1. Introduction
Fluidly, Inc. ("Fluidly," "we," "us," or "our") provides software and AI-assisted workflow orchestration technology designed to help organizations coordinate processes, information, decisions, actions, and outcomes.
Our services include the Fluidly Process Intelligence Operating System ("Platform"), our websites, integrations, communication interfaces, and related applications (collectively, the "Services").
In healthcare settings, Fluidly may support patient communications, medication refill coordination, electronic health record ("EHR") integrations, workflow automation, and related administrative and clinical support activities.
This Privacy Policy describes how Fluidly collects, uses, discloses, retains, and protects personal information in connection with its Services.
Our handling of information may differ depending on whether you are a website visitor, a business customer, an authorized Platform user, or a patient communicating through a participating healthcare organization.
2. Our Role in Healthcare Data Processing
When Fluidly processes protected health information ("PHI") on behalf of a healthcare organization subject to HIPAA, Fluidly may act as that organization's business associate.
In those circumstances, the healthcare organization generally determines the purposes of processing, and Fluidly processes PHI as authorized by the organization, the applicable Business Associate Agreement ("BAA"), and law.
The healthcare organization's Notice of Privacy Practices and applicable agreements govern its handling of patient information. This Privacy Policy does not replace those notices or agreements.
When Fluidly collects information for its own business purposes, such as website inquiries, sales communications, or business account administration, Fluidly is responsible for its own processing activities as applicable under law.
3. Information We Collect
Depending on your interaction with Fluidly, we may collect the following categories of information.
3.1 Personal and Contact Information
Names, business email addresses, phone numbers, organization names, job titles, account identifiers, and information voluntarily submitted through forms or communications.
3.2 Healthcare and Patient Information
When authorized by a participating healthcare organization, information processed through the Platform may include:
- Patient names, dates of birth, demographic details, and contact information.
- Patient identifiers and information needed for identity matching.
- Medication names, strengths, dosages, instructions, prescription history, and refill requests.
- Allergies, conditions, clinical observations, laboratory results, and encounter information.
- Prescriber, pharmacy, insurance, and authorization information.
- Patient communications and workflow outcomes.
The specific information processed depends on the authorized healthcare workflow and the data made available by the participating organization.
3.3 Communication Information
SMS message content, phone numbers, communication timestamps, delivery status, opt-in and opt-out records, support requests, and related messaging metadata.
3.4 Technical and Usage Information
Depending on the technologies deployed, Fluidly may collect IP addresses, device and browser information, authentication events, application activity, diagnostic information, and security logs.
3.5 AI and Workflow Information
Information needed to process authorized workflows, such as task context, structured workflow records, relevant source information, automated recommendations, decision explanations, actions, outcomes, and audit events.
4. Sources of Information
We may receive information directly from individuals, participating healthcare organizations, authorized users, connected EHR systems, permitted third-party integrations, communication providers, and technical systems supporting the Services.
5. How We Use Information
Fluidly may use information, subject to applicable agreements and law, to:
- Provide, operate, and maintain the Services.
- Identify and route authorized patient or business requests.
- Support medication refill and other healthcare workflows.
- Retrieve and organize relevant information from authorized systems.
- Assist authorized personnel with workflow coordination and review.
- Deliver transactional messages and service notifications.
- Maintain authentication, security, monitoring, and audit records.
- Troubleshoot technical problems and maintain reliability.
- Respond to inquiries and provide customer support.
- Comply with legal and contractual obligations.
Any use of PHI for analytics, product improvement, model development, or another secondary purpose must be separately authorized and legally permitted. This Policy does not itself authorize such uses.
6. Artificial Intelligence and Automated Processing
Fluidly may use artificial intelligence, language models, rules engines, and other automated technologies to interpret requests, organize information, identify relevant workflow context, and assist with operational decisions.
Automated outputs may be incomplete, inaccurate, or require additional review.
The availability of human review, clinical approval, and automated execution depends on the configured workflow, authorized permissions, and applicable safeguards.
Fluidly does not independently establish a clinician-patient relationship by providing its technology.
AI-assisted processing of PHI is subject to applicable agreements, approved service-provider arrangements, and legal requirements.
7. SMS Communications and Mobile Information
Fluidly may facilitate transactional SMS communications on behalf of participating healthcare organizations, including refill request acknowledgments, follow-up questions, processing updates, and assistance messages.
Where required, individuals must provide consent before receiving automated messages.
Message frequency varies based on the service requested. Message and data rates may apply.
Recipients may reply STOP to opt out of applicable SMS communications or HELP for assistance.
We do not sell or share your SMS opt-in data or personal information with third parties for marketing purposes.
Mobile phone numbers, text messaging originator opt-in data, and consent records are not shared with third parties or affiliates for their marketing or promotional purposes. Service providers may process necessary messaging information solely to deliver, support, secure, or administer authorized communications, subject to applicable restrictions.
SMS messages may pass through telecommunications networks and may be visible to persons with access to a recipient's device or messaging account. Patients should avoid sending unnecessary sensitive information through SMS.
Additional information is available in our SMS Messaging Terms.
8. Disclosure of Information
Fluidly may disclose information only as authorized and appropriate, including to:
- Participating healthcare organizations and their authorized personnel.
- Approved infrastructure, hosting, communication, integration, and other service providers.
- Authorized EHR systems and other connected systems.
- Professional advisers operating under applicable confidentiality obligations.
- Government authorities or other parties where legally required.
- Successors in a legitimate business transaction, subject to applicable legal and contractual restrictions.
PHI disclosures are subject to the applicable BAA and HIPAA requirements.
Fluidly does not authorize independent marketing use of patient information by service providers.
9. Data Security
Fluidly maintains or will implement administrative, technical, and physical safeguards appropriate to the information it processes and applicable legal obligations.
Depending on the deployed environment, safeguards may include access controls, authentication, encryption, tenant isolation, activity logging, monitoring, backup and recovery procedures, and incident-response processes.
No information system or transmission method can be guaranteed to be completely secure.
Specific security commitments for healthcare customers are governed by applicable agreements and documented security controls.
10. Data Retention
Fluidly retains information only for periods justified by the purposes of processing, contractual obligations, legal requirements, security needs, and applicable retention schedules.
Healthcare customer data is retained, returned, or deleted in accordance with applicable customer agreements and legal requirements.
Certain information may be retained where necessary for legal compliance, security investigations, dispute resolution, or legally required recordkeeping.
Retention periods may vary by data category and service.
11. Individual Privacy Rights
Depending on applicable law and the nature of the information, individuals may have rights to request access, correction, deletion, or information about certain processing activities.
Requests concerning patient records or PHI maintained for a participating healthcare organization should generally be directed to that healthcare organization. Fluidly may assist the organization as required by applicable agreements and law.
For personal information Fluidly controls directly, requests may be submitted using the contact information below.
We will respond in accordance with applicable legal requirements.
12. Cookies and Website Technologies
Fluidly's website may use cookies or similar technologies necessary for site functionality, security, preferences, and, where implemented, analytics.
Additional notice or consent will be provided where required by applicable law.
Any optional analytics or advertising technologies will be disclosed in accordance with applicable requirements.
13. Children's Privacy
Fluidly's public website and general business services are not directed to children under 13.
Healthcare workflows may involve information about minors when lawfully authorized by participating healthcare organizations.
Such information is processed subject to applicable healthcare privacy requirements, authorization rules, and contractual safeguards.
14. International Data Processing
Information may be processed in locations where Fluidly or its authorized service providers operate, subject to applicable law and contractual restrictions.
Healthcare customer data residency and cross-border access restrictions are governed by applicable agreements and technical configurations.
15. Privacy Incidents
Fluidly maintains or will establish procedures to identify, investigate, contain, and respond to suspected privacy and security incidents.
Where an incident triggers legal or contractual notification obligations, Fluidly will provide required notifications to the appropriate parties within applicable timeframes.
16. Changes to This Policy
We may update this Privacy Policy to reflect changes in our Services, processing activities, legal requirements, or business practices.
The updated version will be published with a revised effective date. Additional notice will be provided where required.
17. Contact Us
Fluidly, Inc.
Website: https://fluidly.ai
Privacy inquiries: support@fluidly.ai
Mailing address: 3540 Rawley St Corona CA 92882
For patient-specific medical record requests, please contact your participating healthcare organization.