Privacy Policy

Flexway LLC ("Flexway", "we", "our", or "us") provides software, technology, analytics, artificial intelligence, patient engagement, and operational support services that help healthcare practices manage continuous care programs through web applications, mobile applications, integrations, and related services (collectively, the "Services").

This Privacy Policy describes how Flexway collects, uses, processes, discloses, stores, and protects information when healthcare practices, healthcare professionals, patients, and other users access or use the Services.

Flexway is a technology company.

Flexway does not provide medical services, medical advice, diagnoses, treatment plans, prescriptions, or clinical care.

Healthcare providers and healthcare organizations using the Services are solely responsible for patient care, medical records, diagnoses, prescriptions, treatment decisions, and all clinical decisions.

Flexway provides software and technology infrastructure used by healthcare practices.

Healthcare practices may use Flexway to:

• Create and manage patient accounts
• Invite patients into care programs
• Deliver patient programs
• Collect patient-submitted information
• Review patient progress
• Analyze patient data
• Coordinate care activities
• Manage communications
• Monitor outcomes
• Receive summaries, insights, signals, analytics, and workflow support generated by the platform

Healthcare practices generally create, control, and manage patient participation within the Services.

Patients typically access Flexway-powered applications only after being invited, enrolled, or authorized by a healthcare practice.

Flexway does not independently provide patient care programs and patients do not generally enroll into healthcare programs directly through Flexway.

Patient accounts are maintained on behalf of healthcare practices.

Healthcare practices remain responsible for their patient relationships, clinical workflows, treatment methodologies, and healthcare services.

Flexway provides technology infrastructure intended to support and scale healthcare practice operations and patient engagement programs.

Medical services, diagnoses, prescriptions, treatment decisions, healthcare communications, and all clinical decisions remain the responsibility of the healthcare practice and its providers.

Flexway processes information on behalf of healthcare practices in order to provide the Services.

Healthcare practices generally determine the purposes for which patient information is collected and used in connection with their care programs.

Flexway generally processes patient information on behalf of healthcare practices in order to provide the Services.

Patients seeking access, correction, deletion, export, or restriction of patient information should generally contact the healthcare practice responsible for their care. Flexway may assist healthcare practices in responding to such requests where appropriate and legally permitted.

Information Provided by Healthcare Practices

We may collect:

• Practice information
• Provider information
• Professional credentials
• Contact information
• Billing information
• Practice settings and configuration data
• Program configuration information

Information Provided by Patients

Patients may provide information including:

• Name
• Email address
• Phone number
• Date of birth
• Profile information
• Photos
• Documents
• Voice recordings
• Messages
• Questionnaires
• Survey responses
• Device data
• Health-related information
• Other information voluntarily submitted through the Services

Device and Technical Information

We may automatically collect:

• IP address
• Device identifiers
• Browser information
• Operating system information
• Usage information
• Access logs
• Diagnostic information
• Error reports
• Security logs

Where enabled by a healthcare practice and authorized by a patient, Flexway may receive information from:

• Wearables
• Health devices
• Laboratory providers
• Pharmacy providers
• Logistics providers
• Fulfillment providers
• Partner services
• Third-party integrations

Patients control whether supported devices and integrations are connected to the Services.

Flexway may use cookies, local storage, session technologies, and similar technologies to:

• Authenticate users
• Maintain active sessions
• Remember preferences
• Improve platform performance
• Analyze usage of the Services
• Support security functions
• Detect abuse or unauthorized activity

Flexway does not use third-party advertising cookies.

Users may adjust browser settings to limit or disable cookies, although some features of the Services may not function properly.

Patients may upload photos, documents, voice recordings, and other content through the Services.

Such content may be stored in its original form and may also be processed using automated technologies, including:

• Computer vision systems
• Speech recognition systems
• Natural language processing technologies
• Machine learning technologies
• Artificial intelligence technologies

The purpose of such processing may include:

• Content organization
• Timeline generation
• Summarization
• Transcription
• Trend analysis
• Progress tracking
• Workflow support

Flexway uses artificial intelligence technologies as part of the Services.

Artificial intelligence systems may be used to:

• Analyze uploaded photos
• Analyze uploaded documents
• Process voice recordings
• Generate transcripts
• Organize information
• Build patient timelines
• Generate summaries
• Identify trends and changes
• Create patient cohorts
• Generate analytics
• Support provider workflows
• Identify adherence issues
• Detect potential risks or barriers

Flexway may use third-party artificial intelligence providers, models, and technologies located in the United States or other jurisdictions.

Such providers, models, and technologies may change over time.

Whenever reasonably possible, information may be de-identified, anonymized, pseudonymized, or otherwise transformed before processing.

Flexway does not use identifiable patient information to train public artificial intelligence models.

Artificial intelligence technologies may also be used to analyze patient-submitted photos of medications, supplements, devices, home diagnostic tests, product packaging, labels, and other materials in order to organize information, extract relevant details, support documentation workflows, generate analytics, and improve care coordination.

Artificial intelligence technologies may support healthcare practices by identifying trends, barriers, adherence patterns, patient cohorts, workflow opportunities, and operational insights.

Artificial intelligence outputs are intended to support healthcare practices in implementing and scaling their own methodologies, workflows, and patient programs.

Flexway does not independently diagnose conditions, prescribe treatments, determine treatment plans, or make medical decisions.

Artificial intelligence outputs are intended solely to assist healthcare practices and do not constitute medical advice, diagnosis, treatment, or clinical decision-making.

Healthcare providers remain solely responsible for reviewing information and making all clinical decisions.

Flexway may provide operational and administrative support services on behalf of healthcare practices.

Such support may include:

• Platform support
• Order support
• Fulfillment support
• Delivery support
• Logistics coordination
• Customer service activities
• Program administration

Flexway personnel do not provide medical advice or clinical services.

Patient-facing applications may contain:

• Educational content
• Wellness information
• Product recommendations
• Service recommendations
• Partner offers
• Sponsored content
• Promotional content

Certain products or services may be offered by healthcare practices, third-party providers, partners, or Flexway.

Flexway may act as merchant of record for certain non-medical products or services.

Medical services, prescriptions, and clinical services are provided by independent healthcare providers and healthcare organizations.

Sponsored content, partner offers, promotional content, or advertisements may be displayed only where permitted by the applicable healthcare practice and, where required by law, with patient consent.

Flexway does not require healthcare practices to display advertisements, sponsored content, or partner offers.

Where Flexway receives commissions, referral fees, platform fees, transaction fees, revenue-sharing payments, or other commercial benefits, such arrangements may be disclosed in applicable agreements, ordering flows, product information, or other relevant notices.

Flexway does not sell identifiable patient information to advertisers.

Medical decisions remain the responsibility of healthcare providers and are not influenced by commercial relationships.

We may use information to:

• Provide the Services
• Operate the platform
• Authenticate users
• Support healthcare practices
• Process patient submissions
• Generate patient timelines
• Produce analytics
• Generate reports
• Respond to support requests
• Maintain security
• Detect fraud or abuse
• Comply with legal obligations
• Improve products and services
• Develop new features and functionality

We may create and use de-identified, anonymized, aggregated, statistical, or non-identifiable information.

Such information may be used for:

• Research
• Product development
• Platform improvement
• Artificial intelligence development
• Machine learning improvement
• Outcome analysis
• Benchmarking
• Industry analysis
• Publications
• Analytics
• Business operations
• Development of Flexway intelligence, reporting, and analytical systems

Such information is not intended to identify any individual patient, healthcare provider, or healthcare practice.

Flexway may own and use platform intelligence, analytics systems, benchmark reports, de-identified intelligence systems, artificial intelligence systems, machine learning models, operational intelligence, aggregated insights, reporting systems, and Flexway technology developed from or using de-identified, anonymized, aggregated, statistical, or non-identifiable information.

Flexway may send:

• Account notifications
• Security alerts
• Service notices
• Push notifications
• Email communications
• SMS communications where permitted by law
• Program reminders
• Task notifications
• Adherence reminders
• Engagement communications
• Refill reminders
• Educational content

Healthcare practices may also use the Services to communicate with patients.

Healthcare practices are responsible for obtaining any consents or authorizations required for messages they send or configure through the Services.

Users may be able to opt out of certain communications, although some operational, transactional, security, or care-related communications may be necessary to provide the Services.

Marketing communications may be provided where permitted by applicable law and may be discontinued through available opt-out mechanisms.

We may share information with:

• Healthcare practices using the Services
• Cloud infrastructure providers
• Hosting providers
• Payment processors
• Analytics providers
• Artificial intelligence providers
• Security providers
• Compliance providers
• Laboratories
• Pharmacies
• Device providers
• Fulfillment providers
• Logistics providers
• Suppliers
• Integration partners
• Professional advisors
• Service providers supporting platform operations

We may also disclose information:

• To comply with legal obligations
• To protect rights, safety, or security
• During a merger, acquisition, financing, restructuring, or sale of assets
• With user consent

Authorized Flexway personnel may access information when necessary to:

• Provide support
• Maintain operations
• Troubleshoot issues
• Investigate incidents
• Comply with legal obligations
• Assist healthcare practices

Access is limited based on business need and subject to security controls and audit logging.

Healthcare practices control patient information submitted through the Services.

Healthcare practices generally control patient participation in healthcare programs delivered through the Services.

Patient accounts are maintained on behalf of healthcare practices as part of the Services.

Flexway provides technology infrastructure supporting healthcare practices and does not claim ownership of patient-provider relationships.

Flexway processes patient information on behalf of healthcare practices in order to provide the Services.

Patients may request access, correction, export, or deletion of information through their healthcare practice or directly through Flexway where permitted by applicable law.

Information is retained only as long as necessary to:

• Provide the Services
• Meet contractual obligations
• Comply with legal requirements
• Resolve disputes
• Protect rights and interests

When information is no longer required, it may be deleted, anonymized, or de-identified.

If a healthcare practice ceases using the Services, information may be retained, archived, transferred, exported, or deleted depending on contractual obligations, healthcare record retention requirements, applicable law, regulatory obligations, and instructions received from the healthcare practice.

Where legally permissible and no retention obligations apply, information may be permanently deleted.

Information may be stored and processed in the United States.

Flexway uses HIPAA-compatible infrastructure and service providers where applicable.

Authorized service providers may process information on behalf of Flexway under contractual confidentiality and security obligations.

Where applicable, Flexway may act as a Business Associate under HIPAA and may enter into Business Associate Agreements ("BAAs") with healthcare practices, healthcare providers, healthcare organizations, or other covered entities and business associates.

To the extent Flexway creates, receives, maintains, or transmits protected health information on behalf of a covered entity or business associate, Flexway will use and disclose such information in accordance with applicable law and the applicable BAA.

If this Privacy Policy conflicts with an applicable BAA regarding protected health information, the BAA will control.

Flexway maintains administrative, technical, and organizational safeguards designed to protect information.

Security measures may include:

• Encryption in transit
• Encryption at rest
• Role-based access controls
• Audit logging
• Multi-factor authentication
• Secure cloud infrastructure
• Security monitoring

No system can guarantee absolute security.

Flexway may notify healthcare practices, users, patients, regulators, or other affected parties as required by applicable law, applicable agreements, or applicable Business Associate Agreements following a security incident, unauthorized disclosure, or breach involving protected information.

Where protected health information is involved, notification timing, content, investigation, mitigation, and cooperation obligations will be handled in accordance with HIPAA, applicable Business Associate Agreements, and applicable law.

The Services are not intended for individuals under the age of 18 to use independently.

Healthcare practices may, where permitted by law, invite or authorize minors to use Flexway-powered applications with involvement, consent, or authorization from a parent, guardian, or legally authorized representative.

Flexway does not knowingly collect personal information directly from children under 18 except as directed or authorized by a healthcare practice, parent, guardian, or legally authorized representative, and as permitted by applicable law.

California residents may have additional rights regarding access, correction, deletion, and disclosure of personal information under applicable California privacy laws.

Flexway does not sell identifiable patient information.

To the extent Flexway processes personal information as a service provider or business associate on behalf of a healthcare practice, requests should generally be directed to the healthcare practice responsible for the individual's care or account.

Individuals may also contact Flexway using the contact information below, and Flexway may assist the applicable healthcare practice where appropriate.

Depending on applicable law, individuals may have rights to:

• Access information
• Correct information
• Delete information
• Export information
• Restrict processing
• Withdraw consent where applicable

Requests may be submitted through the healthcare practice responsible for the individual's care or directly to Flexway where appropriate.

We may update this Privacy Policy from time to time.

Updated versions will be posted with a revised effective date.

Flexway LLC

5900 Balcones Drive #17513 Austin, TX 78731 United States

support@flexway.ai