Privacy Policy

This Privacy Policy explains how MANA LLC, a Colorado limited liability company ("MANA", "we", "us", or "our"), collects, uses, stores, processes, discloses, and protects information in connection with MedicalSpace (the "Platform", "Service", or "MedicalSpace").

By creating an account, accessing, or using MedicalSpace, you acknowledge that you have had the opportunity to review this Privacy Policy.

1. Scope

This Privacy Policy applies to information processed through:

• the MedicalSpace mobile application;
• MedicalSpace websites and web services;
• MedicalSpace APIs and backend services;
• communications and support services;
• subscription and billing services;
• AI-assisted features;
• voice, transcription, translation, messaging, and communication features; and
• other services operated by MANA in connection with MedicalSpace.

This Privacy Policy does not necessarily apply to third-party services that have their own privacy policies.

2. Important Healthcare Data Notice

MedicalSpace may be used by healthcare professionals to store and process information relating to their patients, including medical records and other health-related information.

The healthcare professional, clinic, organization, or other MedicalSpace account owner who enters or controls patient information is primarily responsible for determining the lawful basis for collecting, using, disclosing, and otherwise processing that patient information.

MANA provides the technology infrastructure used to store and process such information on behalf of the applicable MedicalSpace customer.

Depending on the applicable law and the specific processing activity, MANA may act as a service provider, processor, data processor, controller, or another legally recognized role.

Nothing in this Privacy Policy is intended to determine the legal classification of MANA or any MedicalSpace customer under a particular jurisdiction where the law requires a different classification.

3. Information We Collect

We may collect or receive the following categories of information.

3.1 Account Information

When a user creates or manages an account, we may collect:

• full name;
• email address;
• telephone number;
• professional information;
• professional specialty;
• professional qualifications;
• professional license or registration information where provided;
• country and city;
• profile photograph;
• camera-captured images;
• clinic or organization information;
• account credentials and authentication information;
• language preferences;
• account role;
• subscription information; and
• information necessary to administer the account.

3.2 Professional Information

Healthcare professionals may voluntarily provide information such as:

• specialty;
• years of experience;
• professional biography;
• clinic information;
• professional profile information;
• professional services;
• professional contact information;
• profile images and logos; and
• information displayed to other authorized MedicalSpace users.

Users are responsible for ensuring that professional information they publish is accurate and lawful.

3.3 Patient Information

MedicalSpace may allow healthcare professionals to create and manage patient records.

Such information may include:

• patient name;
• age or date of birth;
• telephone number;
• demographic information;
• medical history;
• diagnoses;
• symptoms;
• complaints;
• vital signs;
• medications;
• prescriptions;
• treatment plans;
• clinical notes;
• visits;
• medical documents;
• laboratory results;
• radiology and imaging information;
• DICOM files;
• photographs;
• voice recordings;
• transcriptions;
• follow-up information; and
• other health-related information entered by an authorized healthcare professional.

MANA does not independently determine the medical purposes for which a healthcare professional collects patient information.

The healthcare professional or organization using MedicalSpace is responsible for ensuring that it has the necessary legal authority, consent, authorization, notice, or other lawful basis required to process patient information.

4. User-Generated Content and Medical Records

Medical records, documents, notes, prescriptions, photographs, recordings, files, messages, and other information uploaded or entered by a MedicalSpace customer remain under the control of that customer, subject to applicable law and the contractual rights necessary for MANA to operate MedicalSpace.

MANA does not claim ownership of a customer's medical records merely because those records are stored using MedicalSpace.

MANA processes customer content only as necessary to provide, operate, secure, maintain, troubleshoot, synchronize, back up, and support MedicalSpace and its requested features, and as otherwise permitted or required by applicable law.

MANA does not sell customer medical records or personal health information.

MANA does not use customer medical records or personal health information to train general-purpose artificial intelligence or machine-learning models.

Where information is submitted to an AI-enabled feature, it may be processed by MANA and applicable third-party technology providers only as necessary to provide the requested AI functionality, subject to applicable contractual, technical, and legal safeguards.

5. Communications and Messages

MedicalSpace may process information contained in:

• direct messages;
• chat communications;
• voice messages;
• translated messages;
• notifications;
• support requests; and
• other communications transmitted through the Platform.

Messages and communications may be stored to provide synchronization, delivery, security, auditing, and other Service functionality.

Users should not use MedicalSpace to transmit information that they are not legally authorized to transmit.

6. Voice, Microphone, and Audio Data

Certain MedicalSpace features may allow users to record, upload, or transmit voice or audio information.

MedicalSpace may access the device microphone when the user chooses to use features such as:

• voice messages;
• voice-based AI features;
• speech-to-text transcription;
• creation of visit notes;
• audio or video communication;
• voice summaries; or
• other features that require audio input.

Depending on the feature, audio may be processed for purposes including:

• speech-to-text transcription;
• creation of visit notes;
• AI-assisted clinical analysis;
• voice summaries;
• text-to-speech generation;
• communication;
• synchronization; and
• other functionality explicitly requested by the user.

Audio and voice information is processed only as necessary to provide the feature requested by the user and to operate, secure, maintain, and support MedicalSpace.

Users are responsible for obtaining any legally required consent before recording or processing another person's voice.

MANA does not use customer voice recordings or transcriptions to train general-purpose artificial intelligence or machine-learning models.

MANA does not guarantee that any particular voice recording, transcription, translation, or AI-generated result will be error-free.

6A. Camera and Images

MedicalSpace may access the device camera when the user chooses to capture or update a profile photograph or when a MedicalSpace feature requires image capture.

Images captured or uploaded by the user may be stored and processed as necessary to provide the requested functionality.

MedicalSpace may also allow users to upload photographs, medical images, documents, or other visual information as part of patient management, medical records, communication, or other Service features.

Camera access is not used to continuously monitor users or to collect images when the user has not initiated a feature that requires camera access.

MANA does not use customer photographs, medical images, or medical records to train general-purpose artificial intelligence or machine-learning models.

7. Artificial Intelligence

MedicalSpace may provide features that use artificial intelligence and machine-learning technologies.

AI-assisted functionality may be used to:

• summarize information;
• transcribe voice recordings;
• organize clinical information;
• analyze information supplied by the user;
• generate suggested clinical summaries;
• identify potentially relevant information;
• review prescriptions or treatment information;
• generate voice summaries;
• assist with documentation; and
• provide other AI-assisted functionality explicitly requested by the user.

When a user submits information to an AI-enabled feature, that information may be processed by MANA and by third-party technology providers used to provide the requested AI functionality.

MANA uses appropriate contractual and technical measures designed to limit such processing to the purposes necessary to provide the requested functionality and to comply with applicable law.

MANA does not use customer medical records, personal health information, voice recordings, or other confidential customer content submitted to MedicalSpace to train general-purpose artificial intelligence or machine-learning models.

MANA may change or replace an underlying AI technology provider from time to time. Where required by applicable law, MANA will provide appropriate notice regarding material changes in how personal information is processed.

AI-Generated Information

AI-generated information:

• is not medical advice;
• is not a diagnosis;
• is not a prescription;
• is not a substitute for professional medical judgment;
• is not a substitute for clinical examination;
• is not guaranteed to be accurate, complete, current, or appropriate;
• must be independently reviewed by a qualified healthcare professional before being relied upon; and
• must not be used as the sole basis for any medical decision.

Users remain responsible for reviewing AI-generated information and for all clinical decisions and actions taken based on information generated through MedicalSpace.

8. DICOM and Medical Imaging

MedicalSpace may allow users to upload, view, store, or process medical imaging files, including DICOM files.

MANA provides technical functionality and does not independently interpret, diagnose, or validate medical images.

Any image interpretation, diagnosis, or clinical decision remains the responsibility of the appropriately qualified healthcare professional.

9. Video Calls

MedicalSpace may use third-party communication infrastructure to provide video or audio calling.

Depending on the feature, call-related information may be processed by third-party service providers necessary to establish and operate the communication.

Users are responsible for ensuring that their use of video or audio communication complies with applicable professional, privacy, licensing, and consent requirements.

10. Translation Services

MedicalSpace may provide automatic translation of text or voice communications.

Automated translations may contain errors, omissions, or incorrect medical terminology.

Users remain responsible for reviewing translations before relying on them for medical, legal, administrative, or other important purposes.

11. Subscription and Payment Information

MedicalSpace may use third-party payment providers, including Stripe, to process subscriptions and payments.

MANA generally does not need to receive or store full payment card numbers.

Payment providers may independently process:

• card information;
• billing information;
• transaction information;
• payment status;
• invoices;
• subscription information; and
• fraud-prevention information.

Payment processing is subject to the applicable payment provider's terms and privacy policy.

12. Technical and Usage Information

We may automatically collect technical information such as:

• device type;
• operating system;
• application version;
• IP address;
• crash information;
• diagnostic information;
• timestamps;
• session information;
• authentication information;
• performance information;
• feature usage;
• logs;
• security events; and
• other information necessary to maintain and secure the Platform.

13. How We Use Information

We may process information to:

• create and manage accounts;
• authenticate users;
• provide MedicalSpace functionality;
• store and synchronize records;
• provide patient-management functionality;
• provide communication services;
• provide voice and transcription services;
• provide AI-assisted functionality;
• provide translation services;
• process subscriptions and payments;
• provide customer support;
• maintain the security, reliability, functionality, and performance of MedicalSpace;
• detect fraud, abuse, unauthorized access, and security threats;
• troubleshoot technical problems;
• comply with legal obligations;
• enforce our agreements;
• protect the rights, property, safety, and security of MANA, users, patients, and others;
• perform backups and disaster recovery;
• generate operational and security logs; and
• perform other purposes disclosed at or before the time information is collected.

MANA does not use customer medical records or personal health information for advertising purposes or to train general-purpose artificial intelligence or machine-learning models.

14. We Do Not Sell Medical Records

MANA does not sell patient medical records or personal health information.

MANA does not use personal health information for targeted advertising.

MANA may disclose or provide access to information to service providers and other third parties where necessary to:

• operate MedicalSpace;
• provide a feature requested by the user;
• process payments;
• provide AI, voice, transcription, translation, communication, storage, hosting, security, or other technical services;
• comply with applicable law;
• protect the Service and its users; or
• perform another lawful purpose described in this Privacy Policy.

Service providers that process information on behalf of MANA are expected to process such information only as necessary to provide the applicable services and subject to appropriate contractual, technical, and legal safeguards.

15. Service Providers and Third Parties

MANA may use third-party service providers to operate and support MedicalSpace, including providers for:

• cloud hosting;
• databases;
• authentication;
• storage;
• payment processing;
• artificial intelligence;
• speech recognition;
• text-to-speech;
• communication;
• video and audio calls;
• email;
• analytics, where used;
• security;
• monitoring;
• crash reporting;
• customer support; and
• infrastructure management.

Depending on the service, a provider may process information on behalf of MANA based on MANA's instructions, or may process certain information independently where permitted by applicable law.

Examples include:

• payment providers processing payment and billing information;
• AI and speech technology providers processing information submitted to an AI or voice feature;
• communication providers processing information necessary to deliver messages or establish calls; and
• infrastructure providers storing or transmitting information necessary to operate MedicalSpace.

MANA seeks to use appropriate contractual, technical, and organizational safeguards for third-party service providers where required by applicable law.

MANA does not authorize third-party providers to use customer medical records or personal health information to train general-purpose AI models on MANA's behalf.

16. Disclosure Required by Law

MANA may disclose information when reasonably necessary to:

• comply with applicable law;
• comply with a court order or legal process;
• respond to lawful governmental requests;
• protect the safety of an individual;
• investigate fraud or abuse;
• enforce our Terms & Conditions;
• protect MANA's legal rights;
• prevent or investigate security incidents; or
• protect the rights, property, or safety of users, patients, MANA, or others.

We may disclose only information reasonably necessary for the applicable purpose where required by law.

17. Corporate Transactions

If MANA is involved in a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar transaction, information processed through MedicalSpace may be transferred as part of that transaction, subject to applicable law.

18. International Data Transfers

MedicalSpace may be operated using infrastructure located in countries other than the country where the user or patient resides.

Accordingly, information may be transferred across borders.

Where applicable law requires specific safeguards for international transfers of personal information, MANA intends to implement appropriate contractual, technical, organizational, or other legally required safeguards.

Healthcare professionals are responsible for determining whether their use of MedicalSpace and any cross-border processing of patient data satisfies the laws and professional requirements applicable to their practice.

19. Data Security

MANA uses reasonable technical, administrative, and organizational measures designed to protect information against unauthorized access, loss, misuse, alteration, disclosure, or destruction.

Security measures may include, depending on the applicable system:

• authentication controls;
• access controls;
• authorization mechanisms;
• encryption or encrypted transport;
• logging;
• monitoring;
• backups;
• infrastructure security;
• least-privilege access;
• security updates; and
• incident response procedures.

However, no electronic system, Internet transmission, storage system, or security mechanism can be guaranteed to be completely secure.

MANA therefore cannot guarantee absolute security.

20. User Security Responsibilities

Users are responsible for:

• protecting passwords;
• protecting authentication credentials;
• maintaining the security of their devices;
• using appropriate access controls;
• not sharing accounts improperly;
• assigning appropriate permissions to employees and members;
• promptly disabling access for former employees or members;
• reviewing account activity;
• maintaining appropriate patient consent and authorization; and
• reporting suspected unauthorized access.

An account owner is responsible for actions performed by authorized members of that account to the extent permitted by law.

21. Patient Data Access

MANA seeks to provide access controls designed to restrict patient information to authorized users.

However, MANA cannot control information that a healthcare professional intentionally or unintentionally discloses outside the Platform.

MedicalSpace customers are responsible for configuring user roles and permissions appropriately.

22. Data Retention and Deletion

MANA retains information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

When an individual user requests deletion of their MedicalSpace account, MANA will delete the personal information associated with that user account, subject to applicable legal, regulatory, security, fraud-prevention, accounting, dispute-resolution, or other lawful retention requirements.

Where MedicalSpace is used by a clinic, organization, or other account owner to manage patient records, patient records may be subject to separate medical-record retention requirements. Deletion of an individual user's MedicalSpace account does not automatically require deletion of patient records that are lawfully maintained by the applicable healthcare provider or organization.

Where applicable, MANA may retain limited information necessary to comply with legal obligations, protect the security of MedicalSpace, prevent fraud or abuse, resolve disputes, or enforce legal rights.

Information retained for these purposes will be limited to what is reasonably necessary for the applicable purpose and will be deleted or anonymized when the applicable retention period ends.

Information deleted from active systems may remain temporarily in encrypted backups until those backups are overwritten or securely deleted in accordance with MANA's backup and disaster-recovery procedures.

23. Account Termination and Patient Data

Users may request deletion of their MedicalSpace account through the account and data deletion process made available by MANA.

When an account deletion request is received, MANA will process the request within a reasonably prompt period and will delete the personal information associated with the applicable user account, subject to the retention exceptions described in Section 22.

Where patient records are maintained by a healthcare professional, clinic, or organization, those records may be subject to legal, regulatory, medical-record retention, or contractual requirements that prevent immediate deletion.

The healthcare professional, clinic, or organization responsible for the patient records remains responsible for determining the applicable retention requirements for those records.

MANA does not guarantee indefinite availability of information after account deletion or termination.

Users are responsible for exporting or otherwise obtaining records they are legally required to retain before requesting account deletion or terminating their account.

23A. Account and Data Deletion Requests

MedicalSpace provides users with a method to request deletion of their account and associated personal information.

Users may request account and data deletion through the MedicalSpace account deletion web page:

Users who cannot access the MedicalSpace application may use the web-based deletion request process without needing to access the application.

Deletion requests may also be submitted directly by contacting:

The deletion process may require reasonable verification of account ownership before a request is completed.

The account deletion process is intended to delete the personal information associated with the user's MedicalSpace account, subject to information that MANA is legally required or permitted to retain as described in Section 22.

Where applicable, MANA may retain limited information necessary for legal compliance, medical-record retention requirements, fraud prevention, security, dispute resolution, accounting, or enforcement of legal rights.

Patient medical records maintained on behalf of a healthcare provider or organization may be subject to separate legal or regulatory retention requirements. Such records will be handled in accordance with the applicable healthcare provider's instructions and applicable law.

If a user requests deletion of information that cannot legally be deleted immediately, MANA will explain the applicable limitation where required by law.

MANA will process valid deletion requests within a reasonably prompt period and in accordance with applicable legal requirements.

24. Privacy Rights

Depending on the user's location and applicable law, individuals may have rights relating to their personal information, including rights to:

• access;
• correction;
• deletion;
• restriction;
• objection;
• portability;
• withdrawal of consent where applicable;
• information regarding processing; and
• other rights granted by applicable law.

Certain rights may be subject to legal exceptions.

Requests relating to a patient's medical record should generally be directed first to the healthcare professional or organization responsible for that medical record.

25. Colorado Privacy Rights

Where applicable, MANA will comply with the Colorado Privacy Act and other applicable Colorado privacy requirements.

Colorado law provides protections concerning certain personal data and sensitive data, including health-related information, subject to applicable legal requirements and exceptions.

Nothing in this Privacy Policy limits rights that cannot legally be waived.

26. Privacy Rights in Other Jurisdictions

MedicalSpace may be used by professionals and organizations located in different countries.

Where mandatory privacy legislation applies to MANA's processing activities, MANA intends to comply with the applicable requirements to the extent legally required.

Because privacy and health-data laws differ substantially between jurisdictions, the rights and obligations applicable to a particular user or patient may differ.

27. Healthcare Provider Responsibilities

The healthcare professional or organization using MedicalSpace is responsible for:

• determining the lawful basis for processing patient data;
• obtaining required consent or authorization;
• providing required privacy notices to patients;
• maintaining professional confidentiality;
• complying with medical-record retention requirements;
• complying with applicable health-data laws;
• configuring permissions correctly;
• limiting access to authorized personnel;
• reviewing AI-generated information;
• ensuring clinical accuracy;
• ensuring lawful cross-border processing;
• responding to patient requests where legally required;
• complying with professional licensing requirements.

MANA is a technology provider and does not assume the healthcare provider's professional, regulatory, fiduciary, or clinical obligations.

28. Children

MedicalSpace is intended primarily for professional and business use.

The Service is not intended to be used by children to create independent user accounts.

Healthcare professionals may nevertheless have patients who are minors. In such cases, the healthcare professional or organization is responsible for complying with all applicable laws concerning minors' medical information and obtaining any legally required parental or guardian authorization.

29. Changes to This Privacy Policy

MANA may update this Privacy Policy from time to time.

When changes are material, MANA may provide notice through the Platform, email, or another reasonable method.

The updated Privacy Policy will become effective on the date stated at the beginning of the updated policy.

30. Contact Us

For privacy-related questions, privacy requests, or account and data deletion requests, contact:

MANA LLC
Colorado, USA
Email: info@mana-co.com

Account deletion requests may also be submitted through the MedicalSpace account deletion page.

For requests concerning a patient's medical records, MANA may require the requester to contact the healthcare provider or organization responsible for the record.

31. No Waiver of Mandatory Rights

Nothing in this Privacy Policy is intended to remove, limit, or waive any right or protection that cannot legally be removed, limited, or waived under applicable law.

If any provision of this Privacy Policy conflicts with mandatory applicable law, the mandatory law will control to the extent of the conflict.

32. Privacy Policy Acknowledgment

By accessing or using MedicalSpace, users acknowledge that they have had the opportunity to review this Privacy Policy and understand how information may be processed as described herein.

Where applicable law requires consent or another legal basis for processing personal information, MANA will process such information on the applicable lawful basis.