Privacy Policy.
Introduction
Effective date: 17th September 2026
This privacy notice tells you what to expect TORTUS Health Inc. to do with your personal information when you make contact with us or use one of our services. It explains:
- why we are able to process your information;
- what purpose we are processing it for;
- whether you have to provide it to us;
- how long we store it for;
- whether there are other recipients of your personal information;
- whether we intend to transfer it to another country; and
- whether we do automated decision-making or profiling.
This privacy notice explains what personal information TORTUS Health Inc. collect about those who visit our website, use our products and communicate with us, how we use it, the circumstances in which TORTUS Health Inc. may disclose it to others and how we keep it secure.
TORTUS Health Inc. are committed to protecting and respecting your privacy. If you have any questions regarding this privacy notice and our approach to privacy, email us at: support@tortushealth.com.
Governing Law and Jurisdiction Scoping
These privacy practices are provided in connection with services governed by the laws of the State of Delaware, set out in our Terms and Conditions. References in this notice to the UK GDPR, the Data Protection Act 2018, and the Information Commissioner's Office (ICO) relate to TORTUS Health Inc.'s data hosting and processing arrangements in the United Kingdom, including our primary database, hosted in London. If you are a US patient, your rights are primarily exercised under the CCPA, CPRA and other applicable US federal and state law, as described throughout this notice.
Who we are
TORTUS Health Inc. is Stock Corporation based in Delaware in the United States of America under Entity Number B20260338295.
TORTUS Health Inc. provides the technology platform, AI consultation service, and administrative support used to deliver your care to our affiliated professional corporation, TORTUS Medical CA, P.C., a licensed healthcare provider that remains subject to state confidentiality, security, licensing and contractual obligations (including the CMIA), under a services agreement between the two entities. TORTUS Health Inc. processes your health information only as permitted by that agreement, applicable law, and this Privacy Notice. See TORTUS Medical CA's Notice of Privacy Practices, which describes your rights regarding your health information at tortushealth.com.
Our Product
TORTUS Health is a primary care service where the AI listens and licensed clinicians decide. Talk through what is going on with TORTUS, our clinical AI. Speak or type, day or night. TORTUS listens, asks the right questions, and takes a full history. One of our clinicians then reviews the conversation and approves or changes anything TORTUS proposes. Nothing becomes part of your care without a clinician's sign-off. When your plan is confirmed, it is waiting for you in the app. TORTUS Health's transcripts, summaries and proposed care plans are generated by AI and may occasionally be incomplete or inaccurate before your Clinician reviews them. This is why every proposed care plan, prescription and clinical recommendation is checked, and where necessary corrected, by a licensed human Clinician before it becomes part of your care. See also Section 3(d) and Section 10 of our Terms and Conditions, which describe the general limitations of telehealth technology.
Important stuff
- TORTUS Health is not for emergencies. If you think you may be having a medical emergency, call 911.
- When you talk to TORTUS, you are always talking to an AI. TORTUS never diagnoses, treats, or prescribes on its own. Clinical decisions are made only by licensed clinicians.
- Clinicians as appropriate may reach out via message, phone call, or video call, to request additional information to ensure the best care is given.
- TORTUS Health is for adults 18-65 years old.
- Our clinicians do not prescribe controlled substances.
The Information We Process
TORTUS Health Inc. obtain information about you when you use our website, when you contact us about products and services, for example by email or telephone, or during business with you or an organization you represent.
Most of the personal information TORTUS Health Inc. process is provided to us directly by you for one of the following reasons:
- You have made an inquiry to us.
- You have initiated or completed a commercial transaction with us.
- We are providing services to you or the organization or entity you work for or represent.
- You have made a complaint to us.
- You wish to attend or have attended, an event we have organized or attended alongside you.
- You have subscribed to our e-newsletter.
- You have applied for a job with us.
- You work with or for us.
- You visit our website and consent to our use of cookies.
- In limited circumstances, consultation data may be temporarily collected to investigate and resolve technical issues, performance problems, or user-reported errors. This collection is strictly limited to defined triggers and all data is deleted once the issue is resolved.
TORTUS Health Inc. also receive personal information indirectly, in the following scenarios:
- Where we are providing services to the organization or entity you work for or represent and they have provided your information to us.
- Where you have made your contact information available on your organization's website and we use this to contact you and your organization.
- Where you have made your contact information available via a social media platform and we use this to contact you and your organization.
- You have applied for a job with us and we seek a reference from an organization or individual you have previously worked for or with.
- An employee of ours gives your contact details as an emergency contact or a referee.
Where TORTUS Health Inc. receives your personal data indirectly and acts as Data Controller for that data, TORTUS Health Inc. will provide you with the information set out in this Privacy Notice (including what data we hold, why, and your rights) within one month of receiving it, or earlier if TORTUS Health Inc. use it to contact you or intend to disclose it to another party, whichever comes first. TORTUS Health Inc. will do this by email (if we hold a valid email address for you).
Where providing this notice directly would involve disproportionate effort, for example, if TORTUS Health Inc. do not hold accurate contact details for you, or the volume of Individuals involved makes individual contact impracticable, TORTUS Health Inc. will instead take appropriate steps to protect your rights, including publishing this information prominently on our website and, where applicable, informing the organization that provided us with your data so they can pass this notice to you directly.
Data we collect in our product
TORTUS Health is our patient-facing AI consultation service. It holds a voice or text consultation with a Patient, drafts a care plan, and passes that draft to a qualified Clinician who reviews and approves it before anything is actioned. The tables below describe the data that the product collects across all of its surfaces: the Patient mobile app, the Patient web app, the Clinician review application, and the services behind them.
Patient Data (entered or captured during a consultation):
| Data Element | Format | Why Collected |
|---|---|---|
| Legal name | Text, with first, middle and last name stored as separate parts | Your legal identity for the medical record and for prescribing |
| Preferred name | Text, optional | The name the product and the consultation agent greet you by |
| Date of birth | Date | To confirm eligibility, help identify you, and give clinical context for prescribing |
| Sex recorded at birth | Selection of female, male, or intersex and self-describe, with optional free-text detail | The clinical variable that prescribing and reference ranges need. This is deliberately not gender identity |
| Consent records | Document version and server timestamp for each legal document you accept | The legal record of your acceptance of the terms of service, privacy policy and California notices |
| Consultation voice audio | Live audio stream, processed in real time. Not stored as a recording | To hold the voice consultation. Your speech is transcribed and responded to as you speak, then discarded |
| Consultation messages and transcript | Text | The record of your consultation, used to provide your care and reviewed by your clinical team |
| Conversation title | Short text, generated from your own words | To label your consultations so you and your clinician can find them |
| Clinical summaries | Text generated from your transcript, covering presenting complaint, history and summary | To give the reviewing Clinician a fast and accurate read of your consultation |
| Care plans and prescriptions | Structured records covering advice, safety-netting, medication, dose, instructions, clinical indication and status | The draft care your consultation produces, reviewed and approved by a Clinician before anything is actioned |
| Clinician review outcomes | Text, including the reviewing Clinician name, their note to you, and each item approved, amended or removed with an explanation | To show you the outcome of clinical review and to keep an auditable record of every change to your care |
| Safety and quality check records | Structured records of the automated safety, communication and clinical-pathway checks run against your consultation | To keep the consultation safe and on-pathway, and to let a Clinician see why the agent acted as it did |
| Consultation history across visits | Your previous consultation turns and summaries | So the agent knows your history, gives continuous care, and does not ask you to repeat yourself |
| Preferred pharmacy and pharmacy search area | A snapshot of the pharmacy directory record, and the postal or ZIP code you search with | To find pharmacies near you and to send your prescriptions to the one you choose. Only the pharmacy you choose is stored |
Your account data:
| Data Element | Format | Why Collected |
|---|---|---|
| Email address | Email address | To create and sign in to your account, verify it with an emailed one-time code, reset your password, and send you care notifications |
| Password | Stored as a secure hash, never in plain text | To authenticate you |
| Mobile phone number | Phone number in international format, verified by a texted one-time code | A contact detail so your care team can reach you. It is not used to sign in |
| Account name | Text | The name shown on your account and used to address you in emails |
| One-time verification codes | Short numeric code with a short expiry | To prove you control your email address and your mobile number |
| User ID | Unique identifier | To authenticate you and associate your data with your account. This is the only identity our monitoring services receive |
| Authentication tokens and sessions | Secure session cookie held in the device secure storage, with an expiry time | To keep you signed in and to authorize requests to our services on your behalf |
| Account role | Text, such as patient, clinician or administrator | To decide what you are permitted to see and do in the product |
| Invitation records | Email address, roles offered, and status. The invitation link itself is never stored | To let a Clinician or administrator invite you to the service and to keep an audit trail of who invited whom |
| Account deletion requests | Timestamp | To record when you asked us to delete your login and to measure our response against the window we promise you |
Device and usage data:
| Data Element | Format | Why Collected |
|---|---|---|
| Device and operating system information | Text | Diagnostics, compatibility, and to investigate faults |
| Application or browser version | Text | Support, diagnostics, and to deliver the correct features and updates to you |
| IP address and device user agent | Network address and text, recorded for each sign-in session and in our server access logs | Service delivery, session management, network security, and the prevention of fraud and abuse |
| Usage and interaction data | Event data, covering screens viewed and named actions taken | To understand how the product is used and to improve it |
| Diagnostic, crash and performance data | Logs, error and stack traces, and timing metrics. These records carry identifiers, message types, counts and lengths, never the content of your consultation | To monitor stability, reliability and security, and to fix problems |
| Approximate location | Country and state or region, derived on your device from your device location | To confirm the service is licensed and available where you are. Your coordinates are resolved on your device and are not sent to us |
The Lawful Basis for the Processing of Personal Data
The list below describes the personal data TORTUS Health Inc. collect and our lawful basis for processing this data. When TORTUS Health Inc. process data on the basis of legitimate interests, we apply the following test to determine whether it is appropriate:
- Purpose – is the purpose of processing personal data legitimate?
- Necessity – is the processing necessary to fulfilll that purpose?
- Balance – do the individual’s interests, rights or freedoms override the legitimate interest?
The following purposes for the collection of personal data will arise via the use of our website:
- When providing appropriate information via email, video conferencing, or telephone about products and services that you have requested via subscribing to our newsletter, the lawful basis that will apply is consent.
- To provide further, related, information via email, video conferencing, or telephone about the identified area of interest, the lawful basis that will apply is legitimate interests.
- To enable data subjects to exercise their rights over personal data, the lawful basis that will apply is compliance with a legal obligation.
Automated decision-making or profiling
TORTUS Health uses AI to conduct your consultation, draft a proposed care plan, and run automated safety and clinical-pathway checks. No care plan, prescription, or clinical decision is finalized without review and approval by a licensed human Clinician, who may accept, amend, or reject anything TORTUS Health proposes. As a human Clinician makes the final decision, TORTUS Health's use of AI does not constitute solely automated decision-making that produces legal or similarly significant effects without human involvement. TORTUS Health Inc. will provide any additional notices, opt-out rights, or risk-assessment disclosures required under the California Privacy Protection Agency's automated decision-making technology regulations (Cal. Code Regs. tit. 11, arts. 11-22) before their 1st January 2027 effective date.
Retention
Personal and special category data processed within TORTUS Health Inc. will be retained for as long as necessary and where applicable in line with requisite retention periods. Medical records, including consultation transcripts, care plans and prescriptions, are retained for at least seven years, as required for clinical records under applicable law. Account data is retained until your account is deleted. Device, usage, and diagnostic, crash and performance data are retained for 12 months from collection, after which they are deleted or retained only in aggregated, de-identified form.
Data Security and Breach Notification
TORTUS Health Inc. maintains administrative, technical and physical safeguards designed to protect your personal information. If TORTUS Health Inc. discovers a breach of unsecured personal information, TORTUS Health Inc. will notify affected Individuals, and, where required, Regulators and TORTUS Medical CA, P.C., without unreasonable delay and in accordance with applicable State breach notification laws.
Your data protection rights
The rights available to you depend on our reason for processing your information. Under data protection law, you have rights including:
- Your right of access - You have the right to ask us for copies of your personal information.
- Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
- Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organization, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond. If you are a California patient requesting to inspect or obtain a copy of your medical records under the California Health & Safety Code (§§ 123100 - 123149.5), we will permit inspection within 5 business days and provide copies within 15 days of your written request, in accordance with that law, rather than the one-month timeline that otherwise applies to other rights described in this Privacy Notice.
To exercise any of these rights contact us at privacy@tortushealth.com. TORTUS Health Inc. will respond within one calendar month. If you are dissatisfied with how we handle your request you have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk, to the California Privacy Protection Agency (cppa.ca.gov) for CCPA-related complaints.
Sharing your information Collected via Website
TORTUS Health Inc. will not share your information with any third parties for the purposes of direct marketing.
TORTUS Health Inc. use data processors, which are third parties that provide services for us. TORTUS Health Inc. have contracts in place with our data processors. This means that they cannot do anything with your personal information such as share it with other organizations unless we have instructed them to do so. They will hold your personal data securely and retain it for the period we instruct. When it is necessary for us to transfer your personal data outside of the UK, this will only be done in accordance with the UK GDPR and the Data Protection Act 2018 (DPA 2018).
In some circumstances, we are legally obliged to share information. For example, to comply with/ under a court order. In any scenario, we’ll satisfy ourselves that we have a lawful basis on which to share the information and document our decision-making.
Sharing your information Collected via our Product
To deliver TORTUS Health’s core function, TORTUS Health Inc. share personal data with the following Third-Party service providers (sub-processors). Named providers are those in use at the date of this notice. Where a category names more than one provider, TORTUS Health Inc. may add or substitute an equivalent provider or routing gateway within that category on the same contractual terms.
| Who we share your data with | What data is shared | Why | Protections and location |
|---|---|---|---|
| Speech and voice AI providers, currently Cartesia. Deepgram is an equivalent substitute in this category | Your live consultation audio, the transcript produced from it, your preferred name, and a summary of your previous consultations | To convert your speech to text, to speak the agent responses back to you, and to hold the live voice consultation | Data Processing Agreement in place. The providers' model-improvement programs are switched off, so your data is not used to train their models. Processed in the United States. Transfers protected by the UK International Data Transfer Agreement or Standard Contractual Clauses |
| Large language model providers, currently OpenAI and Anthropic. Google (Gemini, via Vertex AI) is an equivalent substitute in this category | Your consultation transcript, the messages you type, the clinical summaries generated from them, and the context needed to run automated safety, communication and clinical-pathway checks | To conduct the consultation, to draft your care plan, to generate clinical summaries, and to run automated safety and quality checks | Data Processing Agreement in place, with zero data retention and no training on your data contracted wherever the provider offers it. Processed in the United Kingdom or the United States. Transfers protected by the UK International Data Transfer Agreement or Standard Contractual Clauses |
| Google Cloud Platform, provided by Google LLC | All of the data described in this notice, held at rest and in transit | To host the service, its database and its supporting infrastructure | Data Processing Agreement in place. The primary patient database is hosted in the United Kingdom, in London. Encrypted in transit and at rest, with restricted and audited access. Some supporting services may process data in the United States under the UK International Data Transfer Agreement or Standard Contractual Clauses |
| Medplum | Your legal name, preferred name, date of birth, sex recorded at birth, email address and your TORTUS Health identifier. No consultation content, summaries, care plans or prescriptions are shared | To maintain your demographic record in an electronic health record | Data Processing Agreement in place. Processed in the United States. Transfers protected by the UK International Data Transfer Agreement or Standard Contractual Clauses |
| Twilio | Your mobile phone number and the one-time code sent to it | To send and check the text message that verifies your mobile number | Data Processing Agreement in place. Processed in the United States. Transfers protected by the UK International Data Transfer Agreement or Standard Contractual Clauses |
| Mailgun, provided by Sinch | Your email address, your preferred name, one-time codes and secure links. Care notifications also carry the name of your reviewing Clinician | To send account, verification and care-notification emails | Data Processing Agreement in place. Processed in the United States. Transfers protected by the UK International Data Transfer Agreement or Standard Contractual Clauses |
| Datadog | Technical telemetry only: your account identifier, device and application information, IP address, screens viewed, and error and performance data. No consultation content, and neither your name nor your email address, are sent | To monitor the reliability, performance and security of the service and to investigate faults | Data Processing Agreement in place. Primarily processed in the European Union. Some web telemetry may be processed in the United States under the UK International Data Transfer Agreement or Standard Contractual Clauses |
| Pharmacies and electronic prescribing networks | Your legal name, date of birth, contact details, and the prescription a Clinician has approved | To send an approved prescription to the pharmacy you chose so that it can be dispensed to you | Bound by healthcare data protection law and by contract. Processed in the United States. These recipients act as independent controllers of the data once it reaches them |
| Cloudflare | Domain name lookups only. No consultation content and no personal data passes through it | To resolve the domain names of our services | Data Processing Agreement in place. Global network. Our services are not proxied through it, so it does not sit in the path of your data |
| Apple and Expo | Application distribution, update and device diagnostic information. No consultation content is shared | To distribute the mobile app, to deliver updates to it, and to receive crash diagnostics | Standard platform terms. Processed in the United States. Transfers protected by the UK International Data Transfer Agreement or Standard Contractual Clauses |
TORTUS Health Inc. maintain a current list of sub-processors and will update it before any new sub-processor begins processing your personal data. The current list is available on the TORTUS Health Inc. website. TORTUS Health Inc. will notify you of material additions or changes to this list by email at least 14 days before the new sub-processor begins processing your personal data, giving you the opportunity to raise questions before the change takes effect.
TORTUS Health Inc. confirm that every Third Party with whom the product shares personal data is bound by a written contract (a Data Processing Agreement) that requires them to protect your personal data to the same or an equivalent standard as required by the UK GDPR and, Data Protection Act 2018. Third Parties may only process personal data on TORTUS Health Inc.’s documented instructions, must keep it secure and confidential, may not use it for their own purposes or share it with others, and must retain it only for the period we instruct. Where any of these providers process personal data outside the United Kingdom, TORTUS Health Inc. ensure that the transfer is protected by an appropriate safeguard recognized under the UK GDPR (such as an adequacy decision, the International Data Transfer Agreement, or Standard Contractual Clauses).
TORTUS Health Inc. do not share your information with any Third Party for the purposes of direct marketing, and TORTUS Health Inc. do not permit any Third-Party AI provider to retain your data or use it to train their models.
How we use your data to improve TORTUS Health
Beyond delivering your care, TORTUS Health Inc. use the data described in this notice to make TORTUS Health safer, more accurate and more useful. This includes:
- Quality and safety review. Measuring the quality and safety of consultations, including automated scoring of consultation records and review of real consultation records by authorized TORTUS Health Inc. personnel.
- Model development. Developing, training, fine-tuning, evaluating and customising the AI models, prompts, clinical pathways and safety checks used in the product.
- Personalization. Taking account of your previous consultations so that the agent gives you continuous care and does not ask you to repeat yourself.
- Customization. Tailoring the product for a particular healthcare organization, site or Clinician.
TORTUS Health Inc. de-identify data for these purposes wherever de-identification still achieves the purpose. Where identifiable data is necessary, TORTUS Health Inc. process it only in accordance with this notice, the Data Processing Agreement in place with your healthcare provider, applicable law, and any consent you have given. Access to identifiable consultation records for these purposes is restricted to authorized personnel, controlled by role, logged and auditable.
TORTUS Health Inc. do not sell your personal data, do not publish your personal data, and do not use your personal data for advertising.
Where you share information relating to sensitive services, including mental or behavioral health, sexual and reproductive health, sexually transmitted infections, substance use disorder, gender-affirming care, or intimate partner violence, TORTUS Health Inc. applies additional controls and, for California Residents, take steps consistent with California Assembly Bill 352 to limit access to authorized Personnel, segregate this information within our system, and restrict its disclosure, transfer or processing outside California except where necessary to deliver your care, required by law, or requested by you.
International Transfers
When personal data is transferred outside of the UK, the appropriate technical and organizational safeguards will be in place. All international transfers will only occur if it complies with the relevant legislation.
Visitors to our website
TORTUS Health Inc. use Google Analytics to collect information and details of visitor behavior patterns on our website. We do this to understand things such as the number of visitors to the different areas of the website. This information is only processed in a way which does not identify anyone. We do not make and do not allow Google to make, any attempt to discover the identities of those visiting our website. Details of Google’s Privacy Policy can be found here: https://www.google.com/policies/privacy.
Where TORTUS Health Inc. do want to collect personally identifiable information through our website, TORTUS Health Inc. will make this clear at the point that personal information is collected and TORTUS Health Inc. will explain what we intend to do with it.
Use of cookies
Like many other websites, our website uses cookies. ‘Cookies’ are small pieces of information sent by a website to your device and stored to enable that website to recognize you when you visit in the future. They can also be used to collect statistical data about your browsing activity and patterns of behavior but do not identify you as an individual. This helps us to understand how people who visit our website use it, enabling us to improve the layout and content for visitors.
For more information about which cookies are used by our website, please refer to the Cookie Notice on our website.
It is possible to switch off cookies by adjusting your browser preferences and settings. Turning cookies off may result in a loss of functionality when using our website.
Links to other websites
Where TORTUS Health Inc. provide links to websites of other organizations, this privacy notice does not cover how that organization processes personal information. TORTUS Health Inc. encourage you to read the privacy notices on the other websites you visit.
How to make a complaint
TORTUS Health Inc. strive to meet the highest standards when collecting and using personal information. For this reason, TORTUS Health Inc. take any complaints we may receive about this very seriously. TORTUS Health Inc. encourage people to inform us if they think that any collection or use of information by us is unfair, misleading or inappropriate. TORTUS Health Inc. would also welcome any suggestions for improving our procedures. You can do this by contacting us using one of the below methods:
Email: support@tortushealth.com
California residents may contact the California Privacy Protection Agency (cppa.ca.gov).
If you remain dissatisfied, you have the right to make a complaint to the Information Commissioner’s Office (ICO). Please see the ICO’s website for more information: www.ico.org.uk
Notice to California Residents. If you are a California resident, then under California Civil Code Section 1789.3, you may contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs in writing at 1625 N. Market Blvd., Suite N 112, Sacramento, California 95834, or by telephone at +1-800-952-5210 in order to resolve a complaint regarding the Medical Services or to receive further information regarding use of the Medical Services.
Changes to this privacy notice
TORTUS Health Inc. reserve the right to modify this Privacy Notice at any time, so please make sure to review this frequently. Our most updated Privacy Notice is posted on our website. All changes will apply with immediate effect.
Addendum 1 - TORTUS Health Mobile App
Purpose of this Addendum
This addendum supplements the main TORTUS Health Inc. Privacy Policy. It describes how the TORTUS Health Mobile App available via the Apple App Store collects, uses, stores, shares with Third Parties under a Data Processing Agreement and deletes any personal information.
It should be read alongside the main Privacy Policy. Where the main Privacy Policy and this addendum conflict, this addendum should take precedence for TORTUS Health Mobile App Users.
Who this addendum applies to
This addendum applies to Patients of TORTUS Health Inc. who engage with TORTUS Health via the iOS mobile app.
What personal data we collect
In addition to any data described in the main Privacy Policy, for TORTUS Health Mobile App Users we collect:
Patient data (entered at sign-up or captured during a consultation)
| Data element | Format | Why collected |
|---|---|---|
| Legal name | Text (first, middle and last name, stored as separate parts) | Your legal identity for the medical record and prescriptions |
| Preferred name | Text (optional) | The name the app and the consultation agent greet you by |
| Date of birth | Date (YYYY-MM-DD) | To confirm eligibility (18+), help identify you, and provide clinical context for prescribing |
| Sex recorded at birth | Selection (female / male / intersex or self-describe), with optional free-text detail | The clinical variable prescribing and reference ranges need (deliberately not gender identity) |
| Consent records | Document version and server timestamp per legal document | The legal record of your acceptance of theterms of service, privacy policy and California notices |
| Preferred pharmacy | Snapshot of the directory record (NCPDP identifier, name, address, phone) | Where your prescriptions are sent |
| ZIP code (pharmacy search) | 5-digit ZIP code | To find pharmacies near you; only the pharmacy you choose is stored |
| Consultation voice audio | Live audio stream (16 kHz PCM), processed in real time; not stored as a recording | To hold the voice consultation — transcribed and responded to as you speak |
| Consultation messages and transcript | Text | The record of your consultation, used to provide care and reviewed by your clinical team |
| Conversation title | Text (a short summary of why you came) | To label your conversations in the app |
| Care plans and prescriptions | Structured records (medication, dose, instructions, status) | The draft care your consultation produces, reviewed and approved by a clinician before anything is actioned |
| Clinician review outcomes | Text (reviewing clinician's name, note and approved items) | To show you the outcome of clinical review |
Your account data:
| Data element | Format | Why collected |
|---|---|---|
| Email address | Email address | To create and sign in to your account, verify it with an emailed one-time code, and reset your password |
| Password | Stored as a secure hash, never in plain text | To authenticate you |
| Mobile phone number | US phone number, verified by a texted one-time code | A contact detail so your care team can reach you; not used for sign-in |
| User ID | Unique identifier | To authenticate you and associate your data with your account; the only identity our monitoring service receives |
| Authentication tokens | Secure session cookie held in the device's secure storage | To keep you signed in and authorise requests to our service on your behalf |
Device and usage data:
| Data element | Format | Why collected |
|---|---|---|
| Device and operating system information | Text | Diagnostics, compatibility, and to investigate faults |
| App version | Text | Support, diagnostics, and to deliver the correct features/updates |
| IP address and device user agent | Network address and text, recorded per sign-in session and when the app communicates with our services | Service delivery, session management, network security, and fraud/abuse prevention |
| Usage and interaction data | Event data (screens viewed, named actions taken) | To understand how the app is used and to improve it |
| Diagnostic, crash and performance data | Logs, error/stack traces, timing metrics (never message content or personal identifiers) | To monitor stability and reliability and to fix problems |
Sharing your information
The general commitments set out in 'Sharing your information' above apply in full to the TORTUS Health Mobile App. This addendum sets out, specifically for the TORTUS Health Mobile App, the Third-Parties with whom TORTUS Health Inc. share personal data in order to provide the TORTUS Health Mobile App's features, and confirms the protections in place.
To deliver the Mobile App's core function, TORTUS Health Inc. share personal data with the following Third-Party service providers (sub-processors):
| Who we share it with | What data is shared | Why | Protections and location |
|---|---|---|---|
| Google Cloud (Google Cloud Platform) | All data the service stores (your account, patient record and consultation transcripts); encrypted in transit and at rest | Secure cloud hosting of the service and its database | Data Processing Agreement in place. The primary patient database is hosted in the United Kingdom, in London. Encrypted in transit and at rest, with restricted and audited access. Some supporting services may process data in the United States under the UK International Data Transfer Agreement or Standard Contractual Clauses |
| Cartesia | Live consultation audio (your speech and the agent's replies) | Current speech and voice AI provider. To transcribe your speech and to speak replies back to you during a voice consultation. Audio is processed in real time and is not kept as a recording | Data Processing Agreement in place. Processed in the United States. Transfers protected by the UK International Data Transfer Agreement or Standard Contractual Clauses |
| Deepgram | Live consultation audio and the agent's reply text | Equivalent speech and voice AI substitute. May be used instead of Cartesia for real-time speech-to-text and text-to-speech during voice consultations | Processed under a Data Processing Agreement; processed in the United States |
| OpenAI | Consultation transcript text and consultation context (never the audio) | Current large language model provider. To understand you, draft your care plan, and run clinical-safety checks | Enterprise agreement and a zero-data-retention policy; data is not retained by, or used to train the models of, the provider; processed in the United States |
| Anthropic | Consultation transcript text, the messages you type, and consultation context (never the audio) | Current large language model provider. To generate the agent's replies during the consultation | Data Processing Agreement in place, with zero data retention and no training on your data; processed in the United States |
| Google (Gemini, via Vertex AI) | Consultation transcript text and consultation context (never the audio) | Equivalent large language model substitute. May be used instead of OpenAI or Anthropic to conduct the consultation, draft a care plan, or run clinical-safety checks | Processed within TORTUS Health's own Google Cloud project under a Data Processing Agreement; model processing in the United States |
| Medplum | Your patient identifier, legal name, preferred name, date of birth, sex at birth, email address, and your chosen pharmacy | To maintain your electronic health record and to search the pharmacy directory your prescriptions are sent through | Processed under a Data Processing Agreement; per-environment tenancy isolation; hosted in the United States |
| Twilio | Your mobile phone number | To text you the one-time code that verifies your number | Data Processing Agreement in place. Processed in the United States. Transfers protected by the UK International Data Transfer Agreement or Standard Contractual Clauses |
| Mailgun | Your email address and the content of transactional emails (verification codes, password resets, account requests) | To send you the emails that operate your account | Data Processing Agreement in place. Processed in the United States. Transfers protected by the UK International Data Transfer Agreement or Standard Contractual Clauses |
| Datadog | Usage, diagnostic, crash and performance data, and an opaque account identifier (never your name, contact details or any consultation content) | To monitor reliability and performance and to investigate faults | Processed under a data processing agreement; hosted in the EU |
TORTUS Health Inc. confirm that every Third Party with whom the Mobile App shares personal data is bound by a written contract (a Data Processing Agreement) that requires them to protect your personal data to the same or an equivalent standard as required by the UK GDPR, Data Protection Act 2018. Third Parties may only process personal data on TORTUS Health Inc.’s documented instructions, must keep it secure and confidential, may not use it for their own purposes or share it with others, and must retain it only for the period we instruct. Where any of these providers process personal data outside the United Kingdom, TORTUS Health Inc. ensure that the transfer is protected by an appropriate safeguard recognized under the UK GDPR (such as an adequacy decision, the International Data Transfer Agreement, or Standard Contractual Clauses).
TORTUS Health Inc. do not share your information with any Third Party for the purposes of direct marketing, and TORTUS Health Inc. do not permit any Third-Party AI provider to retain your data or use it to train their models.
Lawful Basis for Processing
The general commitments set out in 'The Lawful Basis for the Processing of Personal Data' section above apply in full to the TORTUS Health Mobile App. Consent is freely given, specific, informed and unambiguous, captured through confirmation of Reading and Understanding this policy when you first sign up to the TORTUS Health Mobile App. Consent can be withdrawn at any time by contacting support@tortushealth.com. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
Your rights
Under applicable law, including the CCPA/CPRA and the UK GDPR, you have the right to access, rectify, erase, restrict, object to and port your personal data. You can request deletion of your account from Settings in the app. We action deletion requests within 72 hours. Clinical records that we are legally required to keep are retained as described under Retention, and are no longer linked to an active account. To exercise any of these rights contact us at privacy@tortushealth.com. TORTUS Health Inc. will respond within one calendar month. If you are dissatisfied with how we handle your request you have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk, to the California Privacy Protection Agency (cppa.ca.gov) for CCPA-related complaints.
Changes to this addendum
TORTUS Health Inc. may update this addendum. Material changes will be communicated to active TORTUS Health App Users before taking effect. The current version is always available at tortushealth.com/privacy.
Addendum 2 - California Privacy Rights (CCPA/ CPRA)
If you are a California Resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), gives you specific rights regarding the personal information which TORTUS Health Inc. collects through this website.
Categories of Personal information TORTUS Health Inc. collects**, and** the retention periods for each:
| Category | Examples | Retention Period |
|---|---|---|
| Identifiers | Name, Email Address, Business Contact Details | 24 months from last interaction for prospects and leads/ Duration of commercial relationship + 6 years after termination for Customers |
| Commercial Information | Inquiries, demo requests, meeting notes | 24 months from last interaction for prospects and leads / Duration of commercial relationship + 6 years after termination for Customers |
| Internet/ Network activity | Cookies, analytics, device / browser data | 5 years per cookie policy |
| Professional / employment information | Job applications | 6 years |
TORTUS Health Inc. do not sell personal information and do not share personal information for cross-context behavioral advertising, as those terms are defined under CCPA.
Medical information governed by the CMIA is exempt from the CCPA to the extent set out in California Civil code section 1798.146. Other personal information TORTUS Health Inc. collect through the TORTUS Health product, including device, usage and diagnostic data is not exempt and remains subject to the CCPA rights described in this Addendum. This CCPA section otherwise applies to personal information collected through this website (e.g. contact forms, cookies, job applications).
TORTUS Health Inc.'s website may collect limited categories of sensitive personal information, such as information you voluntarily provide in free-text form fields (which may incidentally reference health-related context). TORTUS Health Inc. use sensitive personal information solely for purposes permitted under the CCPA/ CPRA, including providing the services you request and ensuring the security of our systems, and do not use it to infer characteristics about you or for advertising purposes. TORTUS Health Inc.'s use is limited to these permitted purposes, a separate right to limit does not apply; however, you may still exercise your right to know what personal information TORTUS Health Inc. hold about you, the right to delete it, the right to correct inaccurate information, the right to opt out of sale / sharing, the right to limit use of sensitive personal information and the right to non-discrimination for exercising these rights as described above.
To exercise these rights, contact support@tortushealth.com, consistent with the process outlined in the GDPR Compliance Policy.