Consumer Health Data Privacy Policy

    The health information PassOn holds, where it comes from, who receives it, and how to see it, withdraw your consent, or delete it.

    Last updated: October 30, 2026

    Who We Are

    PassOn is operated by Smart Integrations LLC, 218 E. Valley Rd STE 104-313, Carbondale, CO 81623, United States ("PassOn", "we", "us"). This policy covers health information about any person that we hold through the PassOn application at app.passon.cloud. It is written for the health data laws of Washington, Nevada and Connecticut, and it applies to everyone. Our Privacy Policy covers everything else.

    We do not sell health information, and we do not use it for advertising.

    Health Information We Collect, and Why

    About you, the account holder

    Your medical directives: whether you are an organ donor, where your living will is kept, and the name and phone number of your healthcare proxy. If you fill in an incapacitation plan, its medical section: your resuscitation (DNR) wishes, your medications, medical conditions, allergies, physician, health insurer and policy number, the treatments you would or would not want to prolong life, special needs, care instructions, and the people you name as your medical power of attorney. We use it to carry out your incapacitation plan, to deliver your plan after your death as you set it up, and to give it back to you in your printable documents and your Offline Copy.

    If someone reports that you cannot make decisions for yourself, a medical attestation: the physician's name, license and contact details, the facility, the diagnosis or condition, when the incapacity began and how long it is expected to last, notes, and any document supporting it. We use it only to decide whether your incapacitation plan should be activated.

    About the people in your care

    For a child, a parent, or another person who depends on you: their medications, medical conditions, dietary needs, care instructions, age, and the details of their doctor or care provider. We use it to tell the caretaker you chose how to look after them if you die, if you miss a check-in, or if you answer a check-in asking for help.

    For a child under 18, your consent as the child's parent or guardian covers this information. For an adult, we keep their medications, medical conditions, dietary needs and care instructions only after you confirm, in a tick box, that you are the person's guardian, conservator, or agent under a power of attorney that covers their health care. We record that you confirmed it, and when.

    In documents and messages

    A document you upload, such as an advance directive, may contain health information. We read its contents only when you press Analyze on it, to extract the details it contains for you. Anything you type to Marcus, our Support AI Assistant in the application, is used to answer you and is saved to your account until you clear it. Anything you type to Maria, our Welcome AI Assistant on our website, is used to answer you and, if you give her your email address, to write follow-up emails to you. If a death certificate is sent to us under the documented-death instruction, it may show the cause of death; we use it only to verify the death.

    Your Two Consents

    Before you first store health information, we ask for two separate consents: one to collect and store it, and one to share it with the people and companies listed below. Each has its own box, nothing is ticked for you, and we record each one. You need both to store health information in PassOn, because sharing it with the people you name is the only reason we keep it. If a medical attestation is submitted about you by one of your authorized contacts, it is covered by the same consents.

    How We Process It

    We store health information in our database and file storage, on servers in Dallas, Texas. All of it is encrypted at rest: every health detail you enter, about yourself or a dependent, is encrypted one value at a time with AES-256-GCM before it reaches a database whose disk is itself encrypted, and medical attestation documents are encrypted too. We use it only to keep it for you, show it to you, and deliver it as described below. If you choose to anchor a dependent's entry to the Bitcoin blockchain, PassOn keeps an encrypted copy of that entry as it was when you anchored it, health details included, so that the anchored version can be shown to you later. Only a fingerprint of the entry goes to the blockchain; no health information does. That copy is erased when you delete the dependent or withdraw your consent. No third party collects health information about your activity over time or across other websites through PassOn.

    Where It Comes From

    • You, the account holder, for everything about yourself and the people in your care.
    • The authorized contacts you named for your incapacitation plan, and you, for a medical attestation.
    • A family member or funeral director who sends us a death certificate.
    • Google Gemini, for the details it extracts from a document you ask us to analyze.

    If you use the microphone button to dictate into a form, your browser turns your speech into text. Some browsers, such as Chrome, send the audio to their maker to do this. We receive only the text.

    Who Receives It

    People you chose

    • A dependent's caretaker can read the health information you recorded for that dependent if you die, if you miss a check-in, or if you answer a check-in asking for help. We email them a personal link to a private page in PassOn; the email itself carries no health information. After a missed check-in, the page closes when you check in again; after a request for help, it stays open for 30 days. The email inviting a caretaker to accept the role when you name them carries no health information and does not name the dependent.
    • Your medical power of attorney, and the alternate you named, can read the medical section of your incapacitation plan if the plan is activated. We email them a personal link to a private page in PassOn; the email itself carries no health information.
    • Your authorized contacts can read the health information your incapacitation plan allows each of them to see, on their private page in PassOn, from the point your release setting allows. The emails we send them carry a personal link to that page and no health information. They also see who signed a medical attestation and whether a document was attached.
    • Your estate handler receives your estate summary after your death, which can include your dependents' care instructions and whether you have a DNR order or a healthcare proxy.
    • Your partner sees your dependents' health information only if you both have paid memberships and you choose to share dependents with them.

    We never send health information by text message to anyone you name. The texts we send go to you, about your own account, after you opt in (for example, that someone reported a concern about your well-being and how to cancel it), and to a Keeper, your estate handler or the second in line, an authorized contact, an emergency contact or a caretaker who said yes to texts themselves when they accepted their role: that their answer, action or care is needed, never what a report or concern says and never any care details.

    Companies that process it for us

    These companies handle health information only to provide their service to us. SendGrid and Twilio also use the information they receive for their own purposes, such as preventing fraud and meeting legal obligations, under their own privacy policies. Google receives health information only when you press Analyze on a document or type it to Marcus, Wordsmith or Maria, our AI agents.

    CompanyWhat it does for usHow to contact it
    VultrHosting and databasePrivacy policy
    Cloudflare R2File storage and backupsPrivacy policy
    SendGrid (Twilio)Email deliveryPrivacy policy
    TwilioText messages to you, and to a Keeper, estate handler, second in line, authorized contact, emergency contact or caretaker who said yes to texts themselves; never health informationPrivacy policy
    Google (Gemini)AI features you startPrivacy policy

    When the law requires it

    We disclose health information when a law, court order, or lawful government request requires it, limited to what is required.

    PassOn has no affiliates, and no one else receives health information from us.

    Your Rights, and How to Use Them

    • See it. You can see everything you entered in the application, and your Offline Copy (under Reports, and in Settings) downloads all of it. You can also ask us to confirm whether we collect, share or sell health information about you (we never sell it) and to give you a copy, together with a list of everyone we have shared it with and how to contact them.
    • Correct it. You can change anything you entered in the application at any time, or ask us to correct it.
    • Withdraw your consent. You can withdraw at any time under Settings, Data & Privacy, Health information, after confirming it is you. Withdrawing erases the health information you stored (Settings lists exactly what), including the copy kept with any dependent you anchored, and we collect and share none after that. If an incapacitation check about you is in progress, the people deciding it are using that information, so Settings asks you to email us instead and we handle it by hand.
    • Delete it. You can delete a dependent, clear any field of your incapacitation plan, clear your medical directives on your profile (Profile, Medical), delete a single medical attestation (Settings, Data & Privacy), withdraw your consent, or delete your whole account in Settings. If you anchored a dependent, the copy kept with that anchor still holds what the entry said when you anchored it, even after you clear a field; deleting the dependent or withdrawing your consent erases that copy. You can also ask us to delete any health information about you, including medical directives taken from a document you analyzed. We delete it within 30 days from our database and our files, and copies in our backups are gone within 30 days after that. We also tell each company listed above, and each person we sent it to, about your request and ask them to delete it too.

    If you are not a PassOn account holder, for example a dependent, or the relative of someone who uses PassOn, you have the same rights to health information about you. Email us and we will act on it; because it is part of someone else's plan, we may need to tell them.

    To make any request, email privacy@passon.cloud. We check that the request comes from the person it concerns, or from someone with authority to act for them, and we answer within 45 days. If we need longer, we will tell you why within those 45 days and answer within another 45.

    Appeals. If we refuse a request, you can appeal by replying to our answer with the word "Appeal". A founder who did not make the first decision reviews it and answers you in writing within 45 days, with the reasons. If we deny your appeal, you can complain to your state's Attorney General: in Washington at atg.wa.gov/file-complaint, in Nevada at ag.nv.gov, and in Connecticut at portal.ct.gov/ag.

    Changes to This Policy

    This policy takes effect on the date at the top. When we change it, we post the new version here and change that date, which moves only when the text changes. If a change adds a kind of health information, a purpose, or a recipient, we ask for your consent again before it applies to you. For any other change that reduces your rights, we ask you to confirm that you have read the new version the next time you log in or open PassOn.

    Contact Us

    • Privacy: privacy@passon.cloud
    • Mail: Smart Integrations LLC, 218 E. Valley Rd STE 104-313, Carbondale, CO 81623