Building Responsible AI
in Healthcare

Lots going on in the world with AI right now. We believe in building responsible, secure, HIPAA compliant analytics and tools which always put PHI Information Security as top priority.

Review Our Privacy Policy

1. Privacy Policy

AXL Systems (“AXL,” “us,” “we,” “our”) is committed to protecting your privacy. This Privacy Statement sets forth AXL’s data collection and usage policies and practices regarding the Personal Information we maintain about you. For the purposes of this statement, Personal Information is information that can reasonably be used to directly or indirectly identify a person (hereinafter “Personal Information” or “PI”). Please note that this privacy policy applies only to PI and does not apply to information that qualifies as Protected Health Information (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).

2. Revisions to this Privacy Policy

Any information that we collect is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. When we do so, we will update the “Last Updated Date” above to indicate when those changes will become effective.

3. Collection and Use of Information

Information Collected From Third Parties and How It Is Used

Our primary purpose for collecting your information from our third-party business partners is to enable us to create a more comprehensive health profile on behalf of your provider and/or health plan and to offer further analytics tools to your provider and/or health plan. By combining your Personal Information with your HIPAA Protected Health Information that your provider and/or health plan maintains about you, AXL enables your provider and/or health plan to provide you with more comprehensive care. Once combined, that information is no longer considered PI and is then classified as PHI. In addition to collecting PI to augment existing PHI, we also collect your Personal Information in order to offer your provider and/or health plan tools to improve quality of care.

This Personal Information may include:

Contact Information: Including information such as your name, physical address, email address, or telephone number.

Demographic Information: We may collect certain information about population characteristics from you such as your ethnicity, nationality, age, geolocation information, gender, marital status, number of children, household size, language, number of generations in the household, and religious affiliation.

Career Information, Financial Information, Education Information, and Socioeconomic Status Information: This information may include details such as your occupation, payment information, affordability, business ownership status, education, income, personal property records.

Information Regarding Your Interests: Including information about your hobbies and purchase history.

Information Related to Your Health: This may include information collected from fitness trackers and cooking habits.

Personal Information We May Collect From You Directly

If you visit our website, we may collect certain information directly from you:

This may include:

Device Information: technical information associated with the device you use, such as the device type and model, system language, browser type, cookies, geographical location, and operating system, and technical identifiers that identify the device you use, such as IP address, and other unique identifiers; and

Usage Information: such as information concerning your browsing behavior, your purchasing patterns and trends, and engagement, such as how long you visit a page, what links you click on, what pages you visit, how many times you visit a page and how long it takes for you to come back.

4. Information that we share with Third Parties

We will not share any PI that we have collected from or about you with any third party except as described in this Privacy Policy.

Information Shared with Our Service Providers

We may engage third-party services providers to work with us to administer and support our business. These third-party services providers have access to your PI only for the purpose of performing services on our behalf. Examples include analyzing data, providing marketing assistance, and providing customer service to your provider and/or health plan. These companies and individuals may be located in a country whose data protection legislation is different from your country, and they will have access to your PI as necessary to perform their functions, but they may not share that PI with any other third party or use that data for any other purpose.

Information Disclosed in Connection with Business Transactions

We may disclose PI to a third party in the event of reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any of our business, assets, or stock, including in connection with bankruptcy or similar proceedings.

Information Disclosed for Our Protection and the Protection of Others

We may disclose your PI if legally required to do so, pursuant to a request from a governmental entity, or if we believe in good faith – after considering your privacy interests and other factors – that such action is necessary to:

Conform to legal requirements or comply with legal processes (including subpoenas);
Enforce or apply our terms of use and other agreements, including for billing and collections purposes;
Protect our property rights, rights and safety or property, rights and safety of a third party, our affiliated companies, or the public in general; or
Stop any activity that we consider illegal, unethical, or legally actionable

Information Disclosed in an Aggregated or Anonymized Manner

We also share aggregated or anonymized information about you with our business partners so that they can understand the services we offer and how those services can increase the quality of your care. However, such information is not considered PI because it is anonymized in such a way that it cannot reasonably linked back to the individual. The process for anonymizing this data complies with applicable anonymization standards.

Information Disclosed to Our Third-Party Business Partners

We may disclose such PI to our third-party business partners, including health plans and health systems for various purposes including, but not limited to, marketing and patient outreach.

Information Disclosed to Any Other Entity with Your Consent

We may disclose your information to any other party in instances where we first obtain your consent to do so.

5. International Transfer

Your PI may be transferred to, and maintained on, computers located outside of your jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Furthermore, whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable privacy legislation.

6. Your Choices About Your Information

Information Collected by Us

We respect the choices that you make with respect to your privacy and therefore provide you with the following options with respect to your PI. You may request:

Access to your PI to know what information we have collected about you;
That we correct your PI if such data is out of date or incorrect; or
That we delete any PI that we maintain about you.

In the event you decide to exercise these rights, we will do our best to honor your request upon a verified request.

7. The Security of Your Information

AXL takes reasonable administrative, physical and electronic measures to safeguard your Personal Information from unauthorized access or inappropriate use by third parties. Please be aware, however, that no method of transmitting and storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information that we maintain.

8. Data Retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

9. Contact Us

If you have any questions regarding this policy or would like to exercise your rights, please contact us at privacy@axl.health.

10. Your Rights as a California Resident

Scope of this Privacy Notice

This privacy notice describes the Personal Information we collect or process about California residents in connection with our Site, how we use, share, and protect that Personal Information, and what your rights are concerning Personal Information that we collect or process.

In this privacy notice, “Personal Information” has the same meaning as under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), California Civil Code Section 1798.83: information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include information that has been de-identified or aggregated.

Personal Information We Collect and Disclose, and For What Purpose

In the past 12 months, we have collected the Personal Information discussed above in the section titled Information Collected From Third Parties and How It Is Used.

We have also disclosed the following Personal Information for a business purpose in the past 12 months to the following categories of Entities:

We may share or sell your Personal Information as such terms are defined in the CCPA. In the past 12 months, the provision of our analytics products to our third-party business partners in order to accomplish our goals outlined above may constitute “selling” or “sharing” each category of Personal Information we maintain about you under the CCPA. However, please note that we do not sell or share the information of children under 16 years of age.

Please also be aware that some of the information above may qualify as “Sensitive Personal Information” under California law. This information may include certain details about your 1) racial or ethnic origin, 2) religious or philosophical beliefs, 3) health information or sexual orientation when used to uniquely identify you as an individual.

Your Rights as a California Resident

Under California law, users who are California residents have specific rights regarding their Personal Information. These rights are subject to certain exceptions described below. When required, we will respond to most requests within 45 days unless it is reasonably necessary to extend the response time.

Right to Disclosure of Information

You have the right to request that we disclose certain information regarding our practices with respect to Personal Information. If you submit a valid and verifiable request and we confirm your identity and/or authority to make the request, we will disclose to you any of the following at your direction:

The categories of Personal Information we have collected about you in the last 12 months.
The categories of sources for the Personal Information we have collected about you in the last 12 months.
Our business or commercial purpose for collecting that Personal Information.
The categories of third parties with whom we share that Personal Information.
The specific pieces of Personal Information we collected about you.

Right to Delete Personal Information

You have the right to request that we delete any of your Personal Information collected from you and retained, subject to certain exceptions. Upon receiving a verified request to delete your Personal Information, we will do so unless otherwise authorized by law.

Right to Limit the Use of Your Sensitive Personal Information

As some of the information we collect about you is considered “Sensitive” under the CCPA and may be used for reasons other than those set forth in final CPRA Regulations 11 CCR §7027(m), you have the right to request that we limit our use of your Sensitive Personal Information to that which is reasonably necessary to achieve the goals for which we collected the information. You may do so by selecting the “Limit the Use of My Sensitive Personal Information” on our website.

Right to Opt Out of the Sale or Sharing of Your Personal Information

You have a right to opt-out of the sale or sharing of your Personal Information. You may, at any time, direct businesses that sell your Personal Information to third parties not to sell or share your Personal Information.

To exercise your right to opt out of the sale or sharing of your Personal Information, please select the “Do Not Sell or Share My Personal Information” located on our website.

The Right to Correct

You have the right to correct any inaccurate Personal Information that we maintain about you.

Right to Non-Discrimination

You have the right not to be discriminated against for the exercise of your California privacy rights described above.

How to Exercise these Rights

You may submit a verifiable consumer request to us for disclosure or deletion of Personal Information by privacy@axl.health.

Alternatively, you may call us at (888)-738-0633

We will respond to verifiable requests for disclosure or deletion of Personal Information free of charge, within 10 days of receipt.

In order to protect your privacy and the security of your information, we verify consumer requests by using commercially reasonable verification processes. Any additional information you provide will be used only to verify your identity and not for any other purpose.

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney under Probate Code sections 4000-4465 may submit a request on your behalf.

How We Process Your Opt-Out Preference Signals

If you broadcast an Opt-Out Preference Signal via your web-browser we shall treat such signal as a valid request to opt out of the sale or sharing of your PI for information we collected when you interact with AXL’s website online. If you choose to visit the site from a different browser in the future, you will need to re-broadcast the signal from the new browser. To opt out of the sale or sharing of the other PI that we collect about you, please click on the “Do Not Sell Or Share My Personal Information” link on our website.

11. Colorado, Virginia, Connecticut, Utah, and Iowa Notice

Under Colorado, Virginia, Utah, Connecticut, and Iowa law, individuals who are residents of those states have specific rights regarding their Personal Information. For the purposes of this section, Personal Information shall have the meaning given to “Personal Data” under the Colorado Privacy Act, the Virginia Consumer Data Protection Act, the Connecticut Data Privacy Act, and the Utah Consumer Privacy Act, and the Iowa Privacy Law (collectively the “Applicable Laws”). These rights are subject to certain exceptions described below. When required, we will respond to most requests within 45 days unless it is reasonably necessary to extend the response time. Please note that not all of these laws are currently effective at this time, and your rights with respect to these laws will depend on whether such law has yet become effective.

The Sale of Your Personal Information

We may sell each category of Personal Data provided to us as the term “sale” is defined in the Applicable Laws.

2. Processing Sensitive Data

Additionally, some of the information we collect may constitute Sensitive Data under the Applicable laws. Such information may include personal data revealing racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, or citizenship or citizenship status; genetic or biometric data that may be processed for the purpose of uniquely identifying an individual; or personal data from a child under the age of 16. Please note that we do not intentionally collect the Personal Data of children under 16 and we do not sell such information.

3. Personal Information We Collect and Disclose

4. Your Rights

Right to access: You have the right to confirm whether we are processing your Personal Information and to access that data.

Right to correction: You have the right to correct inaccuracies in the Personal Information we hold about you.

Right to deletion: You have the right to request that we delete the Personal information that we hold about you.

Right to data portability: You have the right to request that we provide you with your Personal Information in a portable, and to the extent technically feasible, readily usable format that allows you to transmit your Personal Information to another entity. You may make up to two such requests per year.

Right to opt out of sales of your Personal Information: You have a right to opt-out of the sale of your Personal Information for purposes of:

Targeted Advertising;
The Sale of Personal Data; or
Profiling in furtherance of decisions that produce legal or similarly significant effects. 5

5. How to Exercise these Rights

You may make such requests yourself or you may designate an authorized agent to make such opt out requests on your behalf. In the event that you make a request on behalf of yourself, we may request additional documentation such as a state or government ID to confirm your identity. If you use an authorized agent to make this request, we will request documentation from the authorized agent to 1) demonstrate that such agent has the authority to make requests on your behalf, and 2) confirm your identity. When required, we will respond to most requests within 45 days unless it is reasonably necessary to extend the response time.

Please note that we only process your Sensitive Personal Data (as defined by the Applicable Laws) where we have consent to do so.

You may submit a consumer request to us to exercise your rights by emailing us at privacy@axl.health or by clicking on our “Do Not Sell Or Share My Personal Information” link on our website.

Building Responsible AI in Healthcare

Review Our Privacy Policy

Building Responsible AI
in Healthcare