Pulmosaic Privacy Policy

Version: pulmosaic-privacy-2026-10-01 Effective date: October 1, 2026

This Privacy Policy explains how AME Foresight LLC ("AME Foresight," "we," "us," or "our") collects, uses, shares, and protects information through the Pulmosaic iOS app, the pulmosaic.com website, and related services (together, "Pulmosaic"). It is part of the Pulmosaic Terms of Use.

1. Summary

• Pulmosaic is a free educational app for clinicians. There are no patient accounts.
• Case information must be de-identified. You must not enter patient names, record numbers, exact dates, or other identifiers.
• We host Pulmosaic on Amazon Web Services (AWS) in the United States under a business associate agreement with AWS. CT screenshots are stored in encrypted, private storage.
• We do not sell your information, share it for cross-context behavioral advertising, or show ads.
• Grant funders and drug or device manufacturers never receive your data or the identities of educators.
• You can export your data and delete your account in the app.

2. Information we collect

Account information

When you sign in with Apple, we receive an Apple user identifier and, depending on your Apple settings, your name and email address (which may be an Apple private relay address). We create an internal account ID and record your role, verification status, and account dates.

Professional verification

We collect your NPI and retrieve your public record from the CMS National Plan and Provider Enumeration System (NPPES), including your name, credential, taxonomy, and registry dates.

For invited educators, radiology educators, privacy reviewers, and library editors, we also collect specialty, license state and number, verification dates, a credential summary, disclosures of financial relationships from the prior 24 months, and records needed to administer honoraria.

Case information you enter

Pulmosaic stores the structured, de-identified case information you enter. Depending on the module, this can include banded age, history, exposures, symptoms, test results, imaging descriptors, pathology, treatments, outcomes, and your own diagnostic and treatment decisions. We also store the educational output Pulmosaic generates from those entries.

Case-based teaching

When you request teaching, we collect:

• the teaching questions you chose and a de-identified snapshot of the case, fixed at the time you submit, with dates shown only relative to the submission date;
• any CT screenshots you upload, with their size, type, and standard view;
• your attestations and when you made them;
• your Teaching Case Library preference;
• privacy review decisions; and
• educator commentary, radiology teaching, and any out-of-scope notices.

Learning reflections

If you record a learning reflection after reading teaching or a library entry, we store it with your account.

Legal acceptance

We record which version of the Terms and this Policy you accepted and when.

Usage events

The app sends coarse usage events, such as that a workflow step was completed, how long it took, and the content version. These events use a random workflow key. We use your account only to authenticate the request and do not store your account identity with the event. Events do not contain case content.

Technical and security information

We process session identifiers, session creation and expiry times, a generic client label, and request details such as method, path, and time. We use your network address to limit repeated sign-in attempts. We do not store device hardware identifiers or precise location.

Audit and security logs

To protect health information and meet HIPAA audit-control expectations, we keep security logs:

• Application audit log. An append-only record of access to cases and CT screenshots: which account acted, what action it took, on which record, when, and whether it succeeded. It contains no clinical text. It stores a salted hash of your network address, not the address itself.
• Infrastructure logs. AWS CloudTrail records of activity in our AWS accounts, load balancer access logs (which include the network address and request details for each request to our servers), and API and database logs.

Support communications

If you email us, we receive your message and contact details. Do not include patient information in email.

Information that stays on your device

• Face ID or passcode. Pulmosaic can ask your device to confirm it is you before unlocking the app. Apple handles this on your device. We never receive biometric data.
• Camera and photos. Pulmosaic uses the camera or photo picker only when you choose to add a CT screenshot. A photo taken in the app is not saved to your photo library.
• Offline cache. The app keeps an encrypted cache so it can work offline.
• Exports and PDFs. Account exports and PDFs you create are stored temporarily on your device until you finish sharing them.

We do not use advertising identifiers, third-party analytics, advertising, crash-reporting, or tracking tools. Pulmosaic does not store health data in iCloud.

3. How we use information

We use information to:

• create and secure your account and verify that you are a clinician;
• save, sync, display, export, and delete your cases and records;
• generate evidence-linked educational content from what you enter;
• run case-based teaching, including privacy review, routing to educators, and delivering commentary;
• review, edit, and publish Teaching Case Library entries when your setting allows;
• store learning reflections;
• verify educators and administer honoraria;
• provide support and keep Pulmosaic working;
• keep Pulmosaic secure, maintain HIPAA audit controls, detect and prevent fraud and misuse, and investigate security incidents;
• measure and improve Pulmosaic using usage events that are not linked to your account; and
• comply with law and enforce our Terms.

We do not use your information for advertising, sell it, or use it to train general-purpose artificial intelligence models. Pulmosaic software does not analyze CT images.

4. Legal bases

Pulmosaic is offered only in the United States. Where a law requires a legal basis for processing, we rely on: providing the service you asked for (contract); keeping Pulmosaic secure and improving it (legitimate interests); your choices, such as the library setting (consent); and legal requirements (legal obligation).

5. De-identification and HIPAA

• What we ask of you. Pulmosaic is designed for de-identified case information. The case fields exclude names, record numbers, and contact details, and teaching snapshots show dates only relative to submission. You must also keep identifiers out of CT screenshots. A human privacy reviewer checks each teaching request before any educator sees it, but that check reduces risk and cannot eliminate it.
• Our HIPAA role. AME Foresight is not a HIPAA covered entity. When a clinician uses Pulmosaic with de-identified information, HIPAA generally does not apply to that information. We do not sign business associate agreements with individual users. Where an institution signs a business associate agreement with us, we handle protected health information covered by that agreement consistent with a business associate's obligations under HIPAA and that agreement.
• If identifiers slip through. If we learn that identifying information was submitted, we will not release it to educators, will restrict access to it, and will delete or de-identify it. We may tell you so you can meet any duties you have to your employer or patients.
• How we protect it anyway. We treat all case information as sensitive health information, whether or not HIPAA applies. There is no government "HIPAA certification," and we do not claim one.
• No re-identification. We will not attempt to re-identify de-identified information, and we require our educators, reviewers, editors, and service providers not to attempt it.

6. How we share information

We share information only as described here.

Service providers

Our service providers may use information only to provide services to us.

Other recipients

• CMS NPPES. When you verify, we send your NPI to the public NPPES registry to look up your record.
• Privacy reviewers and educators. Pulmosaic privacy reviewers see your de-identified request. After review, assigned educators see the de-identified case snapshot, released CT screenshots, and your teaching questions. They never see your name or account identity.
• What you see about educators. You see an educator's credential summary and financial disclosures, never their name or account identity.
• Teaching Case Library. If your library setting is on, library editors review the completed case, and a published entry is available to verified clinicians. Published entries never identify you.
• Accredited CME provider. When we work with an accredited CME provider, it may receive what it needs to pay educator honoraria. It will receive your learning records only if you choose to seek credit, and we will tell you before that happens.
• Legal and safety. We may disclose information when required by law or valid legal process, or when reasonably necessary to protect the rights, safety, or security of users, patients, AME Foresight, or others.
• Business transfers. If AME Foresight or Pulmosaic is involved in a merger, acquisition, or sale of assets, information may transfer under this Policy's protections. We will give notice before information becomes subject to a materially different policy.

What we never do

• We do not sell personal information or health information.
• We do not share information for cross-context behavioral advertising or targeted advertising.
• Grant funders and drug or device manufacturers never receive user data, case material, or educator identities.

7. Security

We protect information with administrative, technical, and physical safeguards, including:

• encryption in transit and encryption at rest, with keys managed in AWS;
• private image storage with no public links, accessed only through the authorized app;
• role-based access, so each person sees only what their role needs;
• append-only audit logs of access to cases and CT screenshots, plus infrastructure access logs;
• session tokens and encryption keys kept in the device Keychain for that device only; and
• an encrypted offline cache that is excluded from device backups.

No system is perfectly secure. If a security incident affects your information, we will notify you and others as the law requires. Report security concerns to chase@ameforesight.com.

8. Retention and deletion

When you delete your account, we revoke your Sign in with Apple authorization, delete your uploaded files, and delete your account records. Copies in backups expire on the schedule above and are not restored for ordinary use. Audit and security logs are not deleted with your account; we keep them for the period above for legal, security, and HIPAA audit purposes, and they contain no clinical text.

We may keep information longer when the law requires it, to resolve a dispute, or to investigate a security incident. Account deletion does not remove copies you exported or placed elsewhere yourself.

9. Your choices and rights

Every Pulmosaic user can:

• Access and export your data in the app;
• Correct your case records in the app;
• Delete a case, or your entire account, in the app;
• Change your library setting for a request at any time until it is published;
• Review and revoke active sessions in the app; and
• Contact us at chase@ameforesight.com with any other request.

State privacy laws. Depending on where you live, state law may give you rights to know, access, correct, delete, or obtain a copy of your personal information, and to opt out of its sale, targeted advertising, or profiling. We honor access, correction, deletion, and export requests from all users, whether or not a state law requires it. We do not sell personal information, use it for targeted advertising, or use it for profiling that has legal or similarly significant effects, so there is nothing to opt out of. We treat a Global Privacy Control signal as an opt-out request.

Consumer health data laws. Laws such as Washington's My Health My Data Act, Nevada's consumer health data law, and Connecticut's consumer health data provisions protect health data about people acting in a personal or household capacity. Pulmosaic is a professional tool: information about you is collected in your professional capacity, and case information must be de-identified, which these laws exclude. We therefore do not believe these laws generally apply to Pulmosaic. We follow their core protections anyway: we collect case information only to provide the service you request, we never sell it, we do not use geofencing, and you can access and delete it.

Making a request. Email chase@ameforesight.com from the email address on your account or describe your account so we can verify it. An authorized agent may act for you with written permission that we can verify. We will respond within 45 days, or tell you if we need up to 45 more days as the law allows. We will not treat you differently for exercising your rights.

Appeals. If we decline your request, you may appeal by emailing chase@ameforesight.com with "Privacy appeal" in the subject line. We will respond in writing within 60 days. If you disagree with the outcome, you may contact your state attorney general.

10. Children

Pulmosaic is only for licensed clinicians who are 18 or older. It is not directed to children, and we do not knowingly collect personal information from children. Case information about a patient of any age must be de-identified.

11. United States only

Pulmosaic is offered only in the United States, and we store and process information in the United States. Do not use Pulmosaic from outside the United States.

12. Changes to this Policy

We may update this Policy. Each version has a new version string and effective date. For a material change, we will notify you in the app before it takes effect and ask you to accept the updated Policy where required. We will ask for your consent before using information already collected in a materially different way. We keep prior versions.

13. Contact

AME Foresight LLC Email: chase@ameforesight.com