Privacy Notice

1. Introduction

This Privacy Notice describes how BlockHaven Inc. (“BlockHaven,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information in connection with our websites, the HealthMemory applications, the Haven assistant, the Genesis service, and related features and services (collectively, the “Services”). It also describes the choices and rights available to you.

The Services are offered only to individuals who live in the United States, including its territories. By using the Services, you acknowledge that your information will be handled as described in this Notice.

BlockHaven offers the Services directly to individuals. We are not a health care provider, health plan, or health care clearinghouse, and we do not provide the Services on behalf of one. Accordingly, the Health Insurance Portability and Accountability Act does not apply to the Services as we provide them directly to you under this Notice. Our handling of your information is governed by this Notice and by applicable federal and state law, including consumer health data laws described in the Appendices.

2. Our Approach

The Services are designed so that you control your health information.

• Your Vault. The health information you keep in HealthMemory is stored in an encrypted vault (your “Vault”). Your Vault is encrypted on your device with a key generated on your device. To support account recovery, we store copies of that key that are themselves encrypted with keys we do not have, so we cannot open them or recreate your key on our own. We cannot read the contents of your Vault, including any encrypted copy we store for you. Information you choose to send through a feature that processes it outside your Vault, such as Genesis or the artificial intelligence features described in Section 5, is handled as this Notice describes for that feature.
• Pseudonymous accounts. You do not need to give us your name, email address, telephone number, or date of birth to create a HealthMemory account.
• On-device processing. Much of the processing in the Services takes place on your device. Certain features use third-party artificial intelligence services, as described in Section 5.
• No sale and no advertising. We do not sell personal information, use it for targeted advertising, or use it to train artificial intelligence models.

3. Information We Collect

Information you provide. This includes information you enter or import into the Services, such as health records, documents, measurements, notes, and your conversations with Haven; information you provide when you make a purchase, place a deposit, or redeem a code, such as your email address, the code, and the device you tell us you plan to use; information you provide when you join our mailing list or contact us; and information you provide to set up, recover, or delete your account.

Information from your device, with your permission. If you grant permission, the Services may access information from your device, such as health and fitness data from Apple Health, your calendar, your location, motion data, and your camera and microphone. Each permission is used only for the feature that requests it. You can change these permissions at any time in your device settings.

Information from third parties. We receive payment confirmations and refund and dispute outcomes from our payment processor. When you choose to connect a third-party source of health records, we receive the records that source provides at your direction.

Information collected automatically. When your device or browser interacts with the Services, our systems and service providers record technical information such as network address, date and time, the request made, and device or browser type. We use the country associated with your network address to confirm that a new account is being created in the United States. We maintain records of account security events.

Website analytics. On the pages of our website that describe BlockHaven and invite you to join, including the home page, the membership page, and this Notice, we use Google Analytics to understand how visitors find and use the site. Google Analytics sets cookies in your browser and records the pages you view, the page or campaign link that brought you, the buttons and links you select, whether you started or sent a form or started a purchase, your device and browser type, and your approximate location, which Google derives from your network address; Google states that it does not store the address. These records describe your choices only by category, such as the membership tier you selected, and never include what you type. Google Analytics does not run on the Genesis pages, on the pages where you complete a purchase, claim a code, or manage a purchase, on our Terms of Service, refund policy, or Consumer Health Data Privacy Policy, or in the Apps. We have turned off Google signals and ad personalization, so your visits are not linked to a Google account or used for advertising, and we do not use advertising cookies. Google describes how it uses information from sites that use its services at policies.google.com/technologies/partner-sites. If you visit from the European Economic Area (the European Union, Iceland, Liechtenstein and Norway), Switzerland, the United Kingdom, the Channel Islands, the Isle of Man or Gibraltar, or from a location we cannot determine, Google Analytics runs only after you agree. We use the country associated with your network address to decide whether to ask, and a cookie remembers your choice for about six months.

Where the Services offer a face scan, the video of your face is analyzed on your device to estimate measurements such as heart rate, is not sent to us, and is not used to identify you. Only the resulting measurements are kept, in your HealthMemory. We do not create a faceprint or any other template that could identify you, and we do not collect biometric identifiers.

4. How We Use Information

We use personal information to:

• provide, operate, and maintain the Services you request;
• authenticate you and protect the security and integrity of your account and the Services;
• process purchases, refunds, and related transactions;
• communicate with you, including in response to your requests and, with your consent, to send updates;
• diagnose problems, prevent fraud and abuse, and improve the reliability of the Services;
• understand how visitors find and use our website, as described in Section 3; and
• comply with legal obligations and enforce our terms.

We do not use personal information for advertising, sell it, or use it to make decisions that produce legal or similarly significant effects on you. The Services provide information and organization tools; they do not provide medical advice, diagnosis, or treatment.

5. Artificial Intelligence Features

Haven and related features process your information on your device wherever possible. Haven chat, Genesis, and visit preparation rely on artificial intelligence services provided by third parties. When you use one of those features, the provider receives only a minimized excerpt of your health information, limited to what the request requires, after removal of the direct identifiers our software detects, such as your name, dates, and identification numbers. Identifier removal is automated and cannot be guaranteed to remove every identifier.

Two separate consents apply. When you finish setting up HealthMemory, you give us permission to keep the information you add in HealthMemory. HealthMemory keeps new information you add only while that permission is in effect, and asks for it again on a device where it is not. When you create your account, we ask for your consent to share health information with artificial intelligence service providers for these features. That consent is given by ticking a box that is not ticked for you, separate from your agreement to our Terms of Service and your acknowledgment of this Notice, and an account cannot be created without it.

You may withdraw your consent to sharing with artificial intelligence service providers at any time in the app’s settings, under Privacy. Withdrawal stops any further sharing with these providers and turns off Haven chat, Genesis, and visit preparation until you consent again. Your account and the information in it remain, and nothing is deleted.

6. How We Disclose Information

We do not disclose the contents of your Vault to anyone unless you direct us to. We disclose personal information only as follows:

• Service providers. We use service providers for cloud hosting, website delivery, website analytics, payment processing, email communications, application distribution, software components that run within the Apps, and the artificial intelligence features described in Section 5. We give each provider only the information it needs to perform its service for us.
• At your direction. When you share information through the Services, we transmit it as you direct. Shared information is encrypted on your device before it is sent, so that only someone who has the link or code you share can open it, and we cannot read it. A file you save or copy out of the Services yourself is not encrypted by us and is under your control.
• Legal requirements and protection. We may disclose information as required by law or legal process, or, as permitted by law, to protect the rights, property, or safety of any person. Because we cannot open your Vault, we cannot disclose its contents.
• Business transfers. In connection with a merger, acquisition, financing, or sale of assets, information may be transferred subject to this Notice.

Payments for the Services are handled by a payment processor, which also provides the page on which you manage or cancel a subscription. We designed our purchase systems so that our payment records are not linked to the contents of your health record. When we send you a code by email, such as a membership or early-access code, our email provider holds that code with your email address only for as long as needed to deliver and support it.

7. Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Notice, including to provide the Services, comply with legal, tax, and accounting obligations, resolve disputes, and enforce our agreements, and then delete it. Health records that Genesis processes are deleted from our systems within one day after we receive them, whether the run finishes, fails, or is abandoned, and they are not kept in backups. A finished Genesis record waiting for you to collect it is stored encrypted, in a form we cannot open, for up to 30 days. Copies of other information in backups are deleted when those backups expire, within six months after the information is deleted. Website analytics records are retained for up to 14 months, and the cookies Google Analytics sets expire after two years unless you delete them sooner.

When you delete your account, we delete your account information and encrypted data after a waiting period of 72 hours, during which you can cancel. We keep a record that the deletion was carried out for 24 months. It does not contain your health information and serves as proof of the deletion. We also take steps so that restoring a backup cannot undo a deletion.

8. Your Choices and Rights

Subject to applicable law, you may:

• access the personal information we hold about you;
• correct inaccurate personal information;
• delete your personal information and your account;
• withdraw any consent you have given, which stops future processing that relies on that consent;
• opt out of the sale or sharing of personal information and of targeted advertising, although we do not engage in either; and
• appeal our decision on any request.

You can view and correct the information in your Vault directly in the Services, and you can delete your account in the app’s settings where that option is available. If that option is not available to you, you may ask us to delete your account by writing to [email protected]. To make any other request, contact us at [email protected]. We will verify your request before acting on it, respond within the time required by law, and not discriminate against you for exercising your rights. You may designate an authorized agent to make a request on your behalf. If we deny your request, you may appeal by replying to our response, and we will inform you of the outcome and of how to contact your state attorney general.

We honor Global Privacy Control signals as a request to opt out of the sale or sharing of personal information.

Website analytics. If you were asked before Google Analytics ran, you can change your choice at any time with Cookie choices at the bottom of the pages that use it; withdrawing deletes its cookies. Anyone can block or delete cookies in their browser settings or install Google’s opt-out browser add-on at tools.google.com/dlpage/gaoptout.

9. Security

We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest. No system is completely secure, and we cannot guarantee the security of information.

If a breach of security involving unsecured PHR identifiable health information in a personal health record we maintain occurs, including an unauthorized disclosure, we will notify affected individuals, the Federal Trade Commission, and, where required, the media, as the FTC Health Breach Notification Rule and applicable state law require.

10. Children

The Services are intended only for adults and are not directed to anyone under 18. We do not knowingly collect personal information from children under 13. If we learn that we have done so, we will delete it.

11. Location of Processing

The Services are operated in the United States, and we process and store personal information on our own systems, which are hosted in the United States. Our service providers may process the limited information they receive for us in other locations under their agreements with us. We may restrict access to the Services from outside the United States.

12. Changes to This Notice

We may update this Notice from time to time. We will post the updated Notice with a new effective date. If we make a material change, including any change to how we collect, use, or share consumer health data, we will notify you in advance through the Services or by other appropriate means and, where required by law, obtain your consent.

13. Contact Us

BlockHaven Inc.
16192 Coastal Highway
Lewes, Delaware 19958
[email protected]

Appendix A. Consumer Health Data Privacy Policy

Consumers in Washington, Nevada, Connecticut, and other states with consumer health data laws should read our Consumer Health Data Privacy Policy at www.blockhaven.ai/consumer-health-data, which supplements this Notice and sets out the categories of consumer health data we collect, its sources, and how to exercise your rights. In summary:

Purposes and consent. We collect and use consumer health data to provide the Services you request. When you finish setting up HealthMemory, you give us permission to keep the consumer health data you add. When you create your account, we ask for your separate consent to share consumer health data with artificial intelligence service providers for the features described in Section 5, and an account cannot be created without it. You may withdraw that consent at any time in the app’s settings. Haven chat, Genesis, and visit preparation then turn off, and your account remains. We will ask for your separate consent before we collect, use, or share consumer health data for any other purpose.

Sharing. We share consumer health data only with processors that act on our instructions, in these categories: cloud hosting, artificial intelligence services for the features described in Section 5, payment processing, and email delivery. We also share it with recipients you choose. We have no affiliates that receive consumer health data. You may request a list of the specific third parties with whom we have shared your consumer health data.

Your rights. You may confirm whether we collect, share, or sell your consumer health data; access it; obtain a list of the third parties with whom it has been shared; withdraw your consent; request deletion; and appeal our decision on any request. Submit requests to [email protected].

We do not sell consumer health data, and we do not use geofences around locations where health care services are provided.

Appendix B. Additional State Disclosures

California and other states. In the past 12 months we have collected the following categories of personal information: identifiers (such as email address, account identifiers, network address, and the identifier in a website analytics cookie); commercial information (purchase records); internet or other electronic network activity (server logs and the website analytics described in Section 3); approximate location (the country associated with your network address, and the approximate location Google Analytics estimates from it); and sensitive personal information (health information and account credentials). Precise location, where you permit it, is used only on your device and is not collected by us. We collected this information from the sources described in Section 3, used it for the purposes described in Section 4, and disclosed it only to the categories of recipients described in Section 6. We have not sold or shared personal information, and we use sensitive personal information only to provide the Services you request. Residents of states with comprehensive privacy laws may exercise the rights described in Section 8.