Effective Date: 23 August 2026
Last Updated: 23 August 2026
Application: MySievert — Medical Radiation Tracker
Company: Apex Technology Group, Inc. (“Apex,” “we,” “us,” “our”)
This is a separate document from our Privacy Policy, provided with its own dedicated link as required by the Washington My Health My Data Act (RCW 19.373). It describes how we handle consumer health data specifically.
It applies to residents of Washington and Nevada, and we apply the same commitments to everyone, everywhere, because doing otherwise would mean building two products. It also covers the consumer health data provisions of Connecticut, New York, and other states with comparable requirements.
Where this policy addresses consumer health data, it controls over the general Privacy Policy and over the Terms of Service.
Your consumer health data is encrypted on your device with a key we do not hold and cannot obtain. We cannot read it, list it, count it, or describe it. Not with database access, not under legal compulsion, and not at your request.
Under Washington law, “consumer health data” is personal information linked or reasonably linkable to a consumer that identifies their past, present, or future physical or mental health status. In MySievert, that is:
| Category | What it is | Where it lives |
|---|---|---|
| Medical procedures and treatments | The imaging studies, nuclear medicine studies, interventional procedures, and radiation therapy courses you record, and their dates | On your device, and on our servers as ciphertext only |
| Bodily and anatomical information | The body regions associated with the procedures you record | On your device, and on our servers as ciphertext only |
| Radiation exposure measurements and estimates | Reference dose values attached to your records, any procedure parameters you choose to enter, and derived totals | On your device, and on our servers as ciphertext only |
| Your own notes | Anything you type into a record | On your device, and on our servers as ciphertext only |
| Health-related seeking behaviour | Searches you perform inside the app | On your device only. Search terms are never transmitted. |
| Aggregate procedure counts | Anonymous population totals of which catalog entries are commonly logged | On our servers, unlinked and unlinkable to any individual (Section 8) |
Precise location data is not collected under any circumstances. The application requests no location permission of any kind. It therefore cannot, and does not, infer anything from your proximity to a healthcare facility.
Biometric data is not collected. Device unlock via fingerprint or face is performed by your operating system; we never receive biometric information.
There is exactly one source.
You. Everything in your history is there because you typed it in.
We do not obtain consumer health data from:
We also do not derive or infer consumer health data from anything other than what you enter. We perform no inference, profiling, scoring, or interpretation over your records — and as our servers cannot read them, we could not do so even if we wanted to.
The purpose of collecting your consumer health data is to provide the record-keeping service you asked for: to store your radiation history, keep it available across your devices, and display it back to you. That is the whole purpose.
The specific uses are:
We do not use your consumer health data for advertising, marketing, profiling, research, product analytics, model training, scoring, or resale. We cannot use it for anything at all, because we cannot read it.
We do not process consumer health data for any purpose that is neither disclosed here nor reasonably necessary to and compatible with the purpose for which you provided it. If that ever changes, we will obtain your consent first.
Before you create your first health record, the app asks for your clear, affirmative, freely given, specific, informed, opt-in consent to collect consumer health data for the purposes in Section 4. Consent is not bundled with anything else, is not a pre-checked box, is not obtained through a dark pattern or a design that nudges you toward accepting, and is not a condition of downloading or opening the app. We record the fact and time of your consent.
Sharing consumer health data requires a separate consent, obtained separately from the consent to collect.
We do not share consumer health data, so we have never asked for this consent and do not expect to. If that ever changed, we would ask separately, specifically, and in advance — and you could decline and keep using the app exactly as before.
We do not sell consumer health data. Selling it would require your signed, written authorisation containing all elements the law requires; we have never sought such an authorisation and have no intention of doing so.
You may withdraw consent at any time, in the app or by emailing us. Withdrawal stops further collection. It does not by itself delete what you have already stored — use the deletion right in Section 7 for that, which you can exercise at the same time and which we will treat as a combined request if you say so.
We do not share consumer health data with any third party for that third party’s own purposes. There are no advertising partners, no analytics providers, no data brokers, and no research partners.
The following processors handle your data on our behalf, under contract, solely to operate the service, and are prohibited from using it for anything else. Each of them receives ciphertext only — none of them can read your consumer health data, and none of them ever holds your encryption key.
| Recipient | Category | What it actually receives | Can it read your health data? |
|---|---|---|---|
| Amazon Web Services, Inc. | Cloud hosting and storage | Your encrypted vault and key wraps, your opaque account identifier, and an entitlement boolean | No |
| Google LLC (Firebase Authentication) | Identity and authentication | Sign-in identity information only. No health data of any kind, ever. No encryption key, ever. | No — receives none |
| Google LLC (Play Services Block Store) | Device-to-device key transfer, Android | An end-to-end encrypted 32-byte wrapped key. No health data. | No |
| Apple Inc. (iCloud Keychain) | Device-to-device key transfer, iOS | An end-to-end encrypted wrapped key. No health data. | No |
| Google Play / Apple App Store | Distribution and payments | Product and transaction identifiers. No health data. | No — receives none |
Affiliates. Apex Technology Group, Inc. has no affiliate that receives consumer health data. If that changes, this policy will name the affiliate before any data reaches it.
We disclose data only in response to a valid and binding legal demand. What we are able to produce is an opaque account identifier, an entitlement boolean, and encrypted bytes that neither we nor the requesting party can decrypt. We will not build a mechanism to defeat this, and we would contest an order requiring us to.
In a merger, acquisition, or sale of assets, encrypted data may transfer to the successor, which is bound by this policy or must obtain your consent to any materially different treatment. A successor inherits the architecture, and therefore inherits the same inability to read your data.
With respect to your consumer health data, you have the right to:
Email apex@apextechnologygroup.io with the subject line “Consumer Health Data Request — MySievert”, or use the corresponding control in the app. Deletion is also available directly in the app.
We will respond within 45 days, extendable once by a further 45 days where reasonably necessary, in which case we will tell you within the first 45 days and explain why. An authorised agent may act on your behalf with proof of authority.
On a verified deletion request we delete your consumer health data from our production systems, and we notify all processors and affiliates that hold it — those listed in Section 6 — and instruct them to do the same. Deletion propagates to backups and archived systems within thirty (30) days as they expire in the normal rotation.
Because we hold no derived data, no analytics rows, no activity table, and no record of how many entries you have, there is no residual copy anywhere for us to overlook.
Deletion is permanent and irreversible. Export your history from the app first if you want to keep it — we cannot export it for you, because we cannot read it.
We verify a request by requiring you to act from the account in question. We hold no name, email, or other identifying information on our servers with which to verify you any other way, and we will not ask you for additional personal information solely to verify a request. If we cannot authenticate a request, we will tell you so promptly and explain why.
If we decline to act, we will tell you why within 45 days and explain how to appeal. To appeal, reply to that response or email us with “Appeal” in the subject line. We will decide the appeal within 45 days and give you a written explanation of our reasoning. If we deny the appeal, we will provide a method for you to contact the Washington State Attorney General’s Office to submit a complaint, or the corresponding authority in your own state.
Washington State Attorney General — Consumer Protection Division: https://www.atg.wa.gov/file-complaint
We maintain anonymous aggregate counts of which procedures are commonly logged across the platform, so we know which reference values to verify and refine first. These are population totals. They are not consumer health data, because they are not linked and are not reasonably linkable to any consumer.
That is a design property, enforced by four constraints:
If any one of these four constraints ever ceased to hold, this policy would change in the same release, or the change would not ship. Aggregate counts are not deleted on a deletion request, because there is nothing in them to trace to you.
We do not operate, use, or permit any geofence around any healthcare facility, provider, pharmacy, or any other location, for any purpose — not to identify consumers, not to track them, not to collect data, and not to send notifications or advertisements.
This is not merely a policy commitment. The application does not request location permission of any kind, has never done so, and is subject to a permanent internal rule that it never will. There is no technical means by which we could operate a geofence, and building one would require deliberately violating a documented product constraint.
Consumer health data is encrypted on your device with AES-256-GCM under a 256-bit key that is generated on your device, never transmitted in unwrapped form, and never held by or derivable by any server we operate or any processor. Transport is TLS 1.2 or higher, applied over data that is already ciphertext. Full technical detail, including key derivation, key wrapping, and key custody, is in Section 7 of the Privacy Policy.
We restrict access to production systems to the minimum personnel necessary to operate them. Such access yields ciphertext. There is no administrative view of consumer health data, because no such view can exist.
The corresponding risk, stated plainly: if you lose both your device and your recovery code, your consumer health data becomes permanently unreadable, including by us. Please set up a recovery code and export a PDF copy of your history periodically.
We retain your encrypted consumer health data for as long as your account exists, because its purpose is to be a durable history you can return to. There is no other retention period, and no secondary or derived copy.
We delete it when you delete your account, when you make a deletion request, or when you withdraw consent and ask us to delete.
MySievert is intended for adults and is not directed to children. We do not knowingly collect consumer health data from anyone under 18. An adult may record procedures relating to a person in their care within their own account, and is responsible for having the authority to do so.
This document is the Consumer Health Data Privacy Policy required by RCW 19.373.030, maintained as a separate document with its own dedicated link. We do not collect, use, or share consumer health data beyond what is disclosed here, and we obtain consent before collection and separate consent before any sharing. MHMDA provides a private right of action through the Washington Consumer Protection Act; nothing in our Terms of Service is intended to, or does, waive any non-waivable statutory right.
Nevada residents have equivalent rights of confirmation, access, deletion, and consent withdrawal with respect to consumer health data, and the same prohibition on sale without authorisation and on geofencing applies. Use the process in Section 7.
Where consumer health data provisions apply, we treat health data as sensitive data requiring opt-in consent, do not sell it, do not use it for targeted advertising, do not profile on it, and honour rights requests through the process in Section 7.
We apply the commitments in this document uniformly to all users regardless of residence. Building a weaker version for people whose state has not yet legislated would be a deliberate choice to treat them worse, and we are not going to make it.
We may update this policy. Where a change would materially affect how consumer health data is collected, used, or shared, we will obtain your consent before applying it to data already collected, and we will not apply a weaker policy retroactively to data collected under a stronger one. The effective date at the top of this document reflects the current version.
Email: apex@apextechnologygroup.io
Company: Apex Technology Group, Inc.
Subject line: “Consumer Health Data Request — MySievert”
Related documents: Privacy Policy · Terms of Service