Lenaya Health

Lenaya Health

Washington Consumer Health Data Privacy Policy

Effective Date: October 6, 2026  |  Last Updated: October 6, 2026

Clargenta AI LLC ("Clargenta," "we," "us," or "our") operates Lenaya Health. This separate Policy explains our collection, use, and sharing of consumer health data under the Washington My Health My Data Act, chapter 19.373 RCW, and how to exercise rights under that law.

This Policy applies to consumer health data within the Act's scope. Covered consumers include Washington residents and individuals whose consumer health data is collected in Washington, subject to the Act's definitions and exclusions. Consumer health data includes personal information linked or reasonably linkable to an individual that identifies the individual's past, present, or future physical or mental health status. Information inferred from other data can qualify even when it was not expressly supplied as health information.

1. Consumer Health Data We Collect and Why

We collect the categories below depending on what you, or a person authorized to act for you, provide and which features you use. We do not require every category from every consumer.

CategoryWhat it can includeCollection and use purposes
Medical-visit recordings and transcriptsAudio recorded in Lenaya or uploaded from another source; your voice and statements; statements of clinicians and other participants; descriptions of health conditions, treatment, or careRecord or store a visit at your direction; transcribe it; let you review and understand the conversation
Uploaded medical records and extracted informationLaboratory values, after-visit notes, imaging reports, referrals, medications, diagnoses, procedures, treatment plans, and text extracted from documentsStore and organize records you upload; extract their contents; make them available for your requested summaries and questions
Health questions and communicationsQuestions you ask about your records; information provided in a support request; health information supplied by an authorized caregiverAnswer your questions using your records; provide requested assistance; support authorized care organization
Generated and inferred health informationSummaries, answers, action items, follow-up checklists, identified health concerns and their recorded status, My Care Journey groupings, and laboratory trendsProvide the features you request and connect information across your visits and documents
Health-service and appointment informationVisit dates, clinician and facility names, medical specialties appearing in your records, and information indicating that you sought or received careLabel and organize visits and documents; help you locate information and understand follow-up steps
Location information associated with careA recording-location label, including a street address, if you enable it; a facility or location mentioned in the content you provideLabel the recording and organize your care information; location associated with obtaining care is treated as health data where the Act covers it
Identifiers, permissions, and technical information linked to healthAccount identifiers associated with health records; Care Circle membership and permissions; activity, device, or diagnostic information that reveals or is linked to health activityAuthenticate access; carry out your sharing choices; operate, troubleshoot, and secure the requested features

Depending on the content, these categories can reveal physical or mental health conditions, disabilities, symptoms, medications, diagnoses, tests, treatment, reproductive or sexual health, gender-affirming care, substance-use information, genetic information contained in records, and other health status or services. These are possible contents of the records you choose to provide, not a requirement to supply every type of information.

We process the data to provide the requested Services and authorized sharing, respond to support issues, and maintain secure operation. Where the Act permits processing for security or fraud prevention independently of consent, we limit it to that permitted purpose. We do not treat a general interest in improving our business as unlimited permission to reuse health content.

2. Sources of Consumer Health Data

We obtain these categories from:

3. Categories of Consumer Health Data We Disclose

Depending on your instructions and the permitted purpose, disclosure may involve any relevant category in Section 1. The recipient and purpose determine the scope:

Recipient category or situationData that may be disclosedPurpose and limits
People you authorize, including Care Circle membersThe recordings, transcripts, documents, summaries, questions, answers, health concerns, and associated visit details within the authorized scopeLet the people you choose participate in supporting your care; access depends on permissions and any required consent or authorization
Hosting, storage, transcription, document-processing, and AI processorsContent and associated identifiers needed for the requested processingProvide and operate Lenaya features under our instructions and contractual restrictions; Microsoft Azure is our identified provider for these functions
Support, security, error-monitoring, and communications processorsRelevant account and technical information and, only where necessary, health content involved in the authorized support, delivery, or security functionResolve your support issue, deliver requested functionality or messages, and secure the Services; access is limited to the function
Recipients of a legally required or otherwise legally permitted disclosureOnly information within the lawful scope of the request or permitted purposeMeet the applicable legal requirement or permitted security purpose, subject to health-data confidentiality restrictions
A qualifying successor or transaction recipientConsumer health data included in a legally permitted transactionContinue the Services or complete a transaction consistent with the Act and applicable obligations; a transaction does not remove existing legal protections

Under the Act, certain processor disclosures and qualifying business transfers are excluded from the definition of "sharing." We describe these disclosures so you understand how the Services operate; this does not expand any statutory exception. Other disclosures require the legal basis, consent, or authorization applicable to them.

Affiliates

We do not share consumer health data with corporate affiliates. There are no affiliate recipients to list under this Policy. If that changes, we will identify the specific affiliate recipients and meet applicable notice and consent requirements before the new sharing occurs.

Uses and disclosures we do not make

We do not sell consumer health data; disclose it for targeted or cross-context behavioral advertising; use it to create advertising profiles; or use it to train or fine-tune generative AI models. We do not provide it to data brokers or to insurers or employers for their independent use or decision-making.

4. Collection, Sharing, and Your Permission

We collect consumer health data with the consent required by the Act or to the extent necessary to provide a product or service you requested. We share consumer health data only with the required separate sharing consent or under an applicable exception, including sharing necessary for a requested service where the law permits it.

When consent is required, the request identifies the data categories, specific purpose, categories of recipients when applicable, and how to withdraw consent. Consent to sharing is separate from consent to collection. We obtain additional consent before collecting, using, or sharing additional categories or using the data for additional purposes where the Act requires it. Accepting a general privacy policy does not replace required consent.

You can remove a Care Circle member to stop future access through Lenaya. You can withdraw other applicable health-data consent by contacting us as explained below. If information is necessary for a feature you requested, withdrawing permission may prevent that feature from operating. Withdrawal of optional permission does not require acceptance of an unrelated use.

5. Your Washington Consumer Health Data Rights

You may:

How to submit a request

Email support@lenayahealth.com. You may use "Washington Health Data Request" as the subject, but a particular subject is not required. State the action you want, and use your account email address where possible. To withdraw consent, identify the permission you wish to withdraw. You can request withdrawal and deletion together.

Available account controls also let you export information, delete individual items or your account, and manage Care Circle access. If a control does not cover your request or you cannot access your account, email us. You do not have to create a new account.

We take reasonable steps to authenticate your identity and any representative's authority. We request only information reasonably necessary for that purpose. Do not send health records or identity documents with an initial request unless we ask for them through an appropriate verification process.

Response timing, cost, and verification

We act without undue delay and within forty-five days after receiving your request. Authentication does not restart or extend that deadline. When reasonably necessary and permitted by the Act, we may extend the response period once by another forty-five days; we notify you of the extension and reason during the original period.

Information in response to requests is free up to twice annually. Additional fees or refusals for requests that are manifestly unfounded, excessive, or repetitive are limited to what the Act permits and must be supported by an explanation. If we cannot authenticate a request using commercially reasonable efforts, we explain what additional information is needed or why we cannot act.

We do not unlawfully discriminate against you for exercising these rights.

What deletion and withdrawal do

A covered deletion request reaches consumer health data across our records and network, including applicable derived data and backups. We notify relevant affiliates, processors, contractors, and other third-party recipients of the request and require them to honor applicable deletion obligations.

Our ordinary process removes most health content promptly, with some derived data and routine encrypted backups clearing within about three weeks. If deleted information is reintroduced through system recovery during that window, we reapply the deletion. The Act's permitted backup-deletion limit does not replace this shorter ordinary schedule.

We retain information only where an applicable legal requirement or exception actually supports retention. General accounting convenience does not allow us to keep all of your medical content. Any retained information is limited to the supported purpose.

We cannot remove information from another person's memory or retrieve a copy they independently saved outside Lenaya. This does not excuse deletion of copies controlled by Lenaya or any legally required notice to recipients.

Withdrawing consent stops future collection or sharing covered by that consent, subject to applicable law. It does not itself erase existing records or undo a completed lawful disclosure. Ask for deletion as well if you want us to delete existing data.

Appeals and complaints

If we refuse a request, reply to the decision or email support@lenayahealth.com with "Washington Health Data Appeal" and the reasons you disagree. We respond in writing within forty-five days after receiving the appeal, explaining our decision and any action taken.

If the appeal is denied, we provide a way to contact the Washington Attorney General. You may also use the Attorney General's complaint page.

6. Contact

Clargenta AI LLC — Lenaya Health
Email: support@lenayahealth.com
Website: https://staging.lenayahealth.com