Privacy Policy

Effective Date: March 27, 2026 · Last Updated: March 27, 2026

FreeHealth.ai, Inc. ("FreeHealth," "we," "us," or "our") is committed to protecting the privacy of your personal information and health data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, website, and related services (collectively, the "Service").

1. Information We Collect

1.1 Information You Provide

• Account Information: Name, email address, date of birth, gender, phone number when you create an account.
• Health Information: Chief complaints, symptoms, medical history, medications, family health history, and other health data you voluntarily provide during AI health interviews and check-ins (PROMIS, PHQ-9, GAD-7, WHO-5).
• Payment Information: Billing details processed by our payment provider (Stripe). We do not store full credit card numbers on our servers.

1.2 Information Collected Automatically

• Biometric Data from Facial Scanning: When you use our facial scan feature, our on-device AI analyzes your face to estimate 40+ biometric readings including heart rate, blood pressure, respiratory rate, stress level, skin health markers, and cardiovascular risk indicators. Raw facial images and video frames are processed entirely on your device and are never transmitted to or stored on our servers. Only computed numerical scores are sent to our backend.
• Wearable and Connected Device Data: If you connect third-party health services (Apple Health, Google Fit, Fitbit, Garmin, Oura, etc.), we collect the health metrics you authorize.
• Voice Data: If you use voice check-in features, audio is processed for transcription and health assessment. Audio recordings may be transmitted to our partner (Lucas AI) for clinical analysis when you initiate a formal health interview.
• Usage Data: App interactions, feature usage, session duration, and crash reports to improve the Service.
• Device Information: Device model, operating system, unique device identifiers, and IP address for security and compatibility.

1.3 Information from Third Parties

• Healthcare Providers: If you connect your Electronic Health Records (EHR) via FHIR-compatible systems, we receive the health data you authorize.
• Lucas AI: Our clinical AI partner returns structured medical analysis including potential diagnoses (ICD-10 codes), procedure codes (CPT), symptom categorization, and care recommendations based on your interview.
• doc.com: Our telehealth partner provides session data and audio recordings from health interviews you participate in.

2. How We Use Your Information

3. Biometric Data Notice

Our facial scanning feature collects biometric information as defined under applicable state laws, including the Illinois Biometric Information Privacy Act (BIPA), Texas CUBI, and Washington state biometric laws.

• On-device processing only: Facial analysis runs entirely on your device using TensorFlow Lite. Raw images and video frames are never transmitted to our servers.
• No biometric templates stored: We do not create, store, or retain facial recognition templates or facial geometry data.
• Derived scores only: Only computed numerical health scores (heart rate, stress level, etc.) are sent to our servers — these are health metrics, not biometric identifiers.
• Explicit consent required: You must affirmatively consent before using the facial scan feature for the first time.
• Right to refuse: You may use the Service without the facial scan feature.
• Retention: Derived biometric health scores are retained as part of your health record. You may request deletion at any time.

4. How We Share Your Information

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

5. HIPAA Compliance

Where FreeHealth acts as a Business Associate under the Health Insurance Portability and Accountability Act (HIPAA), we comply with all applicable HIPAA requirements for the protection of Protected Health Information (PHI).

• Business Associate Agreements (BAAs): We maintain signed BAAs with all vendors that process PHI on our behalf, including our database provider, cloud infrastructure, AI partners, and communication services.
• Technical Safeguards: AES-256 encryption at rest, TLS 1.3 in transit, row-level security on all PHI tables, and column-level encryption on sensitive fields (diagnosis codes, SSN, date of birth).
• Administrative Safeguards: Role-based access controls, workforce training, minimum necessary access principle, and regular security assessments.
• Audit Trail: Every access to PHI is logged with timestamp, user identity, action performed, and resource accessed. Audit logs are append-only and retained for a minimum of 6 years.
• Breach Notification: In the event of a breach of unsecured PHI, we will notify affected individuals within 60 days as required by the HIPAA Breach Notification Rule, and report to the HHS Office for Civil Rights.

6. Data Retention

7. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights:

• Access: Request a copy of the personal and health data we hold about you.
• Correction: Request correction of inaccurate personal data.
• Deletion: Request deletion of your account and associated data, subject to legal retention requirements.
• Data Portability: Export your health data in a machine-readable format (FHIR R4 compatible).
• Restrict Processing: Limit how we use your data in certain circumstances.
• Withdraw Consent: Revoke consent for data processing at any time. This does not affect the lawfulness of processing before withdrawal.
• Opt-Out of Research: You may opt out of anonymized data research at any time via Settings > Privacy > Research Data Sharing.
• Disconnect Services: Revoke access to connected wearables, EHRs, or other third-party sources at any time.

To exercise these rights, contact us at [email protected] or use the in-app privacy controls in Settings.

8. Children's Privacy

The Service is not intended for individuals under the age of 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children. If we learn that we have collected information from a child under 18, we will promptly delete that information. If you believe a child has provided us with personal information, please contact us at [email protected].

9. International Data Transfers

Your information may be processed in countries other than your country of residence. We ensure appropriate safeguards are in place for international transfers, including standard contractual clauses and data processing agreements. For EU/EEA users, we comply with the General Data Protection Regulation (GDPR). For California residents, we comply with the California Consumer Privacy Act (CCPA/CPRA).

10. Security

We implement industry-standard security measures including:

• End-to-end encryption (TLS 1.3) for all data in transit
• AES-256 encryption for all data at rest
• Row-level security (RLS) ensuring users can only access their own health data
• Multi-factor authentication (MFA) support
• Regular penetration testing and security audits
• SOC 2 Type II and HIPAA compliance monitoring via automated tooling
• Incident response plan with defined breach notification procedures

11. Third-Party AI and Machine Learning

Our Service uses artificial intelligence and machine learning models to provide health insights. You should be aware that:

• AI-generated insights are not medical diagnoses and should not replace professional medical advice.
• We use multiple AI models with different capabilities. Your data may be processed by our AI partners (Anthropic Claude) under strict data processing agreements.
• AI model versions are tracked and auditable for regulatory compliance.
• Your health data is never used to train third-party AI models without your explicit, separate consent.

12. De-Identified and Aggregated Data

With your explicit opt-in consent, we may create de-identified, aggregated datasets from health data for research purposes. De-identification follows the HIPAA Safe Harbor method (removal of all 18 identifiers) and k-anonymity verification (k≥5). You may opt in or out of research data sharing at any time. Opting out does not affect your use of the Service.

13. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via email and/or an in-app notification at least 30 days before the changes take effect. Your continued use of the Service after the effective date constitutes acceptance of the updated policy.

14. Contact Us

If you have questions about this Privacy Policy or our data practices:

• Email: [email protected]
• Mail: FreeHealth.ai, Inc., Attn: Privacy Officer
• HIPAA complaints: You may also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights.

Terms and Conditions

Effective Date: March 27, 2026 · Last Updated: March 27, 2026

These Terms and Conditions ("Terms") govern your access to and use of the FreeHealth.ai mobile application, website, and related services (collectively, the "Service") provided by FreeHealth.ai, Inc. ("FreeHealth," "we," "us," or "our"). By accessing or using the Service, you agree to be bound by these Terms.

1. Acceptance of Terms

By creating an account, accessing, or using the Service, you acknowledge that you have read, understood, and agree to be bound by these Terms, our Privacy Policy, and any additional terms applicable to specific features you use. If you do not agree to these Terms, you must not use the Service.

We reserve the right to update these Terms at any time. We will provide at least 30 days' notice of material changes via email or in-app notification. Continued use of the Service after the effective date of changes constitutes acceptance.

2. Description of Service

FreeHealth.ai provides a health intelligence platform that includes:

• Facial biometric scanning using on-device AI to capture health metrics (heart rate, blood pressure, stress, and 40+ additional readings)
• AI health interviewer for conversational health intake and symptom assessment
• Health dashboard with scores, trends, and risk indicators
• Telehealth interview integration via third-party providers (doc.com)
• Clinical data analysis via AI partner (Lucas AI) for structured medical interpretation
• Prescriptive marketplace matching health products, services, and providers to your health profile
• Health check-ins including validated clinical instruments (PROMIS, PHQ-9, GAD-7, WHO-5)
• Family health sharing with permission-based access controls
• Wearable and EHR data integration from third-party services you connect

Features and availability may vary by region, device, and subscription tier.

3. Important Health Disclaimer

All health information, scores, insights, recommendations, and AI-generated content provided through the Service are for informational and educational purposes only. They are designed to support — not replace — the relationship between you and your healthcare providers.

• Health scores and biometric readings are estimates derived from AI analysis and may not be clinically accurate. They are not FDA-cleared diagnostic measurements.
• AI-generated triage recommendations (self-care, telehealth, urgent care, emergency) are decision-support suggestions, not clinical determinations.
• Diagnoses (ICD-10), procedure codes (CPT), and clinical summaries generated by our AI partners are preliminary assessments that require verification by a licensed healthcare professional.
• Marketplace product and service recommendations are based on health profile matching algorithms and do not constitute prescriptions or medical orders.
• Always consult qualified healthcare professionals for medical advice, diagnosis, and treatment.
• In case of a medical emergency, call 911 (or your local emergency number) immediately. Do not rely on the Service for emergency medical guidance.

4. Eligibility

To use the Service, you must:

• Be at least 18 years old (or the age of majority in your jurisdiction)
• Have the legal capacity to enter into these Terms
• Not be prohibited from using the Service under applicable law
• Provide accurate and complete information during registration

The Service is not intended for use by individuals under 18. Parents or guardians may use the Family Health features to track dependents' health, but the account holder must be an adult.

5. Your Account

5.1 Registration

You must create an account to use most features of the Service. You agree to provide accurate, current, and complete registration information and to update it as needed.

5.2 Security

You are responsible for maintaining the confidentiality of your account credentials and for all activities under your account. You must immediately notify us at [email protected] if you suspect unauthorized access. We strongly recommend enabling multi-factor authentication (MFA).

5.3 Account Roles

Depending on your use of the Service, you may have one of the following roles, each with different access levels:

6. Subscriptions and Payments

6.1 Free and Paid Tiers

The Service offers a free tier (facial scan, basic health profile, marketplace browsing) and premium subscription tiers with additional features. Premium features, pricing, and availability are described in the app and on our website.

6.2 Billing

Subscription fees are charged in advance on a recurring basis (monthly or annually). Payments are processed by Stripe. By subscribing, you authorize us to charge your payment method at the applicable rate.

6.3 Cancellation and Refunds

You may cancel your subscription at any time through the app or by contacting [email protected]. Upon cancellation, you retain access to premium features until the end of your current billing period. Refunds are provided in accordance with applicable law and our refund policy.

6.4 Marketplace Transactions

Purchases of products and services through the FreeHealth marketplace are transactions between you and the marketplace partner (vendor). FreeHealth facilitates the transaction but is not the seller. Each marketplace partner has their own terms, refund policies, and warranties. FreeHealth processes payments via Stripe Connect and remits funds to partners after deducting the applicable commission.

7. Facial Scanning and Biometric Data

By using the facial scan feature, you acknowledge and agree that:

• Your device camera will capture video of your face for biometric analysis.
• Processing occurs entirely on your device — raw facial images are never transmitted to our servers.
• Only computed health metrics (numerical scores) are transmitted and stored.
• You may opt out of facial scanning and still use other features of the Service.
• Biometric data rights vary by jurisdiction. See our Privacy Policy Section 3 for state-specific biometric data notices (BIPA, CUBI, etc.).

8. AI and Machine Learning

The Service uses artificial intelligence and machine learning extensively. You acknowledge that:

• AI-generated content may contain errors, inaccuracies, or hallucinations. AI outputs should be verified by qualified professionals before acting on them.
• AI models are continuously improved. Results may vary over time as models are updated.
• Your interactions with AI features (health chat, interviewer) may be processed by third-party AI providers under strict data processing agreements.
• AI triage recommendations are not a substitute for professional medical judgment.
• We maintain versioned records of AI model deployments for regulatory and audit purposes.

9. Third-Party Services and Integrations

The Service integrates with third-party services including:

• doc.com for telehealth interviews — governed by doc.com's own terms and privacy policy
• Lucas AI for clinical data analysis — operates under a Business Associate Agreement with FreeHealth
• Wearable platforms (Apple Health, Google Fit, Fitbit, etc.) — data sharing governed by your settings with each platform
• EHR systems — connected via FHIR R4 with your explicit authorization
• Marketplace partners — each partner has independent terms for their products/services

We are not responsible for the availability, accuracy, or practices of third-party services. Your use of third-party services is at your own risk and subject to their terms.

10. Marketplace Terms

10.1 FreeHealth as Platform

FreeHealth operates the marketplace as a platform connecting consumers with health product and service providers. FreeHealth is not the manufacturer, seller, or provider of marketplace items unless explicitly stated.

10.2 Product Recommendations

Marketplace recommendations are generated by our AI matching engine based on your health profile. Recommendations are not endorsements, prescriptions, or medical orders. Always consult a healthcare professional before starting new supplements, medications, or health programs.

10.3 Partner Responsibility

Marketplace partners are solely responsible for the quality, safety, legality, and fulfillment of their products and services. FreeHealth does not warrant or guarantee any marketplace product or service.

10.4 Reviews and Outcomes

You may submit reviews and health outcome data for marketplace products. By submitting, you grant FreeHealth a non-exclusive, royalty-free license to use, display, and aggregate your review content. Outcome data is anonymized before being used to improve matching algorithms.

11. Acceptable Use

You agree not to:

• Use the Service for any unlawful purpose or in violation of any applicable law or regulation
• Provide false, misleading, or fraudulent health information
• Attempt to access other users' accounts, data, or health records
• Reverse engineer, decompile, or disassemble any part of the Service
• Use the Service to develop a competing product
• Circumvent security measures, rate limits, or access controls
• Submit content that is harmful, threatening, abusive, or harassing
• Use automated systems (bots, scrapers) to access the Service without prior written consent
• Resell, sublicense, or commercially exploit the Service without authorization

Violation of these terms may result in immediate suspension or termination of your account.

12. Intellectual Property

The Service, including its design, features, content, AI models, health algorithms, matching engine, and all related intellectual property, is owned by FreeHealth.ai, Inc. and protected by copyright, trademark, patent, and other intellectual property laws.

You retain ownership of the health data you provide. By using the Service, you grant FreeHealth a limited, non-exclusive license to use your data as described in our Privacy Policy to provide, improve, and personalize the Service.

"FreeHealth," "FreeHealth.ai," the FreeHealth logo, and all related marks are trademarks of FreeHealth.ai, Inc.

13. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW:

• THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.
• FREEHEALTH DOES NOT WARRANT THAT THE SERVICE WILL BE UNINTERRUPTED, ERROR-FREE, OR SECURE, OR THAT ANY HEALTH DATA, SCORES, OR INSIGHTS WILL BE ACCURATE OR COMPLETE.
• IN NO EVENT SHALL FREEHEALTH, ITS OFFICERS, DIRECTORS, EMPLOYEES, OR AGENTS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING LOSS OF DATA, HEALTH OUTCOMES, REVENUE, OR PROFITS, ARISING FROM YOUR USE OF THE SERVICE.
• OUR TOTAL AGGREGATE LIABILITY FOR ALL CLAIMS ARISING FROM OR RELATED TO THE SERVICE SHALL NOT EXCEED THE GREATER OF (A) THE AMOUNT YOU PAID US IN THE 12 MONTHS PRECEDING THE CLAIM, OR (B) ONE HUNDRED U.S. DOLLARS ($100).
• FREEHEALTH IS NOT LIABLE FOR ANY HEALTH DECISIONS, TREATMENTS, OR OUTCOMES BASED ON INFORMATION PROVIDED THROUGH THE SERVICE.

14. Indemnification

You agree to indemnify, defend, and hold harmless FreeHealth.ai, Inc. and its officers, directors, employees, contractors, and agents from any claims, damages, losses, or expenses (including reasonable attorneys' fees) arising from your use of the Service, violation of these Terms, or infringement of any third-party rights.

15. Dispute Resolution

15.1 Governing Law

These Terms are governed by the laws of the State of Delaware, United States, without regard to conflict of law principles.

15.2 Arbitration

Any dispute arising from or related to these Terms or the Service shall be resolved through binding arbitration administered by the American Arbitration Association (AAA) under its Commercial Arbitration Rules. The arbitration shall take place in Delaware or, at your election, via video conference. The arbitrator's decision shall be final and binding.

15.3 Class Action Waiver

YOU AGREE THAT ANY DISPUTE RESOLUTION PROCEEDINGS WILL BE CONDUCTED ONLY ON AN INDIVIDUAL BASIS AND NOT IN A CLASS, CONSOLIDATED, OR REPRESENTATIVE ACTION. If this waiver is found unenforceable, then the entirety of this arbitration provision shall be null and void.

15.4 Exceptions

Nothing in this section prevents either party from seeking injunctive or other equitable relief in court for matters related to intellectual property, data security, or unauthorized access.

16. Termination

You may terminate your account at any time through Settings > Account > Delete Account, or by emailing [email protected].

We may suspend or terminate your account if you violate these Terms, engage in fraudulent activity, or if required by law. Upon termination:

• Your access to the Service will cease immediately.
• You may request export of your health data for 30 days after termination.
• We will retain data as required by law (see Privacy Policy Section 6 for retention periods).
• Any outstanding marketplace orders will be fulfilled according to their terms.

17. Force Majeure

FreeHealth shall not be liable for any failure or delay in performance due to circumstances beyond our reasonable control, including natural disasters, pandemics, government actions, internet or infrastructure failures, or third-party service outages.

18. Severability

If any provision of these Terms is found to be unenforceable or invalid, that provision shall be limited or eliminated to the minimum extent necessary, and the remaining provisions shall remain in full force and effect.

19. Entire Agreement

These Terms, together with the Privacy Policy and any additional terms for specific features, constitute the entire agreement between you and FreeHealth regarding the Service and supersede all prior agreements.

20. Contact

For questions about these Terms:

• Email: [email protected]
• General support: [email protected]
• Security issues: [email protected]
• Mail: FreeHealth.ai, Inc., Attn: Legal Department