Legal
Privacy Policy
Clear Consent Inc. (“Clear Consent,” “we,” “us,” or “our”) operates the public Kuluq website (the “website”) and develops Kuluq, a clinical operations system for scheduling, intake, a patient portal, a phone assistant, referrals, and related healthcare workflows.
This Privacy Policy describes how we collect, use, disclose, and protect information when you visit the website, contact us, or interact with general Kuluq communications. Product-specific, portal-specific, or client-specific data practices for clinics using Kuluq are governed by separate agreements, including service agreements, Business Associate Agreements, data protection agreements, clinic policies, or product documentation.
Public Website Scope
The website is intended for general informational and business inquiry purposes only. It is not a medical service, electronic health record, patient portal, clinical decision-support tool, care coordination tool, prescribing tool, support portal, or emergency communication channel. The interactive demo on the homepage runs entirely in your browser and sends nothing to us.
Do not submit Protected Health Information (“PHI”), patient records, symptoms, clinical questions, prescriptions, lab results, urgent medical requests, or any confidential information through the website or general email. If you are a patient with questions about your care, records, portal access, authorizations, or privacy rights, contact your healthcare provider directly.
1. Information We Collect
Information You Provide Directly
When you contact us, we may collect information you voluntarily provide, including your name, job title, email address, phone number, organization or clinic name, and the contents of messages you send to us.
Health-Related Information
Kuluq is technology that may process health-related information on behalf of healthcare provider clients across workflows such as scheduling, intake, the patient portal, the phone assistant, referrals, lab orders, and medications.
When health-related information is provided by or processed on behalf of a healthcare provider client, it may be subject to the Health Insurance Portability and Accountability Act (“HIPAA”). In those cases, Clear Consent processes such information as directed by the healthcare provider client and in accordance with applicable agreements and law.
Automatically Collected Information
When you visit the website, we may automatically collect certain technical information, such as your IP address, browser type, operating system, referring URLs, pages viewed, device/browser information, and general usage information.
The website currently sets no cookies and loads no third-party scripts, trackers, or analytics. If that changes, we will update this policy first.
See our Cookies Policy for more information.
2. How We Use Information
We may use the information we collect to operate, maintain, and improve the website and, where applicable, the Kuluq platform; respond to inquiries; communicate with prospective and current clinics; provide support; support healthcare workflows for our clinic clients; maintain security; comply with legal and contractual obligations; and protect the rights, safety, and integrity of Clear Consent, our clients, users, and services.
3. Patient Consent and Healthcare Provider Direction
Patient consent, authorization, and privacy rights are managed by the healthcare provider responsible for the patient relationship, in accordance with applicable law and the provider’s own policies. If you are a patient whose information is processed through Kuluq, contact your healthcare provider to exercise privacy rights, request access or correction, or revoke authorizations where applicable.
Clear Consent does not use PHI for purposes outside the services we provide to the applicable healthcare provider client except as permitted by applicable law, written agreements, and appropriate authorization where required.
4. Use of Adaptive Technology
Kuluq may use adaptive technology to support clinical workflow experiences, such as its phone assistant and assistive documentation tools. These features are intended to support clinic staff and do not replace clinician judgment, diagnosis, treatment, or emergency care. A licensed clinician reviews assistive output before it becomes part of the record.
We do not use PHI to train, fine-tune, or develop general-purpose artificial intelligence or machine learning models. This prohibition is intended to be contractually enforced across development partners and subcontractors with access to PHI. If this approach changes in the future, it will only occur with appropriate authorization, contractual protections, and compliance with applicable law.
5. HIPAA and Healthcare Data
When providing Kuluq to covered entity clients, Clear Consent may operate as a Business Associate under HIPAA and the HITECH Act. In those circumstances, Clear Consent enters into Business Associate Agreements (“BAAs”) or other appropriate agreements as required by law.
Subcontractors and development partners with access to PHI are required to follow written confidentiality, privacy, and security obligations appropriate to their role.
Clear Consent does not sell PHI. Clear Consent does not use or disclose PHI for marketing purposes unless permitted by applicable law and the applicable healthcare provider relationship. Clear Consent does not aggregate, mine, or use clinical data for commercial advertising, profiling, targeting, or data brokerage purposes.
6. How We Share Information
We do not sell personal information or share personal information for cross-context behavioral advertising as those terms are defined under California law.
We may share information in limited circumstances, including with service providers and subcontractors who help operate the website or the Kuluq platform; with healthcare provider clients as necessary to deliver services; with authorized health information networks, referral partners, or interoperability partners as necessary to provide contracted services; when required by law, regulation, legal process, or enforceable governmental request; or when necessary to protect the rights, safety, or property of Clear Consent, our users, clients, or the public.
Third parties with access to PHI are required to use that information only within the scope of the services provided and applicable written agreements.
If Clear Consent later deploys advertising pixels, retargeting tools, or cross-context behavioral advertising technologies, we will update this policy and implement any required opt-out mechanisms before using those technologies in production.
7. International Data Processing
Clear Consent is headquartered in the United States. Authorized service providers or development partners may support certain systems from outside the United States, subject to written confidentiality, privacy, security, and access-control obligations. Any access to PHI is governed by applicable law, client agreements, BAAs or subcontractor BAAs where required, and Clear Consent’s security requirements.
8. Data Security
We maintain reasonable administrative, technical, and organizational safeguards designed to protect information appropriate to its sensitivity. Depending on the environment and information involved, safeguards may include encryption, access controls, multi-factor authentication, role-based permissions, audit logging, monitoring, and contractual security obligations for service providers, development partners, and subcontractors.
No website, platform, or electronic transmission is completely secure. We cannot guarantee absolute security.
In the event of a breach involving PHI, Clear Consent will notify affected healthcare provider clients in accordance with applicable agreements and HIPAA breach notification requirements.
9. Data Retention
We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, comply with legal and regulatory obligations, perform contractual obligations, resolve disputes, and protect legitimate business interests.
Health-related data processed on behalf of healthcare provider clients is retained in accordance with applicable law and the terms of our agreements with those clients.
10. Our Role in Data Processing
Clear Consent may process health-related data on behalf of healthcare provider clients through Kuluq. In those cases, the healthcare provider client is generally responsible for determining the purposes and means of processing patient data, and Clear Consent processes such data as a service provider, processor, or Business Associate, depending on the applicable legal and contractual context.
If you are a patient, please direct requests regarding your health information to the healthcare provider who collected or maintains that information.
11. Third-Party Links
Our website may contain links to third-party websites or services. We are not responsible for the privacy practices, security, or content of third parties. We encourage you to review their privacy policies.
12. Children’s Privacy
Our website is not directed to children under 13, and we do not knowingly collect personal information from children under 13 through the website. If we become aware that such information has been collected through the website, we will take reasonable steps to delete it.
Kuluq may process health information related to pediatric patients on behalf of healthcare provider clients. In those cases, information about minors is collected and managed by the healthcare provider in accordance with applicable law, including requirements for parental, guardian, or patient consent where applicable.
13. California and Other Privacy Rights
Depending on where you live and how you interact with Clear Consent, you may have rights under applicable privacy laws, including rights to request access, correction, deletion, or information about certain personal information we maintain.
California residents may have rights to know, access, correct, delete, and receive information about certain personal information we collect, use, and disclose, and may have the right to opt out of the sale or sharing of personal information if applicable. Clear Consent does not sell personal information or share personal information for cross-context behavioral advertising unless disclosed otherwise.
Some medical information, PHI, and information processed on behalf of healthcare providers may be governed by HIPAA or other healthcare privacy laws rather than general consumer privacy laws.
To submit a privacy request regarding website or business-contact information, contact us at hello@clearconsent.ai. To submit a request regarding patient health information, contact your healthcare provider.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will revise the “Last Updated” date at the top of this page. We encourage you to review this policy periodically.
15. Contact Us
If you have questions or concerns about this Privacy Policy or our data practices, please contact us:
Clear Consent Inc. · 2108 N ST #7563 · Sacramento, CA 95816, USA