Consumer Health Data Privacy Policy

1. Who this policy covers

This policy is for anyone whose health information CallDear handles, and in particular for residents of Washington State, where the My Health My Data Act calls it “consumer health data”. It is provided by Nova Digital Systems LLP, Stoney Works, 8 Stoney Lane, London SE19 3BD, United Kingdom, the partnership that runs CallDear.

It adds to our Privacy Policy, which covers all the information we handle. If the two ever seem to differ about health information, the more protective one applies.

2. Health data we collect, and why

• What the person tells the assistant in calls about their physical or mental health: how they feel, their mood, sleep, pain or symptoms, medicines, doctor’s or hospital visits, and similar. We keep it in call transcripts and, for a short time, in technical call logs.
• What the family tells us when setting up the calls: for example the person’s age, health topics to ask about or avoid, and questions about their health for the assistant to ask.
• What our service produces from calls: summaries for the family, memory notes the assistant keeps so it can ask how a doctor’s visit went, and alerts when something said suggests the person may be unwell or in danger.

We use this information only to:

• let the assistant talk with the person naturally and remember what they told it;
• tell the family, in a short summary, how the person is, in their own words where it matters;
• alert the family members who agreed to receive alerts when something worrying comes up;
• check that the assistant’s replies are safe and accurate, and fix problems.

The assistant collects health information in calls only after the person has agreed to the calls in their own words, in the recorded consent call described in our Calling & Consent Policy. The consent question tells them that the assistant remembers their conversations, lets the family know how they are, and passes on anything worrying. Before the person agrees, we hold only what the family has entered in the family app, and use it only to set up the calls and to place the consent call. CallDear is not a healthcare provider: we do not diagnose, and a summary is not a medical record.

3. Where it comes from

• The person themselves, in what they say during calls.
• The family members who set up the calls, in what they enter in the family app.
• Our service, which produces summaries, memory notes and alerts from the calls.

We do not buy health information or get it from any other source.

4. What we share, and with whom

What we share

• Summaries, alerts and memory notes that mention the person’s health or mood.
• The words of calls, as they are turned into text and answered during the call.
• Call transcripts and notes, when a summary or alert is written after the call.

With whom

• Family members on the account: they see summaries and alerts, as the person agreed in the consent call. Alerts go only to family members who agreed to receive them.
• Service providers that work for us: the telephone network, speech recognition, the assistant’s voice, language models that write replies, summaries and alerts, our server and backup storage, and text-message and email delivery. Each one is named in our Privacy Policy, with what it receives and under which terms.
• Others only when the law requires it, or to protect someone’s life or safety, as described in our Privacy Policy.

We do not share consumer health data with any affiliate.

5. What we never do

• We never sell health information.
• We never use it for advertising, or share it so that others can advertise.
• We never collect it in calls without the person’s consent, or use it for a new purpose without asking them again.
• We never use location-based tracking (geofencing) around places where health care is given.
• We never let other companies collect health information about you over time or across other websites through this website or the family app: neither runs advertising or tracking tools.

6. Your rights

The person whose health information it is has the right to:

• Know and see it: ask whether we collect or share their health information, get a copy of it, and get a list of every third party we shared it with, with an email address or other way to contact each of them.
• Withdraw consent: stop the calls at any time, by saying so in a call or by email (see the Calling & Consent Policy). From then on we collect no new health information about them. To remove what we already hold, also ask us to delete it.
• Correct it: ask us to fix health information that is wrong or incomplete. Family members can also change the person’s profile and topics themselves in the family app.
• Have it deleted: we delete it from our systems within 30 days, except the consent records described in section 8, and our backup copies lose it about 30 days later. We also tell the service providers that received it, and ask those that may still hold a copy, such as ElevenLabs’ history of generated speech, to delete it.

To use these rights, write to privacy@calldear.com. The person can write themselves, or someone can write for them with their permission. We may need to confirm that the request really comes from them, for example by checking with the email address or phone number on the account; you do not need to create an account to ask.

We answer without undue delay, and in any case within 45 days of receiving the request. If we need more time, we tell you so, and why, within those 45 days, and take no more than 45 days longer. Requests are free, at least twice a year.

7. Appeals

If we turn down a request, you can appeal: reply to our answer, or write to privacy@calldear.com with “Appeal” in the subject line. We decide an appeal within 45 days and tell you in writing what we decided and why. If we turn down your appeal, you can complain to the Washington State Attorney General at atg.wa.gov/file-complaint.

8. How long we keep it

Word-for-word call transcripts are deleted automatically after 90 days, and technical call logs after 30 days. Summaries, memory notes and alerts are kept while the family account is active, and are deleted within 30 days after the account is closed or the person’s information is deleted at their or their family’s request. Backup copies are deleted about 30 days after they are made. The full list is in our Privacy Policy.

So that we can show the calls were made with consent, the records of the consent call itself (the notice, the consent question and the answer) are kept for 7 years after the last event connected with them: the consent call, the last call made with that consent, its withdrawal, or the deletion of the person’s information. While the person is still registered with us, we keep their most recent consent record (a yes, a no or a request to stop) until a newer one replaces it or their information is deleted, because it is what tells us whether we may call them.

9. Changes and contact

If we change this policy, we post the new version here with a new effective date. If a change is material, we tell family account holders by email before it takes effect. Before we collect or use health information in a new way, we ask for consent again.

Questions: privacy@calldear.com. Our contact details are on the Contact page.