1. Who we are.
The data controller is Conceptual Healthcare Corporation (Texas, USA). Our 11 Conceptual Health® properties — Guardian Orb™, Clinical, Provider AI, hc.exchange, Datavault, Pharmacy, Chain, University, Church, Social, and the marketing front door — operate under one HIPAA Notice of Privacy Practices. The Patient Ombudsperson, who reports to the Trust Council and not to the CEO, has independent authority to investigate any privacy concern.
2. What we collect.
- Account data — name, email, phone, password (hashed with Argon2id), preferred name, language, time zone.
- Identity verification (KYC) — government ID image, selfie, address, last four of SSN, fraud-detection signals — collected through Stripe Identity, processed under Stripe's BAA, stored encrypted with envelope keys.
- Health information — medications, allergies, conditions, family history, vitals, sleep and movement signals (if you connect a wearable), pharmacy fills, encounter notes, lab results, imaging where applicable, and the eight-axis Master Equation™ measurements.
- Insurance & payment — payer, plan, member ID, claim history we touch, ACH or card data (tokenized), HSA/FSA data where applicable.
- Device & usage — IP, user-agent, app version, page views, button presses, error logs. Aggregated for product analytics; not sold.
- Wallet & chain data — your CH wallet address, public mints (HCRs you have earned), redemptions you have authorized. The wallet address is yours; we do not custody the private key on your behalf unless you opt in to Datavault recovery.
3. Why we collect it.
To provide care, to compute the Master Equation™ axes accurately, to mint Health Credit Receipts that are verifiable, to bill payers and accept payments, to verify identity for safety and regulatory reasons, to investigate misuse and fraud, to comply with HIPAA, to respond to lawful requests, and to improve the products we ship. We do not sell personal information to third parties. We do not sell health information, period.
4. Who sees it.
- Your care team — clinicians and pharmacists you have selected.
- Conceptual Health® staff — only those whose role requires access. All access to your record is logged; you can read your own access log on demand.
- Service providers (BAAs in place) — Stripe (payments & KYC), Twilio (SMS), AWS (infrastructure), NAVEX (ethics line), DocuSign (consents), and our laboratory partners for ordered tests.
- Trust Council — receives only aggregated, de-identified statistics; never your record.
- Validators — receive cryptographic proofs of HCR validity. Validators do not receive your underlying health record; they verify the math, not the medical detail.
- Government & legal — when required by law, in response to a valid subpoena, court order, or in good-faith belief that disclosure is necessary to prevent imminent harm.
5. The chain and on-chain data.
The chain is public; what is on it is permanent. Only the following is on-chain: your wallet address (a pseudonymous string), Health Credit Receipts (an axis lift, a magnitude, a timestamp, and a hash to off-chain evidence — the receipt itself does not contain your name or any PHI), and Trust Council governance actions. Your underlying health record stays off-chain, encrypted, in your patient vault. We have designed the chain so that, if you delete your account, no part of your medical record can be reconstructed from chain data alone.
6. HIPAA.
We are a HIPAA-covered entity. You may request, in addition to the rights below: a copy of your designated record set, an accounting of disclosures, an amendment, an alternative communications channel, and a restriction request. Our Notice of Privacy Practices is available at the Trust Center. To file a HIPAA complaint, contact privacy@conceptualhealth.com; you may also file directly with the U.S. Department of Health and Human Services Office for Civil Rights without retaliation.
7. Retention.
Medical records are retained for the longer of: the period required by the law of the state where care was delivered (typically 7–10 years), the period required to support open insurance claims, and 7 years from the date of last activity. KYC records are retained for 5 years from account closure (BSA/Reg-A). Marketing analytics are retained in aggregated form for up to 24 months. Account data is deleted within 30 days of account closure, except for records we are legally required to keep.
8. Your rights.
Subject to law, you may: access your record, correct inaccuracies, request deletion, request portability (an export in a machine-readable format), object to certain processing, withdraw any non-essential consent, request restriction, and lodge a complaint with a regulator. Residents of California (CCPA/CPRA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), and the EU/UK/EEA (GDPR/UK GDPR) have rights specific to their jurisdiction; the principles above apply to everyone, the procedures track local law. We respond within 30 days; we do not charge a fee for a first request in any 12-month period.
9. International transfers.
We host primarily in the United States. Data may be transferred to other jurisdictions for legitimate purposes (e.g., a patient seeking care while abroad). For EU/UK/EEA personal data, we rely on Standard Contractual Clauses (SCCs), the UK IDTA, and supplementary measures including encryption-in-transit and at-rest, access logging, and minimum-necessary access.
10. Changes to this policy.
Material changes are announced at least 30 days before they take effect, with email notice to active members. The version history of this policy is itself published on the chain (governance log) so changes are auditable. The current version is 4.1, effective 2026-01-01.
11. How to reach us.
Privacy Office, Conceptual Healthcare Corporation, 720 Harbor Blvd, Destin, FL 32541. privacy@conceptualhealth.com · 1-800-CHC-PRIV. Patient Ombudsperson: ombuds@conceptualhealth.com.