Arxova Consumer Health Data Policy

Consumer health data is personal information that is linked or reasonably linkable to you and that identifies your past, present, or future physical or mental health. It includes information that is derived or inferred, such as a score or an AI-generated insight, and information that suggests you are seeking health care. Nearly everything Arxova holds about you is consumer health data, and we treat it that way.

We do not collect your device's precise location. When you search for research studies, we use a coarse location, such as your state, taken from your profile.

• You, when you enter information, upload documents or genomic files, scan cards, or talk to ARIA.
• Health systems, through their patient portals, when you connect them through Fasten Health.
• Devices and health apps you connect: Apple Health, Android Health Connect, Samsung Health, Garmin (through ROOK), Oura, WHOOP, Withings, Polar, Strava, and Sensor Bio.
• Clinics you give access to, which can add their own care records.
• Your Circle contacts, when they reply to a message.
• Arxova's own systems, which create scores, alerts, insights, and matches from the information above.

We do not buy consumer health data.

We collect and use consumer health data to:

• bring in, store, organize, and display your health information;
• calculate scores, trends, and alerts, and send you notifications and reminders;
• provide ARIA and the other AI features described in Section 8;
• carry out sharing that you start: share links, clinic access, Circle messages, and research steps;
• match you to research studies if you opt in, and count community insights if you opt in;
• understand how the app is used and fix problems;
• protect the Service, detect misuse, and keep security logs;
• respond to your requests and support questions; and
• comply with the law.

We do not use consumer health data for advertising. If we want to collect new categories of consumer health data, or use or share it for new purposes, we will update this policy and ask for your consent first where the law requires it.

Consent to collect. Before setting up a new account, the app asks for your consent to collect and use your health data, and confirms you are 18 or older. Earlier accounts were not asked for specific health-data collection consent beyond the Privacy Policy acceptance. They are asked the next time they open the updated app; until they answer, collection continues, including wearable syncs and incoming records. If you decline or withdraw this consent, or tell us you are under 18, we stop all new collection: no new wearable data, no new records. The app stays locked until you consent again or delete your account.

Separate consent to share. Collection consent does not replace separate sharing consent where the law requires it. Sharing with people, clinics and research teams happens through your own actions, such as creating a share link, giving a clinic access, adding a Circle contact, or consenting to research. Each has its own step, and you can end each one. Service providers also receive information as described in Sections 7–9, including default-on analytics.

AI features. The app asks separately whether to allow AI features. Until you allow them, no AI features run for your account, including background features. Declining or withdrawing stops them, as explained in Section 8.

People and organizations you choose. We share consumer health data with these recipients only after you take the step described.

Service providers. The companies in Section 7 receive consumer health data only to provide their service to Arxova.

Legal requirements. We may disclose consumer health data when the law requires it, such as in response to a valid court order or subpoena.

Affiliates. Arxova has no affiliates that receive consumer health data.

These companies receive information from Arxova. For services involving clinic protected health information, we require the appropriate Business Associate Agreements and service configurations before processing that information.

Some services are connected in our code but not in use today: Stripe (payments), Persona (identity verification), MoonPay, and Jupiter. If we start using one, we will update this list.

We require service providers to use your information only to provide their service to Arxova.

ARIA and several other features use Claude, an AI service from Anthropic, PBC. We use Anthropic’s commercial AI services. We do not authorize Anthropic to use information sent through these services to train its models. A Business Associate Agreement is required before these services process protected health information on behalf of a clinic.

When your information is sent to Anthropic:

• ARIA chat;
• ARIA's memory of earlier conversations;
• building a map of how your health information connects;
• finding patterns in your data;
• daily insights and proactive messages, which are prepared in the background even when you have not opened ARIA;
• doctor and visit summaries;
• tagging meals you log;
• choosing search terms for article citations;
• reading documents you upload; and
• reading photos of insurance or implant cards.

What is sent. A capped, minimized snapshot of your information, not your whole history. Depending on the feature, it can include records, lab results, medications, supplements, symptoms, wearable data, notes, cycle information, a genomics summary, scores, alerts, ARIA's memory, and recent conversation. Your name is removed from the health record before ARIA sees it, and no account details, email, phone number, address, or device identifiers are attached. Card photos, documents, and the text you type are sent as they are and can include your name or other details. Because dates, clinicians, and clinical notes can remain, we treat everything sent to Anthropic as health information, not as de-identified data. Anthropic keeps information only as allowed by its retention terms with us.

Your choice. The app asks separately whether to allow these AI features. Until you allow them, no AI features run for your account, including background features such as morning insights. Older app versions cannot show this choice, so AI features do not work on them until you update the app and answer. If you decline or later withdraw in Settings, AI features stop. Earlier ARIA permissions have been retired; they are not treated as permission under the new choice.

ARIA’s answers, scores, and alerts are informational and may be inaccurate. They are not medical advice or final clinical decisions. Automated research matching can affect which studies you see; the study team makes final eligibility and enrollment decisions.

Security and technical logs help us run the Service, protect accounts and investigate errors. They are separate from the product analytics described below. The app’s analytics switch does not stop necessary security and operational logging.

Product analytics. We use PostHog to understand how the app is used. App analytics is on by default; we have not asked for a separate app-analytics permission. You can turn off analytics events sent by the app in Settings. Some usage events are sent from Arxova’s servers, and the setting does not stop those. This switch controls the app events described here; it does not stop necessary sign-in, security or operational logging.

Since September 30, 2026, events are limited to an approved list of feature-use events, contain no health values, and are tied to a pseudonymous identifier derived from your account, not to your name or email. Events sent before that date included limited health details, such as a symptom type or a daily step total, and some were tied to your wallet address. Which features you use can suggest something about your health, for example using a glucose feature, so we treat these events as consumer health data.

On our website, PostHog loading is controlled by the cookie-choice banner. The app’s analytics setting does not control website cookies. There are no advertising, attribution, or social media tracking tools in the app, and no AppsFlyer SDK. Some of our marketing links use AppsFlyer OneLink to send you to the right app store; when you tap one, AppsFlyer records the click.

Research is optional. Arxova does not sell health data and does not pay participants. Clinics and research institutions pay Arxova for the matching infrastructure; that fee is not payment for your data.

Research matching. If you opt in, Arxova checks your clinical records against study criteria. Wearable data is not used. Matching is automated and happens inside Arxova. Before you agree to a study, researchers see only counts, which are rounded, and broad characteristics, such as top conditions and age bands, of the people waiting. They do not see who you are. Opting out stops matching immediately.

Pre-screening by a clinical site. A clinical site that pre-screens you sees your eligibility result only after you sign a HIPAA authorization for that study. You can revoke it.

Joining a study. After you complete a study’s consent and any required privacy authorization, that study team receives your name, contact details (email, phone, address, and date of birth), and the records relevant to the study so they can enroll you. From then on, the study's consent form and the study team's own policies also apply. Information already delivered to a study team cannot be pulled back by Arxova.

Finding studies. To find studies on ClinicalTrials.gov, we send a condition term, an age, and a coarse location. We do not attach your name or account identifier. The condition, age and coarse location are still health-related search information.

No re-identification. We do not try to re-identify de-identified data, and our researcher terms require researchers not to re-identify it either.

After you withdraw. Your data is removed from research datasets within 30 days.

Community insights. If you opt in, your conditions and symptom types are counted each month, without identifying you in the published counts. Nothing about a condition is shown until at least 50 people with that condition have joined. If you opt out, your counts are removed. Your opt-in or opt-out is recorded on-chain with a random reference.

Arxova does not sell consumer health data. We do not sell it, rent it, or trade it, to advertisers, data brokers, insurers, employers, pharmaceutical companies, or anyone else. Fees that clinics and research institutions pay Arxova are for the matching infrastructure, not for your data, and we do not pay participants.

We do not use consumer health data for targeted advertising, and we do not allow third parties to collect it through Arxova to track you across other websites or apps. We do not set up geofences around health care facilities, and we do not use location to identify or track people seeking health care or to send them messages or ads.

You have the right to:

• confirm whether we collect, share, or sell your consumer health data;
• access your consumer health data, and receive a list of every third party and affiliate we have shared it with, and an email address or other online way to contact each of them;
• delete your consumer health data;
• withdraw your consent to our collection and sharing of your consumer health data;
• correct inaccurate consumer health data, where the law gives you that right;
• appeal if we decline your request (Section 15); and
• be free from discrimination for using these rights. We do not penalize you for exercising a privacy right. Some features cannot work without the information they need; withdrawing the general health-data consent currently locks the app as described in Section 5. You can still make requests by email.

In the app:

• Access: Settings, "Download a copy of my data."
• Correct: on a document, imaging report, note, lab history, or prescription, use "Report a problem with this record." This opens an email to us naming the record type, date, and source, without the record's contents. We fix errors in how Arxova received, processed, or displayed a record. The original record can only be corrected by the health system that created it, and we will tell you how to ask them. Information you entered yourself, you can change or remove.
• Withdraw consent: the health data consent, AI features, research, and community insights can be withdrawn in Settings. Connections can be disconnected in the app. Section 18 of the Privacy Policy lists what each withdrawal stops and what remains.
• Delete: Settings, "Delete account."

By email: write to privacy@arxova.health with the subject "Consumer Health Data Request" and say which right you want to use. Use this route for anything you cannot do in the app, including the list of third parties and affiliates.

Verifying your request. If you write to us from outside the app, we verify that the request comes from the account holder, for example by confirming the email on your account or asking you to sign a message with your wallet. We ask only for what we need to verify you. Where the law allows, an authorized agent may make a request for you; we may ask for proof of their authority and confirm the request with you.

Timing and cost. We respond within 45 days of receiving your request, or within a shorter period required by law. Where applicable law permits an extension, we will notify you within the initial response period and explain the reason and permitted extension. We apply a shorter deadline where required. For deletion requests sent by email, we commit to a shorter time: we complete them within 30 days (Section 16). Requests are free.

If we decline your request, in whole or in part, we will tell you why. You can appeal by emailing privacy@arxova.health with the subject "Consumer Health Data Appeal," including enough detail for us to find your original request. We will respond to your appeal in writing within 45 days and explain our decision.

If your appeal is denied, or you are not satisfied, you can file a complaint with your state attorney general:

• Washington: https://www.atg.wa.gov
• Nevada: https://ag.nv.gov
• Connecticut: https://portal.ct.gov/ag

You can also contact the U.S. Federal Trade Commission. The "Make a privacy complaint" option in Settings opens an email to us and points you to these authorities.

How. In Settings, "Delete account." Deletion starts immediately and runs automatically, with retries until it finishes. You can also email privacy@arxova.health; we complete deletion requests sent by email within 30 days.

What is deleted automatically:

• your account data in Arxova’s active databases, including imported records, shares, ARIA history and settings, subject to the specific retained records listed below;
• the encryption keys we hold in active systems for your Arweave copies; backup copies of those keys expire within 5 days;
• your Privy sign-in account;
• your billing records at RevenueCat and Stripe, if any exist; and
• Arxova's access to your Strava, Garmin (through ROOK), Oura, WHOOP, Polar, and Withings accounts.

What our team deletes by hand: your analytics profile at PostHog, and any records at Persona or Twilio.

What we cannot reach: Fasten Health and Sensor Bio do not offer a way for us to delete data or end the connection. Where available, revoke Arxova in the connected health system’s patient portal or your Sensor Bio account. If you cannot find that option, contact the provider or privacy@arxova.health for help. We do not send account-deletion notices to Anthropic, Fasten Health or Sensor Bio. Information previously sent to Anthropic is subject to its retention terms under our agreement, including our Business Associate Agreement. These describe current technical limits; they do not waive your deletion rights or excuse notices and cooperation required by applicable law. Email us if a provider-held copy needs attention.

What is kept:

• records a clinic created in its care workspace stay with the clinic, no longer linked to your account;
• consent records and security logs are kept without your identity;
• database backups containing your data expire within 5 days;
• encrypted copies on Arweave remain permanently; access depends on whether any usable key or plaintext copy remains;
• public labels on Arweave objects and Solana receipts written before October 1, 2026 remain; and
• We retain a one-way hashed reference derived from your account’s wallet address, together with the time and reason your sign-in sessions were ended, to keep sign-in tokens issued before deletion invalid. The original wallet address is not retained in this session-revocation record. This restricted security reference is not used for research, advertising, or analytics.

Inactive accounts. We do not delete accounts for inactivity. An account and its data stay until you delete it.

We protect consumer health data with encryption at rest and in transit, access controls, separation of encryption keys from data, logging and monitoring, and vendor agreements. Arxova has a SOC 2 Type 1 report covering the Security criteria, as of August 31, 2026, issued by Percilchofe CPA LLC on September 23, 2026. An independent penetration test is underway. No system is perfectly secure. If a breach affects your information, we will notify you and the authorities as required by the FTC Health Breach Notification Rule, by HIPAA where Arxova acts for a clinic, and by state law.

Arxova is not a HIPAA covered entity. Consumer health data is protected by these state laws whether or not HIPAA applies. When a clinic uses Arxova's clinic console, Arxova acts as the clinic's business associate, and the clinic's own Notice of Privacy Practices applies to the records the clinic creates. We sign a Business Associate Agreement with each clinic before it uses Arxova. For services involving clinic protected health information, we require the appropriate Business Associate Agreements and service configurations before processing that information.

Arxova is for adults 18 and older. We do not knowingly collect consumer health data from anyone under 18. If you tell us on the consent screen that you are under 18, we stop collecting health data for that account. If you believe a child is using Arxova, contact privacy@arxova.health and we will delete the account.

We will post any change here with a new effective date. When a change is material, the updated app tells you and asks you to accept the updated terms before you continue. Declining signs you out. Older app versions do not enforce this screen, and our servers currently do not block access solely because updated terms have not been accepted. While that screen is shown, you can accept, sign out, or open the Delete Account page to request deletion by email. For other requests, such as a copy of your data, email privacy@arxova.health.

HealthKey Labs, LLC's Founder and Chief Executive Officer is responsible for this policy and for Arxova's privacy program. You can reach the Founder and Chief Executive Officer at privacy@arxova.health.

Everyone at Arxova with access to personal data completes privacy and security training, and we review our privacy and security practices at least once a year.

HealthKey Labs, LLC d/b/a Arxova
382 NE 191st St PMB #924568
Miami, FL 33179
United States

Privacy email: privacy@arxova.health
Website: https://arxova.health
Privacy Policy: https://arxova.health/privacy-policy
Consumer Health Data Policy: https://arxova.health/consumer-health-data-policy