Privacy Policy

1. Who we are and what this covers

LifePath ("LifePath," "we," "our," or "us") is a family centered care coordination service operated by QuesGen Systems, Inc., 1325 Howard Ave, #437, Burlingame, CA 94010. This Privacy Policy explains how we handle information when you use the LifePath website, web application, and related services (together, the "Service").

This policy covers information we handle as a consumer service that you use directly. In some cases LifePath may instead handle health information on behalf of a healthcare organization that is a HIPAA covered entity. Where that is true, that organization's agreement with us (including any Business Associate Agreement) governs that information, and this consumer policy does not apply to it. [CONFIRM WITH COUNSEL WHICH MODEL APPLIES.]

By using the Service you agree to this policy. If you do not agree, please do not use the Service.

2. Information we collect

Information you give us

• Account information: your name, email address, password, and, if you choose, a phone number.
• Care profile and health information: the information you enter to coordinate care, such as medications and schedules, appointments, care team contacts, care history, wellness check ins (sleep, mood, appetite, energy, pain), and logged symptoms. This may relate to you or to a person you care for.
• Circle and sharing information: the people you invite as helpers, their contact information, and the access level you assign them.
• Billing information: handled by our payment processor. We receive limited details such as billing contact, plan, and the last four digits and type of card. We do not store full card numbers. [CONFIRM PROCESSOR, e.g. Stripe.]
• Communications: messages you send us, support requests, and survey or feedback responses.

Information we collect automatically

• Device and log data: IP address, browser type, operating system, referring and exit pages, and date and time stamps.
• Usage data: features used and general activity, which helps us keep the Service secure and improve it.
• Cookies and similar technologies: described in Section 8.

3. Health and other sensitive information

Much of what LifePath stores is health information about you or someone you care for. We treat this as sensitive information. We use it only to provide and support the Service as described in this policy, and we apply the protections in Section 10.

We do not use your health information for advertising, and we do not disclose it to third parties for their own marketing. Under California law you may limit our use of sensitive personal information, as described in Section 11, although in practice we already restrict our use of health information to running the Service.

4. Information about other people

LifePath is built for coordinating someone else's care, so you will often enter information about another person, such as a parent, partner, or someone you assist. When you do this:

• You confirm that you have the authority or permission to provide that information and to let us process it to provide the Service.
• Where appropriate, you are responsible for telling that person that their information is kept in LifePath and for sharing this policy with them.
• If the person a profile is about wants to access, correct, or delete their own information, they (or you on their behalf) can contact us, and the profile owner can also manage access from within the Service.

If you believe information about you is held in LifePath without your knowledge, contact us at privacy@quesgen.com and we will help.

5. How we use information

We use information to:

• provide, maintain, and improve the Service, including care profiles, reminders, and the AI Companion;
• set up accounts, authenticate users, and manage circle access;
• process payments and manage subscriptions;
• respond to your requests and provide support;
• send service messages (for example, security alerts, reminders you have enabled, and account notices), and, only with your consent, occasional product updates you can opt out of at any time;
• keep the Service secure, prevent abuse, and protect our rights and the safety of users; and
• comply with law.

What we do not do: we do not sell your information, we do not use your health information to target advertising, and we do not provide your information to third party AI companies to train their models.

6. The AI Companion and automated processing

The AI Companion reviews information in a care profile to surface summaries, reminders, and possible patterns (for example, a symptom that tends to follow a medication). It runs on a self hosted model. Your health information is not sent to third party AI providers and is not used to train external models.

The AI Companion is an informational tool. It can be wrong or incomplete and it is not medical advice or a substitute for professional judgment. It does not make decisions that produce legal or similarly significant effects about you on its own. Always confirm important matters with a qualified professional. See the Terms of Service for the full disclaimer.

7. How we share information

We share information only as described here:

• Within your circle: with the helpers and members you invite to a care profile, at the access level you set.
• Service providers: with vendors who process information on our behalf to run the Service, such as cloud hosting, payment processing, and email delivery. They may use the information only to perform services for us. [MAINTAIN A CURRENT SUBPROCESSOR LIST.]
• Legal and safety: when we have a good faith belief that disclosure is reasonably necessary to comply with law or legal process, enforce our terms, prevent fraud or security issues, or protect the rights, property, or safety of LifePath, our users, or the public.
• Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to this policy continuing to govern your information.
• With your direction or consent: when you ask us to share information or otherwise agree.

We do not sell personal information, and we do not share it for cross context behavioral advertising, as those terms are used under California law.

8. Cookies, tracking, and your signals

We use cookies and similar technologies to keep you signed in, remember your preferences, keep the Service secure, and understand how it is used so we can improve it. Standing alone, cookies do not identify you by name.

We use analytics tools to measure traffic and improve the Service. [NAME ANALYTICS PROVIDER AND LINK ITS PRIVACY INFORMATION, e.g. Google Analytics.]

Global Privacy Control and Do Not Track: some browsers and extensions send a Global Privacy Control (GPC) signal. Where required by law, we treat a GPC signal from your browser as a valid request to opt out of any sale or sharing for that browser. Because browsers handle Do Not Track inconsistently, we do not currently respond to other Do Not Track signals.

9. How long we keep information

We keep information for as long as your account is active and as needed to provide the Service. After you close an account or delete a profile, we delete or de identify the associated information within a reasonable period, except where we must keep certain records to comply with law, resolve disputes, or enforce our agreements. We will describe specific retention periods in our internal data retention schedule. [SET RETENTION PERIODS.]

10. How we protect information

LifePath is built on QuesGen's audited infrastructure. We encrypt information in transit and at rest, apply access controls and audit logging, and limit access to those who need it to operate the Service. [CONFIRM AND DESCRIBE CURRENT CONTROLS AND CERTIFICATIONS, e.g. SOC 2 Type 2.]

No method of transmission or storage is completely secure, so we cannot guarantee absolute security. We work to protect your information using measures appropriate to its sensitivity, and we ask that you protect your account by using a strong password and keeping your credentials private.

11. Your privacy rights

Rights available to everyone

Subject to applicable law, you can ask us to:

• access the information we hold about you;
• correct information that is inaccurate;
• delete your information;
• export a copy of information you provided in a portable format; and
• withdraw consent where we rely on it.

You can do much of this yourself inside the Service, or contact us at privacy@quesgen.com.

California residents (CCPA as amended by the CPRA)

If you are a California resident, you have the right to:

• Know and access the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of recipients;
• Delete personal information we collected from you, subject to legal exceptions;
• Correct inaccurate personal information;
• Opt out of the sale or sharing of personal information. We do not sell or share personal information for cross context behavioral advertising, so there is nothing to opt out of, and we honor GPC signals as described in Section 8;
• Limit the use of sensitive personal information. We already limit our use of sensitive information, including health information, to providing and supporting the Service; and
• Not be discriminated against for exercising your rights.

Categories collected. In the past twelve months we have collected these categories of personal information under California law: identifiers (such as name and email); customer records (such as phone number and billing contact); internet and network activity (such as usage and log data); geolocation (general, from IP address); and sensitive personal information (health information you enter, and account log in credentials). We collect these for the purposes in Section 5 and disclose them only as described in Section 7.

How to exercise. Submit a request at privacy@quesgen.com or [REQUEST FORM OR TOLL FREE NUMBER IF REQUIRED]. We will verify your request, usually by confirming control of your account email, before acting. You may use an authorized agent, who must provide proof of authorization. We respond within the timelines required by law and, if we decline, you may appeal by replying to our response.

Shine the Light. California Civil Code Section 1798.83 lets California residents request information about disclosures of personal information to third parties for their direct marketing. We do not make such disclosures. You may direct questions to privacy@quesgen.com.

Other United States states

Residents of certain other states (for example, Virginia, Colorado, Connecticut, Texas, and others with comprehensive privacy laws) may have similar rights to access, correct, delete, and obtain a copy of their personal information, and to opt out of targeted advertising, sale, or certain profiling. To exercise these rights, contact us at privacy@quesgen.com. [CONFIRM STATE COVERAGE WITH COUNSEL.]

12. Children and minors

You must be at least 18 years old to create a LifePath account. The Service is not directed to children, and we do not knowingly collect personal information directly from a child under 13 as a user.

Because LifePath is a care coordination tool, an adult account holder may track care for a minor as a care recipient. In that case the adult is responsible for the information they enter and for having the authority to do so. If you believe a child has created an account, contact us at privacy@quesgen.com and we will take appropriate steps. [CONFIRM APPROACH TO MINOR CARE RECIPIENTS WITH COUNSEL.]

13. Breach notification

If a breach affects your information, we will notify you and any required authorities as the law requires, including, where applicable, the Federal Trade Commission's Health Breach Notification Rule for consumer health information and California's breach notification law. We will describe what happened and the steps you can take.

14. Where your information is processed

We operate in the United States, and we store and process information here. If you access the Service from outside the United States, you understand that your information will be processed in the United States, where privacy laws may differ from those where you live.

15. Changes to this policy

We may update this policy from time to time. When we make material changes, we will update the date above and, where appropriate, provide additional notice. Your continued use of the Service after an update means you accept the revised policy.

16. How to contact us

For privacy questions or to exercise your rights:

17. Accessibility statement

Our commitment. LifePath is committed to digital accessibility for people with disabilities. Accessible design matters especially for the older adults and caregivers we serve, and we work to make the Service usable for everyone.

Conformance goal. We aim to conform to the Web Content Accessibility Guidelines (WCAG) 2.2 Level AA across the LifePath website and application.

Ongoing effort. We use a combination of automated testing and manual review, including keyboard navigation and screen reader checks, to find and fix issues. Some content or third party components may not yet fully conform, and we prioritize fixes by impact.

Feedback. If you have trouble using any part of LifePath, or need information in a different format, contact us at support@quesgen.com or 650-777-7617. Please include the page address and a description of the issue. We aim to respond within five business days.