.

Categories of consumer health data we collect

Because Legacy Pulse is a health record vault, most of what you store with us is consumer health data. The categories we collect are: health records and documents you upload (such as lab reports, visit summaries, imaging reports, discharge papers, and immunization records); individual health observations extracted from those documents (lab values, vital signs, measurements, medications, and immunizations, each with its source); health information contained in phone-health exports you choose to import (for example, an Apple Health export); and information that identifies whose health data a record is — the family member profile it belongs to.

Derived data counts too. The structured entries, search indexes, and summaries that Legacy Pulse creates from your records are treated as consumer health data with the same protections as the records themselves.

Genomic data is a special case: Legacy Pulse does not currently accept genomic files and does not analyze genetic information. See the Genomic File Notice.

Where this data comes from

Consumer health data enters Legacy Pulse from exactly one place: you. You upload documents, you import phone-health exports, and you create the family profiles that records are filed under. We do not buy health data, we do not receive it from data brokers, and we do not collect it from your browsing activity on other sites.

Environmental context (such as air quality for your zip code) comes from public environmental sources. It describes your area, not your body, and it is presented as context and awareness only — never as health guidance.

Why we collect it and how we use it

Consumer health data is processed only to deliver your vault, search, and summaries: preserving your original files; organizing uploads into source-linked entries; answering your questions from your own records, with citations; generating the summaries you request; and securing and supporting the service, including the audit trail of material actions on your account.

We do not use consumer health data for advertising, for marketing profiles, or to train AI models. We do not make automated decisions about you that have legal or similarly significant effects.

Consent

We ask for your affirmative consent before collecting or processing your consumer health data, at the moment you start using the features that involve it. Each consent is recorded with a timestamp and the version of the notice it covered, and you can withdraw it in Settings at any time.

State law requires a separate, distinct consent before consumer health data may be shared with third parties for their own purposes. Legacy Pulse does not share consumer health data with anyone for their own purposes and does not sell it — so we do not ask for sharing consent, and no such sharing occurs. The service providers described below process data on our behalf, under our instructions, which is not sharing for their own use.

Service providers (processors)

A small number of contracted service providers process consumer health data on our behalf and only on our instructions: cloud hosting, database, and file storage providers, which store your encrypted files and entries; and our AI provider, which processes document content and questions to produce entries and answers, under contract terms that prohibit training on your data and limit retention.

Each provider is bound by contract to use the data only to provide its service to us, to protect it, to notify us of security incidents, and to delete it when we instruct. We maintain a current list of these providers and will supply it on request through the contact below.

We do not sell or share consumer health data

We do not sell your health data, and we do not provide it to third parties for their own purposes. There is no version of Legacy Pulse in which your family's health records are a product sold to someone else.

Because we do not sell consumer health data, no person or organization holds a valid authorization to purchase it from us.

Your rights and how to exercise them

You have the right to: know what consumer health data we have collected about you and which service providers have processed it; access that data and export a portable copy; correct it, including flagging AI-extracted values as disputed; withdraw any consent you previously gave; and delete it.

Deletion is complete. When you delete a document, a profile, or your account, the deletion cascades through everything derived from that data — extracted entries, search indexes and embeddings, and summaries — and we instruct our service providers to delete the corresponding data they process for us. Backup copies are cleared within 90 days.

To exercise these rights, use Settings (for export, correction, consent withdrawal, and all three deletion scopes) or write to the contact address below. We will verify that the request comes from you before acting on it, and we will confirm what was done.

If we decline a request, you may appeal by replying to our response or writing to the contact address with the word "Appeal". A person who was not involved in the original decision will review the appeal and respond within the time state law allows. If you are unsatisfied with the outcome, you may contact your state attorney general.

Scope note: Washington, Nevada, and Connecticut

This policy is written to satisfy the Washington My Health My Data Act, Nevada SB 370, and Connecticut's consumer health data provisions, which are currently the most protective state frameworks. Residents of those states have all rights described here, including the right to appeal. Residents of other states receive the same treatment as a matter of Legacy Pulse policy.

California residents: the rights in this policy operate alongside your rights under the California Consumer Privacy Act, including access, correction, deletion, and the right to limit use of sensitive personal information. Exercising them works the same way — through Settings or the contact below.

Contact

Questions about this notice, or requests you would rather not make in the app, can be sent to privacy@lgc.my. You can also exercise most of your choices directly in Settings.

We respond to privacy requests within the timelines required by applicable law, and we will always tell you what we did in response.