Privacy Policy

Who we are

Delightful AI, Inc., doing business as Delightful Health ("Delightful," "we," or "us"), operates this website. This Privacy Policy explains how we handle information collected through our eligibility, interest, waitlist, provider, and organization inquiry forms, participant portal, and data contribution program. For privacy questions or requests, contact legal@delightfulhealth.com.

Your first step is an expression of interest

We use your responses to identify potential opportunities and follow up with you. It is not enrollment in research, not permission to request medical records, and not permission for unrestricted research or commercial use. Any later record collection or research participation requires a separate explanation and the appropriate authorization or consent.

Information we collect

You provide information directly when you complete a form or contact us. Participant information can include your name, email, medical conditions or your choice not to disclose them, health background, diagnostic journey, recent hospital stays or surgery, prescription counts, available record types, and whether you can access records. We also collect your selected opportunity or waitlist preference and any partner or referral code. Your answers may reveal health information, and the potential matches generated from them may also be health information.

Professional inquiries can include your name, email, organization, role, interests, and message. We keep submission identifiers, submission and update timestamps, and records of the permissions you provide. Our hosting and service providers may process technical information, such as IP addresses, browser information, and request logs, to operate and protect the site.

The initial forms do not retrieve medical records or connect to your patient portal. Please do not provide portal passwords, Social Security numbers, medical record files, or sensitive health details in professional inquiry messages or by email.

When your responses are saved

As you answer questions, a draft can be stored in your browser. When you select “See my study match,” your responses are saved on our servers before you provide your name or email. Selecting an opportunity updates that saved submission. If you then submit your name and email, we link those details to your saved answers so our team can follow up. Closing the page or clearing browser storage does not delete information already saved on our servers.

Provider and organization inquiry details are saved when you send the inquiry. We collect information from you and from your interactions with this website; the initial intake does not collect records from your healthcare providers.

How we use information

We use this information to provide the preliminary matching you request, maintain your interest or waitlist submission, respond to inquiries, discuss possible research opportunities or partnerships, and administer and protect our services. A potential match is preliminary and does not establish eligibility. We also use information where necessary to meet legal obligations, resolve disputes, and respond to privacy requests.

Research, de-identification, and sharing with researchers

Your intake responses are not anonymous. Before any later research participation or record collection, we will explain the project, the information needed, permitted uses, who can receive it, and applicable consent or authorization requirements.

Our research work may involve de-identifying information and sharing de-identified information with researchers for the purposes described in the applicable project materials and permissions. De-identification requires more than simply removing your name and email. It reduces the risk of identifying you but does not eliminate every privacy risk. Project-specific terms will explain any further sharing, commercial uses, retention, and limits on withdrawal or deletion. This Privacy Policy alone does not authorize retrieval of your medical records or unrestricted research, licensing, or commercial use of your health information.

Who receives information

Service providers supporting hosting, database storage, site analytics, internal communications, and follow-up may process information needed to perform those services. PostHog processes our site analytics data on our behalf in the United States, as described below. Participant signup notifications sent to our internal Slack workspace include a name, email, and submission identifier; eligibility answers are not included in those notifications. Professional inquiry notifications can include the submitted organization, role, interest, and message.

We do not share your identifiable health answers with researchers for research merely because you submit an interest form. Further research sharing is subject to the applicable permissions and project terms. Providing a referral code does not by itself authorize us to return your health answers to a referring partner.

We may disclose information when required by law or as necessary to protect rights, safety, or the security of our services. Information may also be involved in a merger, acquisition, or similar business transaction, subject to applicable law and existing privacy obligations. We do not sell the health information collected through these initial forms or provide it to advertising platforms for ad targeting.

Cookies and browser storage

The intake uses browser storage to carry answers between pages and a first-party cookie to connect your browser to a saved submission. The draft in session storage expires after approximately one hour, and the intake cookie lasts approximately 24 hours. These time limits do not delete server records. Authentication-related cookies may be used if you access an account feature. Disabling browser storage or cookies can affect the intake experience. The current intake does not use advertising pixels to send your answers to advertising platforms.

We use PostHog for site analytics to understand visits, page views, broad referral sources, device categories, approximate location, and progress through eligibility and contact submission. A random visit identifier is held in session storage and renewed after 30 minutes of inactivity. Analytics does not store your health answers, name, email, full referring URL, or URL query parameters, and is kept separately from intake submissions. PostHog receives your IP address to estimate your approximate location, then discards the IP address rather than storing it with analytics events. Analytics records are not sent to advertising platforms. PostHog analytics events, including approximate location, have a seven-year retention period under our plan. Browser privacy settings and blockers can limit these counts.

Analytics is disabled when your browser sends Do Not Track or Global Privacy Control. You can also turn it off for this browser below; your choice is saved in local browser storage and does not affect the intake. Turning it off stops future collection and does not delete records already saved.

Turn off site analytics in this browser

Retention

The following retention periods apply to website submissions and inquiries. Retention for enrolled participants is described in the data contribution program section below.

Our retention period for incomplete eligibility submissions is one year from the first server save, and for submitted expressions of interest and waitlist submissions is one year from the contact submission. You can request earlier deletion, subject to applicable legal requirements. Routine internal updates do not restart these periods.

We retain professional inquiries for as long as needed to respond and manage the resulting relationship, and retain information longer only when needed for a legal obligation, dispute, or other legally permitted purpose. Later research projects have separately explained retention terms. Removing a browser draft does not remove server records or internal notifications. Deletion requests are reviewed across the systems where we hold the information; backup copies may remain until they are overwritten through the applicable backup cycle.

Your choices and rights

You can choose available “not sure,” no-diagnosis, or “prefer not to disclose” options, or stop before submitting. To ask to access, correct, or delete information, obtain a copy, withdraw a permission, or stop follow-up, email legal@delightfulhealth.com. You do not need to create an account to make a request. Please do not include medical records in your email. We may ask for information reasonably needed to verify your identity and locate your submission.

Depending on where you live, you may have additional rights concerning your personal or consumer health information, including confirmation of collection or sharing, information about recipients, deletion, withdrawal of consent, or an appeal of a decision. We will handle requests and appeals under applicable law and will not unlawfully discriminate against you for exercising your rights. If we cannot fulfill a request, we will explain why and any available appeal process. A later research consent will explain withdrawal and any lawful limits concerning information already used or shared.

If you enroll in our data contribution program

This section applies only if you enroll in Delightful Health’s data contribution program and provide the required consents and authorizations. It supplements the website and interest-form disclosures above. Submitting an interest or waitlist form does not enroll you in the program or authorize collection of your medical records.

For participant records, the collection, use, disclosure, and retention terms in this section apply. Additional details and applicable limits are set out in your participation agreement, medical-record authorization, and State Supplements, if applicable. This Privacy Policy does not replace those documents. If terms conflict, the term that gives your information greater protection applies.

Information we collect

We collect information needed to administer your participation, including your identifying and contact information, date of birth, selected record custodians, sharing preferences, signed agreements and authorizations, consent history, collection status, and payment administration information.

With your authorization, we collect all available medical records that may lawfully be disclosed under the applicable authorizations, including authorized historical records and updates. Records may include medical history, diagnoses, treatments, medications, laboratory results, clinical notes, and other information within the authorized scope.

We do not request or authorize collection of psychotherapy notes, records protected by 42 CFR Part 2, or other sensitive records excluded by your participation agreement and applicable state supplement. Those documents describe the excluded categories in detail. If we receive excluded records, we will not use them or include them in de-identified data and will delete them once identified. References to “all available records” do not override these exclusions.

Sources and collection period

We obtain records from the healthcare providers, health plans, laboratories, pharmacies, hospitals, and other record custodians you select and authorize through the Delightful Health portal.

Records may be obtained through information exchange partners, including Fasten Health, a medical-record connection and transfer service, or through fax, phone, or online portals.

Enrollment requires a one-year record-sharing authorization, subject to your right to revoke it earlier. Where available, you may select how often connected records are shared. Your sharing frequency does not expand the authorized scope or extend the authorization period.

You may add or remove custodians through the participant portal. Collection remains subject to the required permissions, applicable exclusions, and authorization expiration.

How we use identifiable information

We use identifiable information to administer your participation, document permissions, retrieve and organize authorized records, verify receipt, arrange payments, prepare and verify de-identified information, respond to privacy requests, secure our services, and meet legal obligations.

Under this program, we do not use identifiable medical records to train AI models or share, transfer, license, or sell identifiable source records to independent data recipients for their own research or commercial use.

De-identification and commercial uses

We manage de-identification with review by a qualified expert. Before outputs are shared, transferred, licensed, or sold for the purposes described below, we de-identify the information using the HIPAA Expert Determination method under 45 CFR 164.514(b)(1) and satisfy other applicable legal requirements.

Qualifying de-identified information may be used for clinical research; analysis of disease and treatment outcomes; biotechnology, drug discovery, and drug development; scientific workflows; research tools, software, data products, and services; professional, consulting, and analytical services supporting these purposes; and development, training, testing, evaluation, benchmarking, and improvement of AI systems.

We may share, transfer, license, or sell qualifying de-identified information to clinical researchers, biotechnology and pharmaceutical companies, AI developers, and other commercial or nonprofit organizations in the United States or other countries. Delightful Health and recipients may earn revenue from these activities. Not all information will be shared, transferred, licensed, or sold.

We maintain qualifying de-identified information in de-identified form and do not attempt to re-identify individuals, except for limited testing expressly permitted by applicable law. Recipient contracts identify the information as de-identified patient information, prohibit attempts to identify individuals, and require equivalent or stricter restrictions for onward recipients.

Service providers and international access

We use service providers for record connection and transfer, hosting, storage, security, communications, electronic signatures, payment administration, identity verification where needed, and expert review of de-identification. Providers may access identifiable information as necessary for their authorized services, subject to applicable law and written confidentiality, security, and use restrictions.

Current providers include Fasten Health for record connection and transfer, Google Cloud Platform for hosting, SignWell for electronic agreements, and Tremendous, a research payments partner, for participant payments.

Participant records are currently hosted in the United States. Authorized Delightful Health employees outside the United States may access information for the purposes described in this section.

We may engage or replace service providers or change hosting locations subject to applicable law, your agreements, and any required notice, consent, or authorization.

Participant payments

Eligible participants may receive payment under the Contribution Payment Agreement provided during enrollment. Connecting an account alone does not earn payment. Qualification requires satisfaction of the offer’s conditions, including actual receipt of qualifying medical records.

We use contact information, qualification status, and payment administration information to arrange payments.

For the current $200 offer, we estimate the value of your data to Delightful Health at approximately $200, based on its reasonably estimated value for internal research and development, potential licensing revenue, and the costs of collection, processing, and de-identification. Not all information will be shared, transferred, licensed, or sold.

Participation is voluntary. Payment does not waive your privacy rights. Withdrawal after you have earned payment does not require repayment solely because you withdraw. Where required by applicable law, we provide a financial-incentive notice and obtain the required opt-in before enrollment.

Retention

We delete identifiable participant records and information linking them to you within 90 days after your one-year collection authorization expires or you withdraw, unless you request deletion sooner or sign a new authorization, subject to lawful retention exceptions described below.

Participation ends when your one-year authorization expires or you withdraw from the program, whichever happens first. We then stop further collection and creation of new de-identified data from your identifiable records. Where an applicable state supplement includes a separate authorization, program use and disclosure of identifiable medical information also stop when that authorization expires, except for deletion or legally required recordkeeping, unless you sign a new authorization. See your participation agreement and applicable state supplement for details.

We may retain signed agreements, authorizations, consent records, payment records, and other administrative information as permitted or required to document permissions, administer payments, comply with legal obligations, or establish, exercise, or defend legal claims. Information retained under an exception is used only for the purpose supporting that exception and retained only for the legally permitted period.

Qualifying de-identified information may be retained and used for authorized purposes without a fixed expiration, including after collection ends, you withdraw, or you request deletion, to the extent permitted by applicable law.

Withdrawal, cancellation, and deletion

You may withdraw from the program, cancel record collection, or request deletion by emailing legal@delightfulhealth.com or using the participant portal.

When we receive your cancellation, we will stop requesting your records and notify providers with outstanding requests. Deleting your records through the participant portal also disconnects access and stops future collection. Following withdrawal, we stop creating new de-identified outputs from your identifiable records as required by your agreement and applicable law.

Following appropriate identity verification, we delete identifiable information covered by your request, subject to lawful retention exceptions. We generally aim to complete deletion within 30 days after verification and comply with applicable legal deadlines. Verification does not extend a legal deadline unless applicable law permits it.

Withdrawal does not undo lawful disclosures already made. Previously released qualifying de-identified information may no longer be reasonably linkable to you. These limits do not waive applicable duties to delete information, stop use, notify recipients, or honor other privacy rights.

Access and other privacy requests

The rights and request methods described elsewhere in this policy also apply to enrolled participants. You may request access, correction, a copy, or deletion by email or through the participant portal. Available records may also be downloaded through the portal.

SignWell provides copies of signed agreements. You may request paper copies of your signed agreements or this policy by emailing legal@delightfulhealth.com. We provide requested paper copies within 30 days or sooner where required by law.

Adults, security, and updates

This website’s intake and inquiry services are intended for adults aged 18 or older. If you believe a child has submitted information, contact legal@delightfulhealth.com. We use safeguards intended to protect information, but no transmission or storage system can be guaranteed completely secure. If a breach involves your medical or other personal information, we will notify you as required by applicable state law and the Federal Trade Commission’s Health Breach Notification Rule. This notice does not represent that every activity on this website is covered by HIPAA.

We may update this policy and will post the revised effective date. Where required, we will provide additional notice or obtain consent before materially changing how previously collected information is used. An update does not itself supply new research consent.