Privacy Policy

Monte Sereno Health | Global Platform and Healthcare Marketplace

Proposed effective date: To be entered when approved and published. | Working revision: October 27, 2026.

This Privacy Policy explains how Monte Sereno Holdings, Inc. (“Monte Sereno Holdings”, “MSH”, “we”, “our”) processes personal information through the Monte Sereno Healthcare Operating System, websites, applications, communications, AI-assisted functions and related services (collectively, the “Platform”). It applies to patients, visitors, caregivers, professionals, marketplace participants and other individuals, subject to the additional notices identified below. Our initial intended markets are the United States, Nigeria, Kenya and South Africa; functions and legal requirements differ by country.

Our guiding principle: information entrusted to the Platform for healthcare should support that care and related legitimate operations, with strong protection against misuse. We will distinguish identifiable health information from de-identified or aggregated statistical products and will not treat an ordinary visit to our website as consent for every processing activity.

Monte Sereno Holdings is the commercial Platform operator. Monte Sereno Health, Inc. is a separate United States 501(c)(3) organization that conducts its own charitable and population-health initiatives. The nonprofit is not automatically the controller of all Platform data merely because the names are similar. When a nonprofit project collects information, its own project notice, consent or research documentation identifies the responsible organization and applies alongside this Policy where relevant.

A physician, hospital, pharmacy, laboratory, insurer, employer health plan, public-health body or other independent business using the Platform may separately determine why and how it processes your information. Depending on the transaction and applicable law, MSH may act as a controller/responsible party, a joint controller, or a processor/service provider acting on that organization’s instructions. A provider’s legally required notice may also apply to its care, records and billing. Where roles overlap, we aim to identify the responsible parties at the point of service.

We collect only information reasonably necessary for the particular service, its security, agreed research, or another lawful purpose. Categories may include:

• Identity, account and contact information: name, login credentials, contact details, age or date of birth where necessary, language, country, locality, account roles, household or guardian relationships and authentication records.
• Clinical and sensitive health information: symptoms, histories, allergies, current and previous medicines, diagnoses, test results, images, vital signs, telemedicine notes, care plans, electronic health records, referrals, clinician messages, prescriptions, and information voluntarily entered into AI-supported health tools.
• Independent-provider and vendor information: professional qualifications, specialty, licensing, certifications, practice details, services offered, identity-verification details, commercial account and permitted payment information.
• Transaction and coverage information: purchases, orders, price quotations, prescriptions needed for dispensing, fulfillment and delivery data, payments, refunds, insurer/benefit eligibility and policy applications, subject to the role of the relevant licensed seller or insurer.
• Community and communication information: content you elect to publish or share in prayer spaces, support communities, chats, moderated forums, feedback and customer-support communications. Private health records are not automatically made public in social or community spaces.
• Device and technical information: IP address, operating system, browser, approximate location, authentication and audit events, app diagnostics, security logs and cookie or similar technology data. Precise location, microphone, camera, recording or connected-device data is collected only when enabled for an applicable feature and lawful requirements are met.
• Information from authorized third parties: treating clinicians, laboratories, pharmacies, insurers, banks or employer programs, caregivers, linked health apps/devices and partner organizations, only under appropriate authority, technical integrations and data-use terms.

Subject to jurisdiction-specific lawful bases, we use information to provide accounts and services; connect patients with independent providers; maintain records and referrals; route orders and payments; verify vendors and medicines; communicate service information; protect safety and security; meet legal requirements; conduct permitted quality improvement; and measure platform performance. Sensitive data are processed only with the applicable additional condition or safeguard, which may include explicit consent, healthcare necessity under relevant law, professional confidentiality, legal obligation or another permitted basis. Consent is not the only lawful basis and can be withdrawn where consent is the basis, subject to lawful record-retention requirements.

AI-assisted services and decision support

The Platform may provide AI-assisted information and clinical support through products such as Starpilot, Dr. AIva and other healthcare agents, and may use factuality/evidence-support tools such as TruthLink/Ifá as available. These functions may analyze information you provide, relevant available records and permitted evidence sources to answer questions, explain results, prepare recommendations for review, support navigation and surface possible safety concerns. AI outputs can be incomplete or wrong; they are not a substitute for emergency care, a clinician’s independent judgment or other required professional review. We retain appropriate human oversight of consequential clinical decisions and do not represent that an AI system is error-free.

Population intelligence and analytics

Aegis and related analytics may examine appropriately authorized events, service utilization, prices, quality indicators, trends and potential public-health signals. Where lawful and sufficiently reliable, MSH may provide research findings, benchmarks, planning insights and aggregated or de-identified actuarial/statistical products to organizations such as insurers, providers, public-health partners and researchers. We do not offer unrelated parties unrestricted access to identifiable patient records as a general-purpose data product. We prohibit contractual recipients from attempting to re-identify properly de-identified datasets and assess re-identification risk, small-group disclosure and other safeguards before release.

We do not authorize third parties to use identifiable health information obtained through the Platform to set an individual’s insurance premiums, deny coverage, or target sensitive advertising except where a separate, lawful, transparent service specifically permits the activity and any required explicit authorization has been obtained. MSH may process insurance applications and related information on behalf of properly authorized insurers or intermediaries under their separate notices.

Research, traditional medicine and public-health projects

Traditional African Medicine (TAM), Traditional Birth Attendant (TBA), maternal-health, pharmacopoeia and other research activities may involve information about patients, practitioners, communities, observations, medicinal knowledge and biological or botanical samples. Project-specific participant information sheets, research approvals and agreements will specify research purposes, the organizations involved, community and traditional-knowledge rights, benefit-sharing rules, and any additional permissions. Participation in ordinary Platform services does not by itself authorize unrestricted research use or commercialization of identifiable personal information or indigenous knowledge.

We share information on a minimum-necessary or otherwise proportionate basis, under applicable law and contracts, with:

• Your authorized providers, pharmacies, laboratories, insurers and other selected service partners as needed to deliver a requested transaction, coordinate care and meet their independent legal obligations.
• Service providers helping operate the Platform, such as cloud hosting, cybersecurity, communications, translation, AI infrastructure, payments, analytics and customer support, subject to appropriate confidentiality, security and processing controls.
• Caregivers, guardians or others you designate, subject to the permissions, identity verification and legal rights applicable to the particular health record.
• Researchers, ethics-approved projects or public-health authorities when permitted by law, consent and approved protocols; when possible we minimize or de-identify data.
• Authorities and regulators where a valid legal obligation, lawful process, patient-safety reporting or other permitted legal ground applies.
• A successor following a legitimate business transaction subject to applicable privacy law, contractual restrictions, clinical confidentiality and any required notice or consent.

The nonprofit and the for-profit do not have an unrestricted right to exchange personal health data. Transfers between them must serve a defined lawful purpose and follow appropriate agreements, permissions, and research or other governance rules.

We may send account, security, appointment, order and other necessary service notices. Optional marketing, health campaigns or partner offers are subject to applicable consent, preference and opt-out requirements. We will not use confidential consultation content, diagnoses or identifiable health information to build third-party advertising audiences or permit third-party advertising pixels on authenticated health-record screens. Nonessential analytics or advertising cookies will be used only where permitted by the applicable notice and user choices. Cookie settings and consent controls should be available on relevant websites or apps.

Some Platform features allow members to exchange posts, encouragement, prayers, personal experiences or other community content. Joining or posting is optional. Information shared in a group or public space may be seen or copied by other participants, depending on its settings. Do not post another person’s medical details without authority. We may apply community moderation and remove content that threatens privacy, safety or others’ rights. A private clinical record remains subject to its own access controls and is not disclosed to a group merely because a member uses that group.

Adults generally administer their own accounts. Parents, legal guardians and other properly authorized representatives may establish and manage records or permitted care interactions for minors, infants or individuals requiring assistance, consistent with local laws and a provider’s professional obligations. We seek age-appropriate notices and permissions and limit direct access by minors where applicable. A minor’s information may not be visible to every adult account holder merely because they are in the same household; applicable rules about confidentiality and evolving capacity take precedence.

We use risk-based organizational and technical safeguards appropriate to the sensitivity of information, such as access controls, encryption where appropriate, secure transmission, role separation, monitoring, incident response, backup and recovery procedures, vendor due diligence, audit trails and workforce confidentiality. No system can guarantee absolute security. Users should protect credentials and promptly report suspected unauthorized account access to privacy@monteserenohealth.com.

We keep personal information for the time reasonably needed for the stated purposes and as required by medical-record, pharmacy, payment, tax, professional, safeguarding and other applicable laws. Retention varies by country, record type, age and relevant provider obligations. When lawful and appropriate, we delete, anonymize or restrict records when no longer required. Closing an MSH account does not automatically erase legally required clinical records held by independent providers or other entities.

We intend to serve individuals and organizations across the United States, Nigeria, Kenya, South Africa and additional countries. Personal information may be processed in countries other than the country where it was collected only where an applicable legal transfer mechanism, safeguard, authorization, exception or consent permits. Local hosting, localization, public-sector restrictions and cross-border rules are assessed per product and jurisdiction. We do not claim that all information is stored exclusively in the United States, or that continued use of the website alone authorizes every international transfer. Relevant service notices may identify specific hosting locations, overseas recipients and transfer safeguards.

Depending on applicable law and your relationship with MSH or an independent provider, you may request information about processing, access to your data, correction, deletion where allowed, portability, restriction or objection, withdrawal of consent, review of a qualifying automated decision, and information about international transfers. You may also have rights to complain to a regulator and to opt out of qualifying direct marketing. We may need to verify identity, clarify the relevant service and consult a provider that independently controls its records before responding. Some requests are limited by required record retention, professional duties, public-health obligations or other lawful exceptions.

To exercise rights, email privacy@monteserenohealth.com. Please do not include full medical records in an unencrypted initial email. If another organization controls the requested record, we will, where appropriate, direct you to that organization or coordinate the response.

United States

U.S. federal and state privacy rules may apply, including HIPAA only where the relevant entity and information fall within its scope. Where MSH functions as a business associate of a HIPAA-covered organization, the applicable contract and HIPAA obligations control the covered information. Some non-HIPAA consumer health services may be subject to the Federal Trade Commission Act, the FTC Health Breach Notification Rule and state consumer-health or privacy laws. Where required, separate HIPAA Notices of Privacy Practices, state notices, authorizations and user choices will be provided. These laws are not replaced by this general Policy.

Nigeria

The Nigeria Data Protection Act 2023 and the Nigeria Data Protection Commission’s General Application and Implementation Directive 2025 may govern relevant processing. MSH will identify an appropriate lawful basis and sensitive-data condition, respond to applicable data-subject rights, and assess security, registration, impact assessment, vendor arrangements and international transfers. Additional healthcare confidentiality or professional rules may apply.

Kenya

Kenya’s Data Protection Act 2019 and applicable 2021 regulations govern relevant rights and obligations, including health data and cross-border processing. The Digital Health Act 2023 and any operative regulations or certification requirements may also affect health information systems and interoperability. Relevant services may require additional registration, certification, impact assessment, consent or contractual safeguards, depending on their operation.

South Africa

The Protection of Personal Information Act 4 of 2013 (POPIA) governs relevant processing, including special personal information, children’s information, direct marketing, automated decisions and transfers outside South Africa. Requests may be made through the designated MSH privacy contact and, where applicable, a local Information Officer or participating responsible party. Additional health-professional and access-to-information requirements may apply.

We investigate suspected unauthorized access, loss and inappropriate disclosure and notify affected people, customers, professional partners and relevant authorities when required by applicable law and our agreements. Different jurisdictions impose different triggers and deadlines; one universal deadline would not be accurate. Users can report concerns to privacy@monteserenohealth.com.

We may update this Policy to reflect changed features, law, providers or safeguards. We will show the applicable effective date and provide additional notice or obtain renewed consent where law or the material change requires it. Previous versions may be made available upon reasonable request where practicable.

Monte Sereno Holdings, Inc. | Privacy Office | Email: privacy@monteserenohealth.com | Website: https://staging.monteserenohealth.org/ (staging site; replace with the production URL at publication). An appropriate physical mailing address, relevant country representatives or privacy officers, and any mandated registration details will be published once confirmed before launch in each jurisdiction.