Privacy Policy

1. Introduction

This Privacy Policy (the “Privacy Policy”) describes how Bubo Health (“Bubo” or “we” or “our” or “us”), a personal health management platform empowering individuals facing serious illness to play an active role in their health care, collects, uses, discloses, and protects information provided by you when you use the Bubo Health mobile application and our other services (collectively, the “Services”).

Information about your health is especially sensitive. We take privacy and security very seriously when it comes to your data. Please read this Policy carefully. By using Bubo Health, you agree to the data practices described in this Policy.

If you have any questions about this Policy, please contact us at privacy@bubo.health.

2. HIPAA Notice

Bubo Health is not a HIPAA covered entity: we are not a healthcare provider, health plan, or healthcare clearinghouse as defined under the Health Insurance Portability and Accountability Act (HIPAA), and HIPAA does not directly govern our operations. However, we voluntarily commit to treating your health information with protections that meet or exceed the spirit of HIPAA. We implement technical, administrative, and physical safeguards proportionate to the sensitivity of health data, including strong encryption, strict access controls, and ongoing security monitoring.

3. Information We Collect

We may collect information both from you and from your use of our app. This information may come from your interaction with our service and/or information you authorize us to access from third party services. This information may include:

3.1 Information You Provide Directly

• Account information: Information you provide when setting up an account, such as your name, email address, date of birth and password;
• Health profile: Information you enter into the App, such as your medical conditions, diagnoses, allergies, current medications, care team and other health-related information.
• Medication records: drug names, dosages, schedules, and adherence logs.
• Lab results: test names, values, reference ranges, dates, and ordering providers you enter or import.
• Appointments: appointment dates, provider names, locations, and notes.
• Symptom journal entries: free-text descriptions, severity ratings, and timestamps.
• Nutrition and food logs: food items, meals, and photos you capture for nutritional analysis.
• Emergency card information: emergency contacts, critical allergies, and priority medical information you choose to store.
• Care team information: names, specialties, and contact information for your healthcare providers.
• AI chat messages: questions and conversations you initiate with our AI health assistant features.

3.2 Information from Connected Services

• Device health platform:With your explicit permission, we may read health and fitness data stored on your device's built-in health platform. Categories we access may include: steps, heart rate, sleep analysis, body weight, blood pressure, blood glucose, and workout activity. We do not currently write data back to your device health platform. You may revoke this permission at any time through your device settings.
• Electronic health record (EHR) integrations: With your explicit authorization, we may retrieve records from healthcare organizations whose systems you are connected to. Records retrieved may include medications, lab results, and appointments. This connection is strictly read-only; we do not create, modify, or delete records in any external health system. You may disconnect any EHR integration at any time from within the app.

3.3 Voice Recordings (Visit Recorder)

When you use the Visit Recorder feature, your device's microphone captures audio of your healthcare appointments at your direction. This audio is transmitted over an encrypted connection to OpenAI so it can be turned into text. Transcription only happens when you start it. The transcribed text is returned to the app and stored in your account. Raw audio recordings are not retained after transcription is complete: we do not store audio files on our servers or those of OpenAI beyond the time required to generate your transcript.

3.4 Photos and Camera

When you use food photo analysis or prescription scanning features, images captured by your camera or selected from your photo library are transmitted to OpenAI for analysis. Photos are not retained on our servers or those of OpenAI after processing is complete. Structured information extracted from these images (such as nutritional estimates or medication details) may be saved to your health records within the app if you choose to keep the result. AI-generated answers, text analysis, and photo and document analysis are provided using OpenAI. When you request a second opinion or an additional answer, xAI may be used to generate that response.

3.5 Automatically Collected Information

• Device information: Device information, including the type of device, operating system version, application version, and anonymous device ID.
• Usage data: features accessed, screens viewed, in-app actions, and session duration, used to improve the product.
• Crash reports and diagnostics: Error logs and performance data to troubleshoot technical issues.
• IP address: used for security monitoring, fraud prevention, and approximate geolocation at the country or region level only.

4. How We Use Artificial Intelligence

We use 3rd party Artificial Intelligence (AI) services to power certain features of our app, including health-related chat assistance, providing medication-related information, providing information about potential drug interactions, transcribing visit information, and analyzing food items. We want to be very clear about the data that goes into and comes from our AI powered features.

4.1 What Health Context We Share with AI Services

When you interact with an AI feature, we send relevant health context to the applicable AI service provider to generate a useful response. Before transmitting your text inputs to an AI service, we apply automated scrubbing to remove common categories of personal identifying information. The AI service receives clinical and health context relevant to your query, but our scrubbing is designed to prevent it from receiving direct identifiers such as:

• Full names and provider names (e.g. “Dr. Smith”)
• Phone numbers (US and international formats)
• Email addresses
• Postal addresses and ZIP codes
• Dates of birth
• Social Security numbers
• Medical record numbers
• Insurance member, group, and policy identifiers

We log the categories and counts of identifiers our scrubber removes from each request (but never the original values) so we can audit the protection over time. Audio recordings cannot be scrubbed before transcription; instead, we apply scrubbing to the transcribed text returned by the transcription service before it is used or stored. Photos and uploaded images are not text-scrubbable; the textual results extracted from them are scrubbed before any further AI processing.

Examples of what may be included in an AI context payload (after scrubbing):

• Your current list of medications and dosages (without any identifying information)
• Relevant lab results or symptom journal entries pertinent to your question
• The text of your question or message, with any identifying information scrubbed out
• General health context (conditions you have logged) relevant to the query

4.2 We Do Not Train AI Models on Your Health Data

We do not train AI models on your personal health data. We do not sell, license, or share your health information with AI providers for the purpose of training, fine-tuning, or improving AI models. We use third-party AI services exclusively through their standard commercial APIs. The standard terms of service for the AI APIs we use prohibit those providers from using API inputs and outputs to train or improve their models. We do not have separate custom data processing agreements with AI providers at this time, and users should review the applicable standard terms of each AI provider for full details.

4.3 Third-Party AI Providers

We use a few third-party AI services to power features in Bubo. These companies will process:

• OpenAI to power our chat and answers, to analyze text, to transcribe audio from your visits, and to analyze photos and documents.
• xAI to get a second opinion or additional AI answers if you choose to use it.

Content is sent to these providers only when you use an AI feature, and only to generate the response you requested. If you include Apple Health readings, visit transcripts, photos, or documents in a question, that content is sent to the AI provider as part of answering your question. Bubo applies best-effort measures to remove or reduce direct identifiers before content is sent, but we cannot guarantee that all identifying information will be removed. You can limit what is shared by avoiding names, addresses, and other identifying details in your questions, recordings, photos, and documents.

We contract with the above companies through their standard commercial API interfaces. Under their standard terms, they are not permitted to use the input and output from our API calls for their own purposes, such as training their models, etc. However, we do not have custom data processing agreements with the AI companies listed above. Please note that their terms may change over time, but these are the AI companies that we are using as processors at this time. Still have questions? privacy@bubo.health

4.4 How We Use Your Information Internally

• Provide, operate, maintain, and improve the Services
• Deliver AI-powered features including health chat, medication information, visit transcription, and nutrition analysis
• Access and sync data from other services you authorized, such as your device’s health platform or an electronic health record integration.
• Send you reminders and notifications that you can configure, such as medication or appointment reminders.
• Respond to your support requests and communicate with you about our services.
• Detect, prevent and respond to fraud, abuse, and security events.
• Analyze aggregate, de-identified usage trends to improve the app, never at the individual level for advertising
• Comply with applicable legal obligations

5. How We Store and Protect Your Data

Your health data is stored on secure cloud infrastructure with encryption at rest and in transit. We enforce strict access controls so that only your authenticated account can access your personal health records. Employees and contractors with system access are bound by confidentiality obligations and granted only the minimum access necessary to perform their roles.

While we implement industry-standard security practices, no system is perfectly immune to compromise. We encourage you to protect your account by using a strong, unique password and enabling biometric authentication (such as Face ID or Touch ID) within the Bubo Health app.

If we become aware of a security incident that affects your personal information, we will notify you in accordance with applicable laws.

6. Data Retention

We will store your personal health data for the duration of your account. More specific data retention rules include:

• Active accounts: For as long as your account is active and in use;
• Account deletion: When you delete your Bubo Health account, we will permanently delete your personal health data from our live systems within 30 days of the deletion request. Certain records may be retained longer if required by applicable law (for example, financial transaction records required for tax or audit purposes).
• Visit Recorder audio: Raw audio is deleted immediately upon completion of transcription; it is never stored beyond the processing window.
• Photos: Images submitted for analysis are deleted immediately after the analysis response is returned; they are never archived.
• Encrypted backups: After deletion, the data may remain in our infrastructure’s encrypted backup snapshots for up to 90 days before being overwritten during our regular backup rotations.

You can ask us to delete your account by selecting “Delete Account” in the Settings screen of the app, or by contacting us at privacy@bubo.health.

7. How We Share Information

We do not sell your personal health information. We share information only in the following limited circumstances:

7.1 With Your Consent

We share information with third-party services only when you explicitly authorize us to do so, for example, when you connect an electronic health record integration or grant access to your device's health data.

7.2 Third-Party AI and Technology Service Providers

To provide these features, we share only what is needed with the AI providers named in this policy: OpenAI (chat and answers, text analysis, visit audio transcription, and photo and document analysis) and xAI (second-opinion or additional AI answers, when used). As described in Section 4, we share health context with those companies to power AI features. We also use third-party providers for secure cloud infrastructure, analytics, and customer support tooling. We use these providers through their standard commercial terms, which restrict use of your data to the delivery of their services and prohibit use for their own independent purposes such as model training.

7.3 Legal Requirements

We may disclose information if required by law, court order, or governmental authority, or when we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Bubo Health, our users, or the public.

7.4 Business Transfers

In the event of a merger, acquisition, financing, or sale of all or a portion of our assets, your information may be transferred to a successor entity. We will notify you of any such change and any material changes to this Privacy Policy before they take effect.

7.5 Aggregate and De-identified Data

We may share aggregate information about our users that does not include any information that can be used to identify you for purposes such as conducting research and compiling industry reports, or for other ways to improve our products.

8. Device Health Platform Integration

In order to provide you with the best experience possible, Bubo Health may request to read your health and fitness data from the native health platform on your mobile device. The specific health data types that we may have access to are: Step Count, Heart Rate, Sleep Analysis, Body Weight, Blood Pressure Systolic, Blood Pressure Diastolic, Blood Glucose and Workout/Exercise Activity.

We do not currently write data back to your device health platform. Health data read from your device is used solely within Bubo Health to give you a more complete view of your health. We do not share this data with advertisers or use it for any advertising purposes. Device health data is shared with third parties only as minimally necessary to operate app features, for example, displaying your activity data within the app.

You may revoke permissions and remove access to this information at any time in your device’s operating system settings.

9. Electronic Health Record Integration

Bubo Health can connect to your electronic health records through integrations with participating healthcare organizations. When you choose to connect:

• You will be directed to your healthcare organization’s patient portal to authenticate yourself and authorize the connection using industry standard authorization protocols.
• We retrieve your records on a read-only basis, including medications, lab results, and upcoming appointments. We do not create, modify, or delete records in any external health system.
• You can rest assured that we will never see or store your healthcare portal credentials. We only store the secure access tokens provided to us once you authorize our access.
• You may disconnect your EHR integration at any time from the Settings screen within the app, which revokes our access.
• Availability of EHR integration depends on your healthcare organization's participation in open health record access programs and may change without notice.

10. Your Rights and Choices

Depending on where you are located, you may have certain rights related to your personal information. Below are the rights that all Bubo Health users have:

10.1 Access and Portability

You may access and export the health data you have stored in Bubo Health at any time through the app. For assistance with data export, contact privacy@bubo.health.

10.2 Correction

You may update or correct your account information and health records directly within the app at any time.

10.3 Deletion

You may delete your account and all associated personal health data. See Section 6 for deletion timelines. Use the in-app option or email privacy@bubo.health to initiate a deletion request.

10.4 Communications

You may opt out of marketing emails by using the unsubscribe link in any marketing email or by contacting us. You may not opt out of transactional communications related to your account security or service status.

10.5 Connected Services

You may disconnect your device health and EHR integrations at any time from within our app or through your device’s operating system settings. Please note that disconnecting any integration will prevent us from retrieving data from these sources moving forward but will not delete your previously stored data within the app.

11. California Privacy Rights (CCPA / CPRA)

California law provides you with the following rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):

• Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you in the past 12 months.
• Right to Delete: Request deletion of personal information we have collected, subject to certain exceptions permitted by law.
• Right to Correct: Request correction of inaccurate personal information we maintain about you.
• Right to Opt-Out of Sale or Sharing: We do not sell personal information and do not share it for cross-context behavioral advertising. No opt-out is required.
• Right to Limit Use of Sensitive Personal Information: We do not use sensitive personal information (including health data) for purposes beyond those disclosed in this Policy.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

If you are a California resident, you can exercise your rights by contacting us at privacy@bubo.health. We will respond to your request within 45 days in accordance with the law.

12. Children's Privacy

Bubo Health is intended for users 13 years of age or older. We do not knowingly collect personal information from children under 13. If you believe we have inadvertently collected information from a child under 13, please contact us immediately at privacy@bubo.health and we will promptly delete that information.

If you are between the ages of 13 and 17, you may use Bubo Health only with the consent of your parent or guardian. If you are the parent or legal guardian of a minor and would like to review, correct, or delete your child’s personal information, please contact us.

13. International Users

Bubo Health is operated 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, where privacy laws may differ from those in your home country. By using the Services, you acknowledge this transfer. Bubo Health's Services are primarily designed for users in the United States, and we make no specific representations regarding compliance with the laws of other jurisdictions.

14. Changes to This Privacy Policy

From time to time, we may update this Privacy Policy. In the event of a material change to this Privacy Policy, we will update the “Last Updated” date at the top of this Privacy Policy, and we will notify you via email or in-app notification prior to the date that the new Privacy Policy will take effect. Your continued use of our Services after you have been notified constitutes your acceptance of our Privacy Policy.

15. Contact Us

If you have any questions, concerns, or requests related to this Privacy Policy, please contact us at:

• Privacy inquiries: privacy@bubo.health
• Legal inquiries: legal@bubo.health
• General support: support@bubo.health
• General inquiries: info@bubo.health

As a technology company, Bubo Health is governed by the laws of the State of Tennessee, U.S.