Privacy Policy

Last Updated: August 4, 2025

HDX Labs, Inc. (“HDX”, “HealthEx”, “we”, “our”) provides a platform for individuals to access, manage, and share their health data and information with third parties (the “Platform”).

This Privacy Policy describes (1) how we handle personal information that we collect in connection with our Platform, our websites (including https://www.healthex.io/), and your other interactions with HDX, (2) how we use and share that information, and (3) the rights and choices you have.

Applicability of this Privacy Policy

We have developed relationships and built integrations with various health systems and networks (each, a “Third-Party Health Network”). Our Platform enables individuals to manage and share their personal information which may include health data, related information, and “protected health information” (those categories collectively, “User Health Data”) stored at these Third-Party Health Networks with various third parties (together with Third-Party Health Networks, “Third-Party Partners”) at the individual’s direction.

When we process personal information to Third-Party Partners on your behalf, we process your personal information (including User Health Data) on your behalf as a “controller”. In limited circumstances, we process your personal information on behalf of Third-Party Health Networks as a “service provider” or “processor” and do not control how such User Health Data is used. Where we process your personal information as a “service provider” or “processor”, we will provide you with a notice-at-collection on behalf of our Third-Party Partner. In all cases, if you have questions or concerns with respect to how a Third-Party Partner is processing your User Health Data after you have chosen to share it with them, please contact the corresponding Third-Party Partner.

Additionally, we also act as an Individual Access Service Provider in connection with our Trusted Exchange Framework and Common Agreement (“TEFCA”). You may elect for our Platform to receive your User Health Data and other personal information through our TEFCA connection. This Privacy Policy does not apply to our processing of your personal information we receive, at your direction, through our TEFCA connection, instead our TEFCA Privacy and Security Notice Addendum will apply.

Personal Information We Collect

Information you provide to us:

User Health Data: We may process your User Health Data in a transient manner in connection with your use of the Platform. This can include any health data and information you elect for us to process on your behalf.
Account Registration Information, such as the information you provide to us in order to register an account on the Platform (e.g. name, email, etc.). This does not include your User Health Data.
Feedback or correspondence, such as information you provide when you contact us with questions, feedback, reviews, or otherwise correspond with us online.
Usage information, such as information about how you use the Platform and interact with us.
Marketing information, such as your preferences for receiving communications about our activities, services, and publications, and details about how you engage with our communications.
Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Platform, our communications and other online services, such as:

Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them. We may use third party tools to assist with capturing online activity data.
Email Open/Click Information. We may use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email that we may send to you.

We use the following tools for automatic data collection:

Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How We Use Your Personal Information

To operate our Platform. We may use your personal information to:

Provide, operate, maintain, secure and improve our Platform.
Provide information about our Platform.
Communicate with you about our Platform, including by sending you announcements, updates, security alerts, and support and administrative messages.
Respond to your requests, questions and feedback.

Marketing and advertising. We may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers and events via email. You may opt out of our marketing communications as described in the “Opt out of marketing communications” section below.

For research and development. We may use your personal information for research and development purposes, including to analyze and improve our Platform and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into de-identified data by removing information that makes the data personally identifiable to you. We may use this de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve our Platform and promote our business.

Compliance and protection. We may use personal information to:

Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims).
Audit our internal processes for compliance with legal and contractual requirements and internal policies.
Enforce the terms and conditions that govern our Platform.
Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Sharing of Your Personal Information

Your Sharing: When you use our Platform, you may be able to provide your User Health Data and other personal information you obtain from one Third-Party Partner to other Third-Party Partners supported on our Platform. You will have discretion in determining the items of personal information that are shared with such Third-Party Partners. You agree and acknowledge that the Third-Party Partners are unaffiliated with HealthEx and that the Third-Party Partners’ use and processing your personal information will be done in accordance with their respective Privacy Policies. If you have questions or concerns regarding a Third-Party Partners’ processing of your information or would like to exercise any rights that you may have with respect to information processed by a Third-Party Partners, please contact the corresponding Third-Party Partners.

Our Sharing: We may share your personal information in the following circumstances:

Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate our Platform (such as user support, hosting, analytics, email delivery, marketing, and database management services).
Advertising partners. If you have signed up or otherwise elected to receive marketing communications, we may share your personal information (excluding User Health Data) with third party advertising companies, including for the interest-based advertising purposes described above.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.

Privacy Choices

You have the following choices regarding our collection and use of your personal information:

Access or update your Account Information. You may review and update your HDX Account Information by logging into your account.

Opt-out of marketing communications. You can opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the emails you receive from us. If you do so, you will continue to receive service-related and other non-marketing emails until you cease using our services linked to those service updates.

Privacy rights. Depending on your location and the nature of your interactions with our Platform, you may have the right to submit requests about your personal information:

Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
Correction of personal information that is inaccurate or out of date.
Deletion of personal information that we no longer need to provide our services or for other lawful purposes.
Opt-out of the “selling” and “sharing” of your personal information. By default, we do not “sell” or “share” your personal information.
Additional rights, such as to object to and request that we restrict our use of your personal information, and where applicable, to withdraw your consent.

To make a request, please email us as provided in the “How to Contact Us” section below. We may ask for specific information from you to help us confirm your identity. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Online tracking opt-out. There are a number of ways to opt out of having your online activity and device data collected through our Platform, which we have summarized below:

Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit allaboutcookies.org.

Use the following links to learn more about how to control cookies and online tracking through your browser:

Firefox; Chrome; Microsoft Edge; Safari
Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
Google Analytics. We use Google Analytics to help us better understand how people engage with the Platform by collecting information and creating reports about how users use our Platform. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
Using privacy plug-ins or browsers. You can block our website from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
Platform opt-outs. Some third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, allow you to opt-out directly by using their opt-out tools. Some of these providers, and links to their opt-out tools, are:
- Google
- Facebook
Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
- Digital Advertising Alliance
- Network Advertising Initiative

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below.

Do Not Track. Some Internet browsers can be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Data Retention

We may retain your personal information for as long as it is reasonably needed in order to maintain and expand our relationship and provide you with our services; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes. When it comes to User Health Data, we typically retain such data in an identifiable form for less than 72 hours. However, our retention of your User Health Data depends on how you use our Platform. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of such information, the potential risk of harm from unauthorized use or disclosure of such information, the purposes for which we process it, and the applicable legal requirements.

Other sites, mobile applications and services

Our Platform may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

Security practices

We use reasonable organizational, technical and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information. In the event that we are required to notify you about a situation involving your data, we may do so by email or telephone to the extent permitted by law.

Children

Our Platform is not intended for children, and we do not collect personal information from them. We define “children” as anyone under 18 years old. If we learn we have collected or received personal information from a child without verification of parental consent, we will delete the information. If you believe we might have any information from or about a child, please contact us via the contract information noted below.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our website. We may also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through our Platform.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on our Platform (or as otherwise indicated at the time of posting). In all cases, your continued use of the Platform after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.