DRAFT — NOT FOR EXECUTION — MUST BE REVIEWED BY A QUALIFIED ATTORNEY BEFORE PUBLICATION OR USE

Privacy Policy

Last updated: [DATE — DRAFT ONLY]

1. Who we are

PHIGuard, Inc. ("PHIGuard," "we," "us," or "our") operates the PHIGuard platform available at phiguard.app. PHIGuard provides HIPAA-native task management and compliance software for medical clinics and other covered entities under HIPAA.

For questions about this Privacy Policy, contact us at: privacy@phiguard.app

2. Scope of this policy

This Privacy Policy describes how PHIGuard collects, uses, and discloses information about:

This policy does not apply to Protected Health Information (PHI) that your clinic enters into the PHIGuard application. PHI submitted by your clinic is governed by our Business Associate Agreement with your clinic, not by this Privacy Policy. Your clinic (as a covered entity) remains responsible for its PHI under HIPAA.

3. Information we collect

3.1 Account and contact information

When you create a PHIGuard account, we collect: name, email address, clinic name, and billing information (processed by our payment processor — we do not store full card numbers). We use this information to provide the service, send administrative communications, and fulfill our contractual obligations.

3.2 Usage data

We collect usage data about how administrators and staff use the PHIGuard application, including: feature usage, login timestamps, and error logs. This data is used to improve the product, troubleshoot issues, and maintain security. Usage data does not include the content of tasks or records containing PHI.

3.3 Marketing site analytics

Our public marketing website (phiguard.app) uses PostHog analytics to understand visitor behavior. PostHog analytics are present only on the public marketing site — never inside the PHIGuard application (behind authentication). We do not use session replay, third-party advertising pixels, or tracking technologies inside the authenticated application.

3.4 Communications

If you contact us by email, we retain your correspondence for customer service and legal purposes.

4. How we use your information

We use information we collect to:

We do not sell, rent, or share your personal information with third parties for their marketing purposes.

5. PHI handling

PHIGuard is a Business Associate under HIPAA. When your clinic uses PHIGuard to create or manage tasks that contain Protected Health Information, that PHI is governed by our Business Associate Agreement with your clinic. Key points:

6. Third parties

PHIGuard uses the following categories of third-party service providers for the application. All providers who may process PHI have signed Business Associate Agreements with PHIGuard:

No third-party JavaScript, analytics, session replay, or advertising technology is present inside the authenticated PHIGuard application. PostHog analytics are present only on the public marketing site.

7. Data retention

Account data is retained for the duration of your active subscription. Upon account termination, account data and task records are retained for 30 days before secure deletion, giving you time to export your records.

Audit log records are retained for a minimum of six years in compliance with HIPAA records retention requirements (45 CFR §164.530(j)). Audit logs cannot be deleted by customers or PHIGuard staff during the retention period.

Backup copies of data may be retained for up to [PERIOD — TO BE DETERMINED] following deletion of the primary copy, after which backups are securely destroyed.

8. Your rights

Depending on your jurisdiction, you may have rights regarding your personal information, including rights to access, correct, delete, or export your account data. To exercise these rights, contact privacy@phiguard.app.

Note: rights regarding PHI are governed by HIPAA and are exercised through your clinic (as the covered entity), not directly through PHIGuard.

9. Security

We implement technical and organizational measures to protect your information. See our Security page for details. To report a security concern, contact security@phiguard.app.

10. Changes to this policy

We will post material changes to this Privacy Policy on this page with an updated effective date. For significant changes affecting PHI handling, we will notify clinic administrators directly.

11. Contact

PHIGuard, Inc.
privacy@phiguard.app

DRAFT — NOT FOR EXECUTION — MUST BE REVIEWED BY A QUALIFIED ATTORNEY BEFORE PUBLICATION OR USE