Privacy Policy: Ambient Clinical Intelligence Platform

Effective Date: July 15, 2026

This Privacy Policy describes how Oncology Solutions LLC (“Company,” “we,” “us,” or “our”) collects, uses, stores, discloses, and safeguards personal information and Protected Health Information (PHI) processed through our medical ambient listening software, applications, APIs, and associated services (collectively, the “Platform” or “Services”).

This policy is specifically tailored to the unique privacy demands of ambient clinical recording, automated clinical documentation, and medical terminology processing.

1. Scope & HIPAA Compliance
2. Information We Collect & How We Collect It
3. The Ambient Data Lifecycle (Audio Deletion Policy)
4. How We Process Your Information
5. Sharing and Disclosure of Information
6. AI Model Training & Data Safeguards
7. Enterprise Security & Encryption
8. Your Rights and Choices
9. State Privacy Laws
10. Changes to This Policy & Contact Info

1. Scope & HIPAA Compliance

This Privacy Policy applies to licensed healthcare professionals, clinical staff, and enterprise health systems (collectively, “Users” or “Providers”) utilizing the Oncology Solutions LLC ambient scribe platform.

Business Associate Agreement (BAA) Status: Our Services are designed for use with Protected Health Information (PHI) governed by the Health Insurance Portability and Accountability Act (HIPAA). As of the date of this policy, we have not yet executed a Business Associate Agreement with individual Users or with our infrastructure and AI sub-processors. Until a BAA is executed and in effect for your account, do not enter real, individually identifiable patient information anywhere in the Platform (full name, date of birth, medical record number, or similar) — use a de-identified handle such as initials or a private code for the patient-identifier field, which the Platform is designed to accept in place of a formal identifier. We will update this Privacy Policy and notify Users before processing identifiable PHI under an executed BAA.
Precedence: If and when a Business Associate Agreement is executed between us and a User or covered entity, its terms will control over this Privacy Policy and our Terms of Use with respect to any Protected Health Information (PHI) covered by that agreement.

2. Information We Collect & How We Collect It

A. User Account & Credential Information (Disclosed by You)

We collect registration and identity verification details to ensure only authorized, licensed professionals access the Platform:

Professional Credentials: Name, National Provider Identifier (NPI), medical specialty, clinical license numbers, and affiliated healthcare institution.
Account Credentials: Email address and an optional phone number. The Platform is passwordless — sign-in uses a one-time code sent to your email, verified against your NPI, rather than a stored password.

B. Ambient Audio & Clinical Consultation Data (Collected in Real-Time)

During patient-provider consultations, when actively initiated by the Provider, the Platform captures:

Ambient Audio Recordings: Temporary raw audio of the verbal dialogue between the clinician, patient, and any present third parties.
Encounter Transcripts: Automated text transcripts generated from the captured audio.
Generated Notes: Structured clinical summaries, SOAP notes, and patient instructions generated by our clinical AI.

C. Automated Operational Logs (Collected Automatically)

To maintain security, track audit logs required by HIPAA, and diagnose technical errors, we automatically record:

Device Details: IP address, browser type, operating system, hardware model, and unique device identifiers.
Access Metrics: Timestamps of logins, recording starts/stops, and note-generation activity.

3. The Ambient Data Lifecycle (Audio Deletion Policy)

To limit data exposure and safeguard patient privacy, Oncology Solutions LLC operates on a strict transient storage workflow for all voice and conversational data:

Raw Audio: Audio is streamed to our transcription provider for processing and is not written to durable storage on our servers at any point — it exists only transiently in memory/temporary files for the duration of that processing request.
Transcripts, Notes, and Related Data: Once saved, the transcript, generated note, coding, and toxicity data for an encounter are retained for a fixed 24-hour window and then automatically and permanently deleted — this applies uniformly to every encounter and every User; it is not configurable per institution or hospital agreement.

4. How We Process Your Information

Oncology Solutions LLC processes your data strictly for legitimate clinical, administrative, and security purposes:

Clinical Note Generation: Utilizing advanced machine learning models to synthesize ambient conversations into accurate, structured medical draft notes.
Credential & Licensing Audits: Validating NPI numbers against national registries to prevent credential fraud or unauthorized clinical access.
HIPAA Compliance Auditing: Maintaining immutable audit logs of which authorized accounts accessed, modified, or exported clinical data.

We do not sell, license, or rent patient clinical data or provider information. We only share information under the following strictly controlled circumstances:

With Infrastructure and AI Vendors: We use third-party providers for hosting, database storage, and AI-based transcription and note generation. As noted in Section 1, Business Associate Agreements with these vendors are not yet executed — see that section for what this means for real patient information today.
For Legal & Safety Mandates: Where required by federal law, court order, or to defend against legal claims, or to protect the safety and security of patients and clinicians.

6. AI Model Training & Data Safeguards

AI Providers Used: Transcription and note generation are performed by sending encrypted requests over HTTPS to third-party AI providers (currently OpenAI for transcription and Anthropic for note generation). These are the same providers’ standard API products, not a dedicated private deployment we operate — see Section 1 for BAA status with these providers.
Model Training: Under these providers’ standard API terms, data submitted through their APIs is not used to train their general-purpose models by default. We do not separately use your clinical inputs to train any model of our own.

7. Enterprise Security & Encryption

We utilize robust administrative, physical, and technical safeguards designed to exceed industry healthcare standards:

Data in Transit: All audio transmissions, API payloads, and metadata are encrypted in transit via HTTPS/TLS, including HTTP-Strict-Transport-Security (HSTS) so browsers never fall back to an unencrypted connection.
Data at Rest: Our database provider encrypts all stored data at rest using AES-256.
Access Control: Sign-in requires a one-time code sent to your verified email (no password to be phished or reused), and sessions automatically time out after a period of inactivity. We do not currently offer a second authentication factor beyond the one-time code, or role-based permission tiers beyond a single administrative role used for internal oversight.

8. Your Rights and Choices

As a licensed clinical user, you maintain control over your data:

Audio Interruption: You can pause, stop, or delete a live ambient recording at any point during a clinical encounter.
Access & Edits: You have the right and duty to review, edit, and correct any draft note the Platform generates before relying on it.
Data Access and Deletion: You can request a full export of everything we hold about your account, or request permanent deletion of your account and all associated data, by contacting us at the email below. Deletion is irreversible and, once processed, removes your encounters, notes, preferences, and account record — see Section 1 for how PHI handling changes once a BAA is in effect.

9. State Privacy Laws

Hei Atlas is currently used directly by individual licensed practitioners who sign up themselves, rather than exclusively through institutional or hospital contracts. Whether a particular state consumer privacy law (such as the California Consumer Privacy Act or the Colorado Privacy Act) applies to your use of the Platform, and to what extent, depends on your specific circumstances and jurisdiction. We are not asserting a blanket exemption from state privacy law here, and you should not rely on this policy as legal advice about which laws apply to you. If you have questions about your rights under a specific state law, please contact us using the information in Section 10.

10. Changes to This Policy & Contact Info

We may update this Privacy Policy from time to time to reflect evolving regulatory frameworks or new software capabilities. When changes are made, we will update the “Effective Date” at the top of this document and provide prominent notifications inside your provider dashboard.

For compliance audits, questions regarding this policy, or concerns about data processing, please contact us at:

Oncology Solutions LLC
Email: compliance@oncologysolutions.us