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EMRAKON is electronic health record and practice software for hospitals and clinics. This policy explains what personal information we handle and why, who we share it with, how we protect it, and the rights you have.
Are you a patient? Your hospital or clinic controls your medical record. Contact them to see, correct or delete it. We'll help them respond.
1Who we are
EMRAKON is operated by [COMPANY LEGAL NAME], [REGISTERED ADDRESS] ("EMRAKON", "we", "us").
This policy covers:
- our website, emrakon.com
- the EMRAKON web app (app.emrakon.com) and its API (api.emrakon.com)
- the EMRAKON app for iPhone (currently in testing)
It doesn't cover how a hospital or clinic handles your information. Their own privacy notice explains that. In the United States, this is their Notice of Privacy Practices.
2Our two roles
For patient records, we act for the hospital or clinic. Healthcare providers enter and manage patient information in EMRAKON and decide how it is used. In privacy law they are the "controller", the "custodian" in some Canadian provinces, or the "covered entity" under US law. We process patient information only to provide our services to them, under our agreement and their instructions.
For our own users and contacts, we decide. We are the controller for:
- account information of the people who use EMRAKON (doctors, nurses, staff and administrators)
- security and activity records about how accounts are used
- messages you send us, such as demo requests
Our staff's access
A small number of authorized EMRAKON administrators can access every hospital's data, including patient records, and can export it. They use this access only to run, support and secure the service, or on the provider's instructions. [CONFIRM: who at EMRAKON holds Super Admin access, and whether EMRAKON ever uses identified or de-identified patient data for its own purposes, such as AI training or analytics. If not, say so here.]
3Information we handle
Patient information (for healthcare providers)
The provider's staff enter this information, or EMRAKON creates it while they use the service:
| Type | Examples |
|---|---|
| Identity and contact | Name, date of birth, sex and gender, race and ethnicity if recorded, address, phone, email, preferred language, emergency contacts |
| Insurance and billing | Insurer and member details, charges, invoices and payments |
| Clinical | Visits, triage, vitals, diagnoses, allergies, medications, medical history, lab results, procedures, tasks, alerts, clinical notes and their versions, transcripts, and documents imported into the chart |
| Appointments | Including telehealth visits |
Recordings and dictation
When a clinician records a visit or dictates, the audio goes from their device through our servers to our speech-to-text provider, which turns it into a transcript. Our servers don't save the audio file. The transcript and the drafted note are stored only when the clinician saves them. Section 5 explains what our speech-to-text provider may keep.
Account information (our users)
- name, work email, phone, role, hospital and department, job title and profile photo
- for doctors: professional details such as specialty, licence and registration numbers, qualifications, languages and availability
- your password, stored only as a one-way hash
- messages between colleagues in EMRAKON. These can include patient information and are protected like patient records.
- if a doctor connects Google Calendar for video visits: a Google sign-in token that lets EMRAKON add events to their calendar, stored encrypted
Security and activity records
When someone signs in or creates, changes or deletes a record, we log who it was, their role and hospital, the time, the action, their IP address and their device and browser type. We also log each data export.
Website and email enquiries
- When you email us or use the demo form, we receive what you send: usually your name, work email, organization, role and message. The form opens your own email app. Nothing is sent through the website itself.
- Our website host, Vercel, keeps standard server logs such as IP address, browser type and the pages requested.
- Our pages load the Inter typeface from Google Fonts, so your browser connects to Google, which receives your IP address.
App testing
If you test the iPhone app through Apple's TestFlight, Apple shares your tester details, crash reports and any feedback you send with us, under Apple's terms.
4How we use information
Patient information is used only to provide EMRAKON to the healthcare provider. That means storing and showing records, drafting notes and documents with AI, finding billable items, creating tasks and alerts, and sending appointment and account emails on the provider's behalf. It also covers keeping the service secure, giving support the provider asks for, and meeting legal requirements. [CONFIRM: de-identified data, see section 2]
Account and contact information is used to:
- create and manage accounts and sign-ins
- send service emails, such as account set-up and appointment confirmations
- keep EMRAKON secure, investigate misuse and keep audit records
- support users and improve the service
- reply to enquiries and arrange demos
- meet legal obligations
We send marketing emails only if you agree to them, and every one lets you unsubscribe.
Legal grounds. Where a law requires a legal ground, such as in Barbados, we rely on one of these:
- performing our contract with you or your organization
- our legitimate interests in running and securing EMRAKON and answering enquiries
- legal obligations
- your consent, where we ask for it
For patient information, the healthcare provider determines the legal ground.
5AI features
- Step 1Voice or textRecorded, dictated or typed
- Step 2Speech to textDeepgram
- Step 3AI draftGoogle Cloud Vertex AI
- Step 4Clinician reviewsEdits and approves
- Step 5SavedLabs, procedures and tasks added to the chart
EMRAKON uses AI to:
- draft SOAP notes and fill forms from dictation
- summarize a chart and answer questions about a patient's record
- draft handoff notes and discharge summaries
- find billable items in notes and imported documents
- read hospital price lists
To do this, the relevant text, documents or audio are sent to the providers named above for processing.
What a person reviews. AI-drafted notes and documents are reviewed and edited by a clinician before saving. From a saved note or an imported document, EMRAKON automatically adds lab, procedure and task entries to the chart, which staff can correct. AI-found charges stay pending until someone approves them.
Speech to text. Under Deepgram's standard terms, Deepgram may keep audio and transcripts and use them to improve its own speech models. [CONFIRM: before publishing, either switch on Deepgram's opt-out in the API (mip_opt_out=true) or get written confirmation that EMRAKON's Deepgram contract excludes this. Then replace this sentence with: "Deepgram doesn't use EMRAKON audio or transcripts to train its models."]
AI drafting. We use Google Cloud's business AI service, Vertex AI, not a consumer AI app. [CONFIRM: that Google Cloud's terms for the model EMRAKON uses, a pre-release "preview" Gemini model, stop Google from using EMRAKON data for its own purposes, such as training its models; or switch to a generally available model]
7Where information is stored
EMRAKON's app data is stored on Amazon Web Services servers in the US East (Ohio) region of the United States. Some of the service providers above may process data elsewhere in the United States or in other countries where they operate.
So information from Barbados, Canada and other countries is transferred to and processed in the United States. While it is there, it is subject to US law. US courts, law enforcement and national-security authorities may be able to obtain access to it under that law.
We protect transferred information with the security measures in section 8 and with contract terms with our providers. [CONFIRM: safeguards used for transfers out of Barbados and Canada]
8How we protect information
- Encryption in transit. Connections to EMRAKON use HTTPS. The iPhone app connects only over HTTPS.
- Encryption at rest. Server disks are encrypted. Our application also encrypts many sensitive fields again before storing them, such as most patient details, clinical notes and records, messages and imported documents.
- Passwords. Stored only as one-way hashes.
- Role-based access. Each user has a role, assigned by their hospital, and sees only what that role allows.
- Hospital separation. Hospital users reach only their own hospital's records. EMRAKON's own administrators can reach every hospital (see section 2).
- Audit logs. Of sign-ins, changes and data exports.
- Sessions. Sign-in tokens are short-lived. Each hospital sets an inactivity sign-out (15 minutes by default), which a hospital admin can turn off. Changing your password ends your sign-ins on other devices within about 30 minutes.
- iPhone app. Face ID, Touch ID or passcode lock. Sign-in details are kept only in the iPhone's Keychain on that device, and patient screens are hidden in the app switcher. Face ID and Touch ID are handled by your iPhone, so EMRAKON never receives face or fingerprint data.
- Servers. Our database is not reachable from the internet, and backups are encrypted.
No system is completely secure, and we can't guarantee security. If a breach affects information we hold for a healthcare provider, we'll tell that provider without undue delay and help them meet their obligations. We'll notify regulators and affected people where the law requires us to.
9How long we keep information
| Information | How long |
|---|---|
| Patient information | For as long as the healthcare provider uses EMRAKON, or as their instructions and our agreement say. When a contract ends, we return or delete it as agreed. [CONFIRM: what happens to a provider's data at contract end, and how quickly] Providers set their own medical-record retention periods, and the law often requires these to run for many years. |
| Account information | While the account is active, and for [CONFIRM: period] after it closes, unless the law requires longer. |
| Security and audit records | [CONFIRM: period] |
| Website and email enquiries | As long as needed to handle the enquiry and any follow-up. [CONFIRM: period] |
| Deleted clinical entries | Most clinical entries that users delete, such as diagnoses, lab results, procedures and notes, are kept, marked as deleted, as part of the medical record's history, unless the provider instructs otherwise. |
| Audio | Our servers don't keep recordings after transcription. Deepgram may keep them under its terms (see section 5). |
| Backups | Routine backups roll off automatically. Data that is permanently removed can stay in backups for about three weeks. Backups taken before system changes are deleted once they are no longer needed. |
10Your rights
Depending on where you live and which law applies, you can:
- AccessGet a copy of your information
- CorrectFix information that is wrong or incomplete
- DeleteHave information erased
- Object or restrictObject to certain uses, or have use paused
- PortGet it in a portable format, or sent to another organization
- Withdraw consentWhere we rely on your consent
- ComplainTo us, and to your privacy regulator
If you are a patient, your hospital or clinic controls your medical record, so please send requests to them. If you contact us instead, we'll pass your request to your provider and help them respond. We can't change a medical record without the provider's instructions.
If you use EMRAKON or have contacted us, email info@emrakon.com or our privacy officer (section 17).
- We may need to confirm your identity before acting on a request.
- We'll reply within [CONFIRM: response time], or sooner if the law requires.
- Some rights have limits. For example, we may need to keep records that the law requires us to keep.
- We won't treat you differently for using your rights.
11Barbados
- Data Protection Act, 2019
- Data Protection Commissioner
The Data Protection Act, 2019 protects personal data processed in Barbados. Health information is "sensitive personal data" under the Act and gets extra protection.
Under the Act, you have the right to:
- be told how your data is used
- access your personal data
- have inaccurate data corrected
- have data erased
- restrict processing
- data portability
- object to processing, including for direct marketing
- not be subject to decisions based solely on automated processing that significantly affect you
- withdraw consent
Patients: your healthcare provider is the data controller for your medical record and answers your requests, with our help.
Complaints: please contact us first. You also have the right to complain to the Data Protection Commissioner of Barbados. [CONFIRM: Commissioner contact details]
Your data is stored in the United States (see section 7).
12Canada
- PIPEDA
- Quebec Law 25
- BC and Alberta PIPA
- Provincial health laws (e.g. PHIPA, HIA)
PIPEDA. The federal Personal Information Protection and Electronic Documents Act applies to private-sector organizations that handle personal information in commercial activities. It also applies to personal information that crosses provincial or national borders.
Provincial laws can apply instead of PIPEDA, or as well as it:
- Quebec: the Act respecting the protection of personal information in the private sector, as amended by Law 25. Health bodies may also fall under Quebec's Act respecting health and social services information.
- British Columbia and Alberta: each has a Personal Information Protection Act (PIPA) for private organizations.
- Health information: provincial health-information laws, such as Ontario's Personal Health Information Protection Act (PHIPA) and Alberta's Health Information Act, govern how custodians handle personal health information. Custodians include your hospital, clinic or doctor. These laws also set rules for the service providers that custodians use.
Your rights in Canada:
- access the personal information an organization holds about you, and learn how it has been used and who it has been disclosed to
- challenge its accuracy and have it corrected
- withdraw consent, subject to legal or contractual limits
- challenge an organization's compliance with the law
- in Quebec, also: data portability, and having information de-indexed in some cases
Patients: your health information custodian (hospital, clinic or doctor) answers requests about your record. We act on their behalf.
Complaints: please contact us or your provider first. You can also complain to:
| Where | Regulator |
|---|---|
| Canada (federal) | Office of the Privacy Commissioner of Canada · priv.gc.ca |
| Quebec | Commission d'accès à l'information · cai.gouv.qc.ca |
| British Columbia | Office of the Information and Privacy Commissioner · oipc.bc.ca |
| Alberta | Office of the Information and Privacy Commissioner · oipc.ab.ca |
| Ontario (health information) | Information and Privacy Commissioner · ipc.on.ca |
| Other provinces | Your provincial privacy commissioner |
Stored outside Canada: information in EMRAKON is stored in the United States (AWS, Ohio) and may be processed by our providers there or elsewhere. While outside Canada, it may be accessible to courts, law enforcement and national-security authorities under the laws of those countries. Quebec residents: your personal information may be communicated outside Quebec for the purposes in this policy.
Accountability: our privacy officer is responsible for our compliance. In Quebec, this is the person in charge of the protection of personal information: [PRIVACY OFFICER NAME OR TITLE], [PRIVACY OFFICER EMAIL].
13United States
- HIPAA
- California CCPA / CPRA
- Other state privacy laws
- Washington My Health My Data Act
Health information from US providers (HIPAA)
Some US healthcare providers are "covered entities" under HIPAA. When EMRAKON serves them, patient information in EMRAKON is protected health information. We handle it as the provider's service provider, and only to provide our services to them. [CONFIRM: de-identified data, see section 2] [CONFIRM: whether EMRAKON signs Business Associate Agreements with US covered entities]
Your HIPAA rights are exercised through your healthcare provider. You can:
- see and get a copy of your record
- request an amendment
- get an accounting of certain disclosures
- request restrictions on certain uses and disclosures
- request confidential communications, for example at a different address or phone number
Your provider's Notice of Privacy Practices explains these rights. You can also complain to your provider, or to the US Department of Health and Human Services, Office for Civil Rights (hhs.gov/ocr).
State privacy laws (information not covered by HIPAA)
Some state laws cover personal information that HIPAA doesn't, such as website enquiries and EMRAKON user account data. Which rights you have depends on your state and on whether a law applies to us.
California (CCPA, as amended by the CPRA). California residents, including people acting in a work role, have the right to:
- know what personal information we collect, use and disclose, and get a copy
- delete it
- correct it
- opt out of its sale or sharing
- limit the use of sensitive personal information
- not be discriminated or retaliated against for using these rights
In practice:
- Sale and sharing: we don't sell or share personal information, including that of people under 16, so there is nothing to opt out of.
- Sensitive information: we use sensitive personal information, such as account sign-in details, only to provide and secure the service.
- What we collect: in the last 12 months, the categories of personal information we collected as a business were identifiers (such as name, email and IP address), professional information (such as role, hospital and specialty), internet activity (security and server logs), sensitive personal information (account log-in details) and visual information (profile photos). Sections 3, 4 and 6 describe the sources, purposes and recipients, and section 9 covers retention.
Other states give similar rights to access, correct, delete and port data, and to opt out of sale, targeted advertising and profiling. These include Colorado, Connecticut, Oregon, Texas and Virginia. If we decline your request, you can appeal by replying to our decision. If your appeal is denied, you can contact your state attorney general.
You can use an authorized agent to make a request. We may ask for proof that they are authorized.
Consumer health data (Washington and similar laws)
Washington's My Health My Data Act and similar state laws protect consumer health data that HIPAA doesn't cover. We don't collect consumer health data through our website. Health information in EMRAKON is entered by healthcare providers and handled for them as described above. We don't sell consumer health data.
If one of these laws applies to information we hold about you, contact us to:
- access it, including a list of who we have shared it with
- delete it
- withdraw your consent
14Children
EMRAKON is a professional tool for healthcare organizations. It isn't directed at children, and we don't knowingly collect personal information directly from children (in the US, under 13).
Healthcare providers may enter records about patients who are minors. Those records are protected like all patient records and controlled by the provider. Parents and guardians should contact the provider about a child's record.
16Changes to this policy
We'll post any update on this page with a new effective date. If a change is significant, we'll tell our customers and account holders before it takes effect.
17Contact us
Company
[COMPANY LEGAL NAME]
[REGISTERED ADDRESS]
Privacy officer
[PRIVACY OFFICER NAME OR TITLE]
[PRIVACY OFFICER EMAIL]
[CONFIRM: whether to name a separate contact or representative for Canada and the United States]
Patients: please contact your hospital or clinic first. They control your medical record.