Legal

Privacy Policy

This policy does not contradict our Data Oath. Every commitment made on that page is a legally binding obligation reflected in this document. If you find a conflict, tell us immediately.

Effective Date: March 1, 2025 Last Updated: March 1, 2025 Version: 1.0
Contents
1. Who We Are 2. Our Unconditional Commitments 3. What We Collect 4. How We Use Information 5. PHI & HIPAA 6. The TETRA Vault 7. When We Share Information 8. AI & Data Governance 9. Data Retention 10. Security 11. Your Rights 12. Children's Privacy 13. Cookies 14. State Privacy Rights 15. Breach Response 16. Changes to This Policy 17. Contact

1. Who We Are

InPursuit Health, Inc. ("InPursuit Health," "we," "us," or "our") is a veteran-owned health data orchestration company. We build the TETRA™ platform — infrastructure that unifies, protects, and puts health data to work for the people and organizations that generate it. We are not a data company that happens to offer software. We are an infrastructure company whose revenue comes from delivering outcomes — not from monetizing the information that flows through our systems.

This Privacy Policy governs how we collect, handle, protect, and limit the use of personal information and protected health information (PHI) across our websites, the TETRA™ platform, TETRA Ex™, TETRA Conductor™, TETRA Aegis™, TETRA Sentinel™, the InPursuit consumer application, and all related services (collectively, the "Services").

2. Our Unconditional Commitments

These commitments are not aspirational language. They are legally binding obligations. They do not have carve-outs. They cannot be overridden by a future policy update. They are the foundation everything else in this document is built on.

Commitment 1

We will never sell your data. Your health information will never be sold, traded, brokered, or transferred to any third party for profit — not to advertisers, data brokers, pharmaceutical companies, insurers, or anyone else. No exceptions. No loopholes.

Commitment 2

You own your data — always. Every provider and patient retains full intellectual property ownership of their data at all times. InPursuit Health is a custodian and a tool. If you leave, your data leaves with you, in full, in standard formats, at no cost.

Commitment 3

Your data trains only your insights. We do not aggregate, anonymize, pool, or repurpose your clinical data to train AI models, build commercial products, or develop benchmarks sold to or shared with any other organization. Your patient population is yours.

Commitment 4

Full transparency — always. You will always know exactly what data we hold, how it is used, and who has accessed it. There are no hidden processes, no shadow analytics, and no secondary uses you have not explicitly approved.

Commitment 5

Data is never our product. Our revenue comes from infrastructure subscriptions and outcome-based arrangements. We have no financial interest in the content of the data that flows through our platform. Data monetization does not supplement our fees — it is prohibited.

Commitment 6

Security is ongoing, not a checkbox. We continuously invest in penetration testing, vulnerability assessments, compliance audits, and emerging threat intelligence. Your data protection does not expire.

The Data Oath

"We built InPursuit Health on a simple, unbreakable rule: the people who generate health data are the people who own it. No exceptions. No loopholes. No fine print." — InPursuit Health Leadership. Read the full Data Oath →

3. What We Collect

3.1 Information You Provide

  • Account information: Name, email address, phone number, professional credentials, NPI number, and organizational affiliation for provider accounts.
  • Contact and inquiry data: Information you submit through contact forms, demo requests, or direct correspondence.
  • Payment information: Billing address and payment details, processed through PCI-DSS compliant processors. We do not store raw card data.
  • Platform interactions: Queries, configurations, and workflow settings you create inside the TETRA platform.

3.2 Protected Health Information (PHI)

When you are a healthcare provider, health plan, or other HIPAA-covered entity using the TETRA platform, or a patient whose records are orchestrated through TETRA Ex™, we handle PHI as a Business Associate under a signed Business Associate Agreement (BAA). See Section 5 and Section 6 for how PHI is governed and protected within the TETRA Vault architecture.

3.3 Automatically Collected Technical Data

  • Log data: IP address, browser type, operating system, pages viewed, and session timestamps — collected to operate and secure the Services.
  • Usage data: Features accessed and interaction patterns within the platform — used only to improve reliability and performance. This data is never linked to PHI or used to build commercial profiles.
  • Device data: Device identifiers and network information for security monitoring and access control.

3.4 Health Data You Authorize Through TETRA Ex™

If you use TETRA Ex™ — either as a provider connecting to health information exchanges or as an individual exercising your data rights — we access clinical records, lab results, medications, claims, and other health information from connected systems solely on your direction and with your explicit authorization. We are the pipe, not the destination. This data lives in your TETRA Vault and is governed by your permissions.

3.5 What We Do Not Collect

  • We do not collect data for advertising targeting or behavioral profiling.
  • We do not collect or share reproductive health data, mental health records, or substance use data for any purpose other than direct care coordination you authorize.
  • We do not use third-party advertising pixels, behavioral tracking scripts, or cross-site tracking on our clinical platform.

4. How We Use Information

We use the information we collect only for the following purposes:

  • Delivering and operating the Services: Running the TETRA platform, processing data exchange transactions, managing your account, and providing customer support.
  • Security and access control: Authenticating users, detecting unauthorized access, monitoring for security threats, and operating immutable audit logs.
  • Compliance: Fulfilling HIPAA, HITECH, and applicable state law obligations; responding to lawful government requests; and enforcing our agreements.
  • Platform reliability: Diagnosing technical issues, optimizing performance, and ensuring system availability. Technical performance data is never linked to PHI.
  • Communications: Sending transactional emails, security alerts, and service updates. Marketing communications require separate opt-in consent.

We do not use your information for: advertising, behavioral profiling, commercial data analytics, AI model training on behalf of third parties, or any purpose not listed above.

5. PHI & HIPAA Compliance

5.1 Our Role as a Business Associate

When InPursuit Health handles PHI on behalf of a HIPAA-covered entity, we act as a Business Associate under 45 C.F.R. § 160.103. A signed Business Associate Agreement (BAA) must be in place before any PHI is processed through our platform. We do not treat HIPAA compliance as a badge or a marketing claim — it is a legal obligation that is operationally enforced at every layer of our architecture.

To request a BAA: privacy@InPursuitHealth.com.

5.2 Permitted Uses of PHI

As a Business Associate, we use or disclose PHI only: (a) as directed by the covered entity in the BAA; (b) as required for the proper management and administration of our services to that covered entity; or (c) as required by law. We do not use PHI for any commercial purpose, AI training, or analytics that benefit InPursuit Health commercially.

5.3 Minimum Necessary Standard

Role-based access controls (RBAC) are enforced across every component of the TETRA platform. Access to PHI is granted only to personnel and systems with a documented need. Audit logs record every access event with full provenance.

5.4 Individual Rights Under HIPAA

Individuals have rights to access, amend, and obtain an accounting of disclosures of their PHI under 45 C.F.R. §§ 164.524–164.528. For PHI handled on behalf of a covered entity, requests should be directed first to that covered entity, who will coordinate with us. For PHI held in your personal TETRA Vault through the consumer application, you may exercise these rights directly by contacting privacy@InPursuitHealth.com.

6. The TETRA Vault

The TETRA Vault is the architectural model by which your data is stored and governed within our platform. It is not a marketing concept — it is how the system is built.

  • Logical isolation: Each organization's and each individual's data is logically isolated. Your data does not share a storage context with another customer's data.
  • No cross-customer data pooling: We do not combine, compare, or aggregate your clinical data with data from any other organization. Your patient population's data remains exclusively yours.
  • You control the keys: Access permissions are yours to grant and revoke. TETRA Aegis™ enforces those permissions at the architectural level — not just as a policy setting.
  • Real-time audit visibility: You have access to real-time audit logs showing who accessed your data, when, what action was taken, and what the outcome was. This is a platform capability, not a report generated on request.
  • TETRA Aegis™ protection: Every interaction with an AI model — whether initiated by a provider, patient, or automated agent — passes through TETRA Aegis™, which intercepts, classifies, risk-scores, and mediates the interaction before any data leaves your Vault. TETRA Sentinel™ monitors continuously for anomalies, hallucinations, and unauthorized data access attempts.

7. When We Share Information

We share information in only the following limited circumstances, and we do not share beyond what is necessary for each purpose.

7.1 Authorized Data Exchange

Through TETRA Ex™, we transmit PHI and clinical data to providers, systems, and networks that you have explicitly authorized to receive it. This is the core function of the platform — bidirectional exchange at your direction. We are executing your instructions, not making independent sharing decisions.

7.2 Infrastructure Subprocessors

We engage a limited set of vetted infrastructure providers (cloud compute, storage, security monitoring) to operate the TETRA platform. All subprocessors are bound by:

  • Data processing agreements with the same no-resale, no-training obligations in our Data Oath
  • HIPAA Business Associate Agreements where applicable
  • Contractual prohibition on using your data for any purpose other than providing infrastructure services to InPursuit Health

Our current subprocessor list is publicly available at privacy@InPursuitHealth.com. We update this list before adding any new subprocessor with access to PHI and notify affected customers.

7.3 Legal Requirements

We may disclose information when required by law, court order, or government authority. Where legally permitted, we will notify you before disclosure and cooperate with any efforts to obtain a protective order. We will not disclose PHI in response to a voluntary government request without a BAA or court order.

7.4 Business Transfers

In the event of a merger, acquisition, or sale of substantially all assets, we will provide at least 60 days' advance notice to affected customers. Any successor entity will be required to honor all existing Data Oath commitments and BAAs as a condition of the transfer. You may terminate your agreement and export your data before any transfer takes effect.

7.5 What We Will Never Do

  • Sell, rent, lease, or broker your data to any third party — ever
  • Share PHI or personal data with pharmaceutical companies, insurers, advertisers, or data brokers
  • Provide access to your data for market research, population studies, or commercial analytics without a valid HIPAA authorization signed by you
  • Share anonymized or de-identified data derived from your patient population with any external party for commercial gain
  • License AI-derived insights, risk scores, or predictive models built on your data to any other organization

8. AI & Data Governance

8.1 AI That Serves You — Not Us

AI capabilities within the TETRA platform exist for one purpose: to improve health outcomes for patients and reduce administrative burden for providers. TETRA Conductor™ routes clinical AI interactions to the appropriate model. TETRA Aegis™ and TETRA Sentinel™ ensure those interactions are safe, auditable, and confined to your authorized data scope.

8.2 No Cross-Customer AI Training

Your data trains only your insights. When AI learns from your patient population, those insights stay within your TETRA Vault. We never pool clinical data across customers to build, fine-tune, or benchmark AI models — for ourselves or for any third party. This applies equally to anonymized, de-identified, or aggregated derivatives of your data. The only exception is internal platform improvements that use technical (non-clinical) performance data — never PHI, never patient-level records.

8.3 Explainability and Auditability

Every AI-generated recommendation produced through the TETRA platform includes the reasoning behind it. No black boxes. Every AI interaction — input, classification, risk score, decision, output — is captured in your immutable audit log. You can review any AI decision at any time.

8.4 TETRA Aegis™ and TETRA Sentinel™

TETRA Aegis™ is the supervisory control layer between your users and any AI model. It intercepts every prompt, classifies the sensitivity of the content, scores the interaction for risk, and either passes, mediates, or blocks the interaction — all in under 200ms, before any data leaves your organization. TETRA Sentinel™ is the intelligence inside that layer — the AI that watches AI — providing continuous behavioral surveillance, hallucination detection, and anomaly monitoring across all AI interactions in your environment.

8.5 AI Clinical Responsibility

The TETRA platform supports clinical decision-making. It does not replace it. AI-generated outputs are informational. All clinical decisions remain the exclusive responsibility of licensed healthcare providers. InPursuit Health does not assume liability for clinical outcomes based on AI-generated recommendations.

9. Data Retention

We retain data for the shortest period consistent with our legal obligations and your business needs. We do not retain data to build commercial value from it.

  • PHI (as Business Associate): Retained in accordance with the applicable BAA and state law. HIPAA requires a minimum of 6 years from creation or last effective date (45 C.F.R. § 164.530(j)). We cannot delete PHI during the applicable retention period even upon request — this is a federal legal obligation, not a data hoarding practice.
  • Account data: Retained for the duration of your active account, plus the longer of: (a) 7 years to satisfy HIPAA record retention requirements, or (b) any longer period required by applicable state law.
  • Audit logs: Retained for a minimum of 6 years per HIPAA Security Rule requirements (45 C.F.R. § 164.312). Audit logs are immutable — they cannot be altered or deleted, by you or by us, during the retention period. This protects both parties.
  • Technical performance data: Retained for 90 days and then automatically purged, unless a specific incident investigation requires extended retention, in which case only the relevant records are preserved.
  • Marketing and contact data: Retained until you request deletion or unsubscribe, with no minimum retention requirement.

Upon request or account termination, we will provide a full export of your data in standard formats and confirm in writing when destruction is complete.

10. Security

The TETRA platform was built to meet Department of Defense security standards — forged in the U.S. Military Health System and the Department of Veterans Affairs before entering the commercial market. Security is not a feature we added — it is the foundation the platform was built on.

Our security program includes:

  • AES-256 encryption at rest and TLS 1.3 encryption in transit — on every data path, without exception
  • Role-based access controls (RBAC) with least-privilege enforcement across all platform components
  • Multi-factor authentication (MFA) required for all accounts with access to PHI or clinical data
  • Zero-trust architecture — no implicit trust between systems or users, regardless of network location
  • Real-time immutable audit logging of all data access events
  • Continuous intrusion detection and behavioral anomaly monitoring via TETRA Sentinel™
  • Annual third-party penetration testing and HIPAA security risk assessments
  • FIPS-compliant cryptographic standards
  • SOC 2 Type II audit program (in progress)
  • Documented incident response, business continuity, and disaster recovery plans

If you believe your account has been compromised or you have identified a security vulnerability, contact us immediately at security@InPursuitHealth.com.

11. Your Rights

These rights apply to personal information we hold about you directly. For PHI handled on behalf of a covered entity, coordinate requests through that entity.

  • Access: Request a copy of the personal information we hold about you.
  • Portability: Receive your data in a structured, machine-readable format. For clinical data in your TETRA Vault, export is available at any time, in standard FHIR R4 format, at no cost.
  • Correction: Request correction of inaccurate or incomplete information.
  • Deletion: Request deletion of personal information, subject to applicable retention obligations (see Section 9). We will confirm in writing what has been deleted and what is being retained, and why.
  • Restriction: Request that we limit processing of your personal information in specific contexts.
  • Withdrawal of Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.
  • Audit Log Access: Access your real-time audit trail directly within the platform. No request required — it is always available to you.

To exercise any right, contact privacy@InPursuitHealth.com. We respond within 30 days, or sooner as required by applicable law, and at no charge.

12. Children's Privacy

Our Services are not directed to individuals under 18. We do not knowingly collect personal information from minors under 18. If we become aware of such a collection, we will delete it promptly. Contact privacy@InPursuitHealth.com if you believe a minor's information has been collected.

For minor patients whose PHI flows through the TETRA platform as part of authorized care coordination, access and authorization rights are governed by HIPAA and applicable state law regarding parental and guardian rights.

13. Cookies and Tracking

On our marketing website (InPursuitHealth.com):

  • Essential cookies: Required for authentication, session management, and security. Cannot be disabled.
  • Analytics cookies: Used only with privacy-preserving tools configured to anonymize IP addresses and disable third-party data sharing. We do not use Google Analytics, Meta Pixel, or any behavioral advertising tracking tool.
  • No advertising cookies: We do not use, and will never use, behavioral advertising tracking technologies on any InPursuit property.

On the clinical TETRA platform, there are no third-party tracking scripts of any kind. All logging is internal, audit-purpose only, and accessible to you.

14. State Privacy Rights

California (CCPA/CPRA)

California residents have rights to know, delete, correct, and opt out of sale or sharing of personal information. We do not sell personal information. We do not share personal information for cross-context behavioral advertising. California residents may submit requests to privacy@InPursuitHealth.com. We will not discriminate against you for exercising your rights.

Texas (TDPSA), Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA)

Residents of these states have rights to access, correct, delete, and port personal data, and to opt out of targeted advertising and profiling. Submit requests to our Privacy Officer. We respond within the timeframes required by each applicable state law.

Other States

We extend the same rights to residents of all states with comprehensive privacy legislation and will continue to update our practices as new state laws take effect.

15. Breach Response Commitment

In the event of a confirmed breach of unsecured PHI or personal information, InPursuit Health commits to:

  1. Notify affected covered entities within 60 hours of discovery — ahead of the HIPAA Breach Notification Rule requirement — with full details of what occurred, what data was involved, and what steps we are taking
  2. Provide a plain-language explanation accessible to affected individuals, not just technical or legal language
  3. Offer complimentary credit monitoring and identity protection services to any individual whose personal information was exposed
  4. Publish a post-incident transparency report, available publicly, within 90 days of containment

We will not minimize, delay, or obscure the nature or scope of any breach. Transparency after an incident is an extension of the same commitment we make before one.

16. Changes to This Policy

We will not retroactively change this policy to enable uses of your data that were not permitted when you signed up. Any material change to this Privacy Policy requires:

  • At least 60 days' written notice to all registered users
  • A clear, plain-language explanation of what is changing and why
  • The right to terminate your account and export all data before the change takes effect, at no cost and with no penalty

The "Last Updated" date at the top of this page reflects the most recent revision. Prior versions are available upon request.

17. Contact Us

For privacy inquiries, rights requests, BAA execution, or breach reports:

HIPAA Privacy Officer
InPursuit Health, Inc.
privacy@InPursuitHealth.com

Security incidents: security@InPursuitHealth.com

General: info@InPursuitHealth.com

To file a complaint with HHS Office for Civil Rights: hhs.gov/ocr/complaints

InPursuit Health

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