Privacy Policy
HIPAA Compliant
PHI handled under BAA
SOC 2 Type II
Annually audited security
No Data Selling
We never sell your data
Overview
Curely AI, Inc. ("Curely AI," "we," "our," or "us") is committed to protecting the privacy and security of the information we process in connection with our healthcare AI platform, products, and services (collectively, the "Services"). This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our Services, visit our website at curely.ai (the "Site"), or interact with us.
This policy applies to all users of our Services, including healthcare organizations, clinicians, administrators, and individuals who interact with our platform. It does not apply to information that is subject to a separately executed Business Associate Agreement (BAA) with a covered entity, which is governed by the terms of that agreement and applicable law.
Important Notice for Healthcare Customers
If you are a covered entity or business associate under HIPAA and have executed a BAA with Curely AI, the handling of Protected Health Information (PHI) under that agreement takes precedence over this general Privacy Policy to the extent of any conflict.
By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree, please discontinue use of the Services.
Information We Collect
A. Information You Provide Directly
- Account registration information: name, work email address, organization name, job title, and password.
- Contact and inquiry information: information submitted through our "Request Demo" form, contact forms, or email correspondence, including your name, email, phone number, and the content of your message.
- Payment information: billing address, payment method details (processed by our PCI-DSS-compliant payment processors; we do not store raw card numbers).
- Communications: records of your correspondence with us, including support tickets, feedback, and survey responses.
- Professional credentials: for clinician-facing features, professional license numbers and verification data you submit.
B. Information Collected Automatically
When you access our Site or Services, we automatically collect certain technical information through cookies, web beacons, and similar technologies:
- Log data: IP address, browser type and version, operating system, referral URLs, pages viewed, time and date of visits, and clickstream data.
- Device information: device identifiers, hardware model, operating system version, and mobile network information.
- Usage data: features accessed, actions taken within the platform, session duration, and performance telemetry.
- Location data: approximate geographic location derived from IP address (city/region level; we do not collect precise GPS coordinates from website visitors).
C. Information from Third Parties
- Integration data: when you connect third-party electronic health record (EHR) systems or data sources to our platform, we receive data according to the permissions you configure.
- Identity providers: if you authenticate via single sign-on (SSO) through a third-party identity provider, we receive the profile information you authorize that provider to share.
- Business partners: information from our resellers, implementation partners, or referral sources in connection with your relationship with them.
- Publicly available data: information available in public professional databases (e.g., NPI registry) for credential verification purposes.
D. Protected Health Information (PHI)
Curely AI processes PHI solely as a Business Associate on behalf of covered entities and other business associates pursuant to a signed BAA. See the for full details on how PHI is handled.
How We Use Information
We use the information we collect for the following purposes:
Providing and Improving Our Services
- Delivering, operating, and maintaining the Curely AI platform and its features.
- Processing transactions and managing your account.
- Providing customer support and responding to your inquiries.
- Training, evaluating, and improving our AI models and platform features — using only de-identified, aggregated, or synthetic data unless you have provided separate written consent for identifiable data use.
- Developing new products, features, and services.
- Monitoring platform performance, security, and infrastructure stability.
Communications
- Sending transactional communications such as account confirmations, password resets, billing receipts, and service notifications.
- Sending product updates, release notes, and security advisories relevant to your use of the Services.
- Sending marketing communications about our products and services (you may opt out at any time; see the Your Rights section).
- Responding to your requests, inquiries, and feedback.
Legal and Safety Purposes
- Complying with applicable laws, regulations, legal process, and governmental requests.
- Enforcing our Terms of Service and other agreements.
- Detecting, investigating, and preventing fraud, abuse, security incidents, and other harmful or illegal activity.
- Protecting the rights, property, and safety of Curely AI, our customers, and the public.
Analytics and Research
- Analyzing usage patterns to understand how our Services are used and to guide product development.
- Conducting internal research and publishing aggregate insights about healthcare AI trends (no individual-level data is included in publications).
HIPAA & Protected Health Information
HIPAA Business Associate
Curely AI operates as a HIPAA Business Associate. We process PHI only under the terms of a signed Business Associate Agreement (BAA) with each covered entity or business associate customer. A BAA is required before any PHI may be transmitted to or processed by our platform.
What Constitutes PHI in Our Context
PHI includes any individually identifiable health information created, received, maintained, or transmitted by our platform on behalf of a covered entity, including: patient names, dates of service, diagnoses, treatment information, clinical notes, lab results, imaging data, and any other data that could identify a patient.
How We Handle PHI
- PHI is processed only as directed by the covered entity customer and only for permitted purposes under the BAA and HIPAA.
- PHI is stored in dedicated, logically isolated environments with encryption at rest (AES-256) and in transit (TLS 1.3).
- Access to PHI is restricted to authorized personnel on a need-to-know basis, enforced through role-based access controls and audit logging.
- PHI is not used to train general-purpose AI models without explicit written authorization and appropriate de-identification.
- We maintain breach notification procedures consistent with the HIPAA Breach Notification Rule (45 C.F.R. §§ 164.400–414).
- Upon termination of a BAA, PHI is returned to the covered entity or securely destroyed in accordance with the agreement.
HIPAA Security Rule Compliance
We implement and maintain administrative, physical, and technical safeguards as required by the HIPAA Security Rule (45 C.F.R. Part 164, Subpart C), including workforce training, access management, audit controls, and transmission security. Our compliance posture is reviewed annually by an independent third party.
Patient Rights Under HIPAA
Individual patients whose PHI is processed by Curely AI on behalf of a covered entity must exercise their HIPAA rights (access, amendment, accounting of disclosures, etc.) directly with the covered entity, which is the relevant Covered Entity for HIPAA purposes. Curely AI will cooperate with covered entities to facilitate patients' HIPAA rights as required by our BAA.
Data Security
We take data security seriously and implement comprehensive measures to protect the information we process. Our security program is built around the principle of defense in depth and includes:
Technical Safeguards
- Encryption at rest using AES-256 for all stored data, including database fields, file storage, and backups.
- Encryption in transit using TLS 1.3 for all data transmitted between clients and our infrastructure.
- Multi-factor authentication (MFA) enforced for all employee access to production systems.
- Network segmentation and zero-trust architecture limiting lateral movement within our infrastructure.
- Intrusion detection and prevention systems (IDS/IPS) monitoring network traffic in real time.
- Automated vulnerability scanning and penetration testing conducted quarterly by independent security firms.
- Immutable audit logs for all access to sensitive data, retained for a minimum of 7 years.
Organizational Safeguards
- Annual security awareness training for all employees and contractors with access to customer data.
- Background checks for all employees with access to PHI or sensitive customer data.
- Formal vendor risk management program evaluating the security posture of all sub-processors.
- Incident response plan with defined response times, escalation procedures, and customer notification protocols.
- SOC 2 Type II audit conducted annually; reports available to customers under NDA upon request.
Your Responsibilities
While we implement robust security measures, security is a shared responsibility. You are responsible for maintaining the confidentiality of your account credentials, configuring appropriate access controls within your organization, and promptly notifying us of any suspected unauthorized access to your account.
No method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your information, we cannot guarantee absolute security. In the event of a security breach that affects your data, we will notify you as required by applicable law.
Data Retention
We retain different categories of data for different periods, based on the nature of the data, our legal obligations, and legitimate business purposes:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account information | Duration of account + 3 years | Contract & legal |
| PHI (under BAA) | Per BAA terms (typically 6–10 years) | HIPAA & BAA |
| Audit logs | 7 years minimum | Legal & compliance |
| Usage & analytics data | 2 years (anonymized after 90 days) | Legitimate interest |
| Support communications | 3 years from resolution | Legitimate interest |
| Payment records | 7 years | Legal obligation |
| Backup data | Rolling 90-day window | Business continuity |
When retention periods expire, data is securely deleted or anonymized using industry-standard methods. Upon written request, we can provide more specific information about the retention of your particular data.
Your Rights
Depending on your jurisdiction and the nature of your relationship with us, you may have certain rights regarding your personal information. We honor all applicable rights under GDPR, CCPA/CPRA, and other applicable privacy laws.
Rights Available to All Users
- Right to access: request a copy of the personal information we hold about you.
- Right to correction: request correction of inaccurate or incomplete personal information.
- Right to deletion: request deletion of your personal information, subject to legal retention requirements.
- Right to opt out of marketing: unsubscribe from marketing communications at any time using the unsubscribe link in any email or by contacting us at privacy@curely.ai.
- Right to data portability: request your personal information in a structured, machine-readable format.
Additional Rights for EEA, UK, and Swiss Residents (GDPR)
- Right to object: object to processing of your personal data for direct marketing or legitimate interests.
- Right to restrict processing: request restriction of processing under certain circumstances.
- Right to withdraw consent: where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing.
- Right to lodge a complaint: file a complaint with your local supervisory authority (e.g., your national Data Protection Authority).
Additional Rights for California Residents (CCPA/CPRA)
- Right to know: request disclosure of the categories and specific pieces of personal information collected, sold, or disclosed about you in the past 12 months.
- Right to opt out of sale or sharing: we do not sell personal information; however, you may submit a request via our Do Not Sell My Personal Information link.
- Right to limit sensitive personal information: request that we limit our use and disclosure of sensitive personal information to purposes permitted by CPRA.
- Right to non-discrimination: exercise your privacy rights without receiving discriminatory treatment.
To exercise any of these rights, contact us at privacy@curely.ai or through our Contact page. We will respond to verifiable requests within 30 days (or as required by applicable law). We may need to verify your identity before processing certain requests.
International Data Transfers
Curely AI is headquartered in the United States. If you access our Services from outside the United States, your information may be transferred to and processed in the United States or other countries where our service providers operate.
For transfers of personal data from the European Economic Area (EEA), United Kingdom, or Switzerland to the United States, we rely on:
- Standard Contractual Clauses (SCCs) approved by the European Commission, incorporated into our Data Processing Agreements.
- The EU-U.S. Data Privacy Framework, UK Extension to the Data Privacy Framework, and Swiss-U.S. Data Privacy Framework, to the extent Curely AI maintains certification.
- Binding Corporate Rules where applicable.
Healthcare customers with specific data residency requirements (e.g., data must remain in the EU or a specific country) may request dedicated regional deployment. Contact your account team for more information.
Children's Privacy
Our Services are not directed to children under the age of 16, and we do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe your child has provided us with personal information, please contact us at privacy@curely.ai and we will take steps to delete that information.
Note: Our clinical platform may process health information about minor patients as PHI under a BAA with a covered healthcare entity. In such cases, the covered entity is responsible for compliance with applicable laws governing the health information of minors (e.g., FERPA, state minor consent laws).
Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will:
- Update the "Last updated" date at the top of this policy.
- Post a prominent notice on our Site or within the platform for at least 30 days.
- Send an email notification to registered account holders.
- For material changes affecting PHI processing, provide advance notice as required by applicable BAA terms.
Your continued use of the Services after the effective date of a revised policy constitutes your acceptance of the changes. If you do not agree to the revised policy, you may close your account and cease using the Services.
Previous versions of this policy are available upon request.
Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Privacy Team
privacy@curely.ai
Response within 2 business days
Data Protection Officer
dpo@curely.ai
For GDPR-specific inquiries
Mailing Address
Curely AI, Inc.
123 Health Innovation Drive
Gayaza, Uganda
Legal
legal@curely.ai
For legal process and subpoenas
If you are not satisfied with our response to your privacy inquiry, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction. For EEA residents, this is your national Data Protection Authority. For UK residents, this is the Information Commissioner's Office (ICO) at ico.org.uk.
