Privacy Policy

1. Scope

This Privacy Policy applies to the FitsPro iPad application ("App"), the FitsPro administrative portal, and the public website at fitspro.clinic (collectively, the "Services"). The Services are designed for licensed clinical practitioners and the organizations they work for.

This policy covers (i) data we collect from the practitioner-user of the Services, and (ii) data the practitioner enters about a patient. Patient data is also governed by separate clinical agreements and a Business Associate Agreement ("BAA") between FitsPro and the practitioner's organization.

2. Roles

• The practitioner is the user. When a licensed practitioner registers, signs in, and uses the Services, the practitioner is "you" in this policy and is the FitsPro account holder.
• The patient is the data subject. Patients do not install the App or have a direct account relationship with FitsPro. The practitioner enters and manages the patient's clinical record within the practitioner's organization.
• The practitioner's organization is the HIPAA Covered Entity. FitsPro acts as a Business Associate with respect to Protected Health Information. A Business Associate Agreement between FitsPro and the practitioner's organization governs all clinical use of the Services.

3. Information we collect from the practitioner-user

• Account information — name, email address, telephone number, organization, practice address, NPI (National Provider Identifier).
• Authentication — account credentials and session tokens (managed by Amazon Cognito).
• Billing — payment method (collected and stored by Stripe), order history, invoice records.
• Service operation — app usage events, performance and crash diagnostics, IP address, device identifier, application version.

4. Information practitioners enter about patients

In the course of clinical work, practitioners enter the following categories of patient information through the Services:

• Patient demographics (name, date of birth, contact information, gender).
• Medical history fragments and chief complaints captured during clinical workflows.
• 3D foot scans and other anatomical imaging.
• Gait, posture, and range-of-motion measurements.
• Clinical notes (subjective, objective, assessment, plan), optionally including transcribed audio from a recorded encounter.
• Orthotic device specifications, fabrication records, and order history.
• Telehealth session metadata (appointment times, participants, optional session transcripts).

FitsPro processes patient data only as directed by the practitioner, for the purposes the practitioner is permitted to pursue under HIPAA and applicable state law. Patient data is not used for advertising, marketing, profiling, or sold to third parties.

5. 3D foot scans and anatomical imaging

FitsPro captures three-dimensional surface scans of the patient's foot for the purpose of designing and manufacturing a custom orthotic device prescribed by the patient's practitioner. These scans are clinical imaging — a geometric record of foot surface shape — and are used solely for:

1. designing the prescribed orthotic device,
2. manufacturing that device to clinical specification, and
3. attaching the scan to the patient's clinical record at the practitioner's organization for ongoing care.

The App generates 3D Models of the feet using the TrueDepth® camera, Structure Sensor® or LIDAR camera. This information is stored securely and is necessary to accurately manufacture a custom orthotic. All orthotics are custom-made based on the 3D information in lieu of traditional casting methods. These models may be removed at any time by opening a support ticket within the App.

3D foot scans are NOT used for biometric identification, biometric authentication, facial recognition, fingerprinting, voiceprint analysis, or any purpose unrelated to the prescribed clinical device. Scans are encrypted in transit (TLS 1.2 or higher) and at rest. Access is limited to the patient's practitioner, that practitioner's authorized clinical staff, and authorized personnel at the manufacturing facility producing the prescribed device and is not shared with any 3rd parties for any reason.

Patients seeking access to, correction of, or deletion of their 3D scans or other clinical records should contact their practitioner. FitsPro will support such requests through the practitioner under the Business Associate Agreement governing clinical use.

6. How we use information

We use practitioner-user data to:

• Authenticate the practitioner and maintain account security.
• Operate the Services and provide customer support.
• Bill for orthotic devices and any optional fees.
• Send service announcements, security notices, and other transactional communications.
• Investigate abuse, fraud, and security events.
• Improve the Services through aggregated, de-identified analytics.

We use patient data only as directed by the practitioner under the BAA, for the following purposes:

• Designing and manufacturing prescribed orthotic devices.
• Attaching diagnostic findings, scans, and documentation to the patient's clinical record.
• Hosting embedded telehealth sessions.
• Generating reports the practitioner requests — including diagnostic PDFs and Letters of Medical Necessity.

7. Subprocessors

FitsPro uses the following subprocessors to operate the Services. Subprocessors handling PHI are bound by a written agreement, including a BAA where required by HIPAA.

8. Sharing and disclosure

FitsPro does not sell personal information. We do not share patient data except:

• With the practitioner's authorized clinical and administrative staff at the patient's organization.
• With authorized personnel at the manufacturing facility producing the patient's prescribed device.
• With our subprocessors listed above, only as needed to operate the Services.
• As required by law, court order, subpoena, or to respond to a lawful government request.
• As permitted by HIPAA (treatment, payment, healthcare operations) at the practitioner's direction.

9. Security

FitsPro implements administrative, physical, and technical safeguards designed to protect Protected Health Information and other sensitive data. These include:

• Encryption in transit (TLS 1.2 or higher) and at rest.
• Role-scoped access using Cognito user groups (practitioner / manager / administrator / super).
• No shared service accounts; every connection authenticates as a specific user.
• Audit logging of access to PHI in the clinical database.
• Periodic review of access permissions and security configurations.

10. Retention

• Practitioner-user accounts — retained for the lifetime of the account plus seven (7) years after deactivation to support audit, dispute resolution, and applicable regulatory requirements. Earlier deletion may be requested subject to legal and contractual obligations.
• Patient data — retained per the practitioner's record-retention policy and applicable HIPAA, state, and federal requirements. HIPAA generally requires retention of medical records for at least six (6) years from creation or last use, whichever is later; some states impose longer minimums, and pediatric records are typically retained until at least the age of majority plus the applicable minimum.
• 3D foot scans — retained as part of the patient's clinical record consistent with the schedule above, plus for the duration of any device warranty period.
• Pre-registration records — organizations that pre-register but never activate (no NPI verified, no patients added) are deleted after thirty (30) days.
• Operational logs — retained for security analysis, typically not more than ninety (90) days.

11. Patient rights

Patients have rights under HIPAA, including the right to access, correct, and request restrictions on the use of their health information. These rights are exercised through the patient's practitioner, who is the HIPAA Covered Entity holding primary responsibility for the patient's clinical record. FitsPro supports practitioner-routed requests under the Business Associate Agreement. Direct patient inquiries to FitsPro will be acknowledged and routed to the appropriate practitioner.

12. Practitioner-user rights

Practitioner-users may:

• Access and update their account information from inside the App or the admin portal.
• Request a copy or deletion of their personal information by opening a support ticket from inside the App or by contacting FitsPro.
• Withdraw from the Services by closing their FitsPro account.

Account closure does not automatically delete patient records — the practitioner's organization retains custodianship of those records consistent with its record-retention obligations.

13. State-specific notices

Residents of certain U.S. states have additional privacy rights. FitsPro honors the following:

• California (CCPA / CPRA) — California residents may request access, correction, and deletion of personal information, and information about categories of personal information collected. We do not sell personal information. We do not share personal information for cross-context behavioral advertising.
• Illinois (BIPA) — 3D foot scans are clinical imaging used for orthotic device design and manufacture; they are not used for biometric identification or biometric verification within the meaning of the Illinois Biometric Information Privacy Act. Scans are retained per the schedule in Section 10 and are protected by reasonable security measures consistent with industry standards for protected health information.
• Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), and other state laws — comparable rights are honored consistent with the operative state law.

To exercise state-law rights, contact us using the information in Section 17. Patient rights under HIPAA are exercised through the practitioner per Section 11.

14. Children's data

The Services are designed for licensed clinical practitioners and are not intended for direct use by individuals under the age of 18. Practitioners may treat pediatric patients within their clinical practice; clinical records of pediatric patients are handled under HIPAA's parental-authorization framework and applicable state minor-consent laws by the practitioner's organization. FitsPro does not knowingly collect personal information directly from children under 13.

15. International data transfers

The Services are operated from the United States. Practitioners and patients located outside the United States should not expect data protection equivalent to their home jurisdiction. The Services are not currently designed for processing data subject to the European Union / United Kingdom General Data Protection Regulation; practitioners outside the United States should evaluate the Services' suitability for their regulatory environment before adoption.

16. App Store and billing transparency

The FitsPro App is distributed through the Apple App Store. Orthotic devices are physical goods manufactured to clinical specification and are billed via Stripe outside of Apple's in-app purchase system, as permitted under Apple App Store Review Guideline 3.1.3(e) for physical goods and services consumed outside of the App.

17. Changes to this policy

FitsPro may update this Privacy Policy from time to time. Material changes will be posted at fitspro.clinic/legal/privacy and communicated to active practitioner-users via in-app notification or email. Continued use of the Services after a material change constitutes acceptance.

18. Contact

• Practitioner-users — open a support ticket from inside the App or the admin portal, or visit fitspro.clinic/support.
• Patients — contact your practitioner's organization, which holds primary responsibility for your clinical records.
• All inquiries — email privacy@fitspro.clinic.